ALPHA SERVICES AND HOLDINGS S.A.

ANNUAL REPORT

For the period from 1 January to 31 December 2024

(In accordance with Law 3556/2007)

Athens, March 6, 2025

1 | ANNUAL FINANCIAL REPORT

Contents

Statement by the Members of the Board of Directors .............................................................................................................................................. 5

Board of Directors’ Management Report as at 31.12.2024 ....................................................................................................................................... 6

Explanatory Report of the Board of Directors of Alpha Services and Holdings S.A. for the year 2024 ................................................................ 34

Sustainability Statement FY 2024......................................................................................................................................................................... 37

Corporate Governance Statement ..................................................................................................................................................................... 154

Independent Auditor’s Report on Sustainability Statement ................................................................................................................................... 230

Independent Auditor’s Report ............................................................................................................................................................................... 234

Group Financial Statements as at 31.12.2024 ....................................................................................................................................................... 244

Consolidated Income Statement ........................................................................................................................................................................... 245

Consolidated Statement of Comprehensive Income ............................................................................................................................................. 246

Consolidated Balance Sheet .................................................................................................................................................................................. 247

Consolidated Statement of Changes in Equity....................................................................................................................................................... 248

Consolidated Statement of Cash Flows ................................................................................................................................................................. 250

Notes to the Consolidated Financial Statements................................................................................................................................................... 251

GENERAL INFORMATION ...................................................................................................................................................................................... 251

1. Accounting policies applied ................................................................................................................................................................ 253

1.1 Basis of presentation ....................................................................................................................................................................................... 253

1.2 Material accounting policies ............................................................................................................................................................................ 255

1.3 Significant accounting judgments and key sources of estimation uncertainty ................................................................................................ 273

2. Restatement of financial statements ................................................................................................................................................. 276

INCOME STATEMENT ............................................................................................................................................................................................ 281

3. Net interest income ........................................................................................................................................................................... 281

4. Net fee and commission income ........................................................................................................................................................ 281

5. Dividend income ................................................................................................................................................................................ 282

6. Gains less losses on derecognition of financial assets measured at amortised cost .......................................................................... 282

7. Gains less losses on financial transactions ......................................................................................................................................... 283

8. Other Income ..................................................................................................................................................................................... 283

9. Staff costs ........................................................................................................................................................................................... 284

10. General Administrative expenses ....................................................................................................................................................... 285

11. Impairment losses and provisions to cover credit risk ....................................................................................................................... 286

12. Expenses relating to credit risk management .................................................................................................................................... 286

13. Impairment losses on fixed assets and equity investments ............................................................................................................... 287

14. Gains/(Losses) on disposal of fixed assets and equity investments ................................................................................................... 287

15. Provisions ........................................................................................................................................................................................... 287

16. Transformation costs ......................................................................................................................................................................... 287

17. Income tax .......................................................................................................................................................................................... 287

18. Earnings/(losses) per share ................................................................................................................................................................ 289

ASSETS ........................................................................................................................................................................................................... 291

19. Cash and balances with Central Banks ............................................................................................................................................... 291

20. Due from financial institutions ........................................................................................................................................................... 291

21. Trading securities ............................................................................................................................................................................... 291

22. Derivative financial instruments (assets and liabilities) ..................................................................................................................... 292

23. Loans and advances to customers ...................................................................................................................................................... 298

24. Investment securities ......................................................................................................................................................................... 300

25. Investments in associates and joint ventures .................................................................................................................................... 301

26. Investment property .......................................................................................................................................................................... 303

27. Property plant and equipment ........................................................................................................................................................... 304

28. Goodwill and other intangible assets ................................................................................................................................................. 304

29. Deferred tax assets and liabilities ...................................................................................................................................................... 305

30. Other assets ....................................................................................................................................................................................... 306

LIABILITIES ........................................................................................................................................................................................................... 307

31. Due to Banks ...................................................................................................................................................................................... 307

32. Due to customers ............................................................................................................................................................................... 307

33. Debt securities in issue and other borrowed funds ........................................................................................................................... 307

34. Liabilities for current income tax ........................................................................................................................................................ 309

35. Employee defined benefit obligations ............................................................................................................................................... 309

36. Other Liabilities .................................................................................................................................................................................. 311

37. Provisions ........................................................................................................................................................................................... 311

EQUITY ........................................................................................................................................................................................................... 313

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38. Share Capital ...................................................................................................................................................................................... 313

39. Share premium ................................................................................................................................................................................... 313

40. Other Equity Instruments ................................................................................................................................................................... 313

41. Reserves ............................................................................................................................................................................................. 314

42. Retained Earnings............................................................................................................................................................................... 315

ADDITIONAL INFORMATION ................................................................................................................................................................................. 316

43. Contingent liabilities and commitments ............................................................................................................................................ 316

44. Group Consolidated Companies ......................................................................................................................................................... 318

45. Disclosures Law 4261/5.5.2014 ......................................................................................................................................................... 328

46. Segment Reporting ............................................................................................................................................................................. 329

47. Risk Management ............................................................................................................................................................................... 331

47.1 Credit Risk .......................................................................................................................................................................................... 331

47.2 Market Risk ........................................................................................................................................................................................ 369

47.3 Liquidity risk ....................................................................................................................................................................................... 373

47.4 Fair value of financial assets and liabilities ......................................................................................................................................... 378

47.5 Transfers of financial assets ............................................................................................................................................................... 383

47.6 Offsetting financial assets - liabilities ................................................................................................................................................. 384

48. Capital Adequacy ................................................................................................................................................................................ 385

49. Related party transactions ................................................................................................................................................................. 387

50. Auditor’s fees ..................................................................................................................................................................................... 388

51. Disclosure of Law 4151/2013 ............................................................................................................................................................. 389

52. Assets held for sale ............................................................................................................................................................................. 389

53. Corporate events relating to the Group structure ............................................................................................................................. 392

54. Discontinued Operations .................................................................................................................................................................... 394

55. Insurance Contract Liabilities ............................................................................................................................................................. 395

56. Strategic Plan ..................................................................................................................................................................................... 397

57. Events after the balance sheet date ................................................................................................................................................... 398

Financial Statements of Alpha Services and Holdings S.A. as at 31.12.2024 ................................................................................................. 400

Income Statement ....................................................................................................................................................................................... 401

Statement of Comprehensive Income .......................................................................................................................................................... 401

Balance Sheet .............................................................................................................................................................................................. 402

Statement of Changes in Equity ................................................................................................................................................................... 403

Statement of Cash Flows ............................................................................................................................................................................. 404

Notes to the Financial Statements ............................................................................................................................................................... 405

1. Accounting policies applied ............................................................................................................................................................................... 407

1.3 Significant accounting judgments and key sources of estimation uncertainty ................................................................................................ 418

2. Net interest income ........................................................................................................................................................................... 420

3. Net fee and commission income ........................................................................................................................................................ 420

4. Dividend income ................................................................................................................................................................................ 420

5. Gains less losses on financial transactions ......................................................................................................................................... 420

6. Other Income ..................................................................................................................................................................................... 420

7. Staff costs and expenses .................................................................................................................................................................... 421

8. General administrative expenses ....................................................................................................................................................... 421

9. Provisions ........................................................................................................................................................................................... 421

10. Income Tax ......................................................................................................................................................................................... 421

11. Earnings/(losses) per share ................................................................................................................................................................ 422

12. Due from Banks .................................................................................................................................................................................. 423

13. Investment securities ......................................................................................................................................................................... 423

14. Investments in subsidiaries ................................................................................................................................................................ 423

15. Other assets ....................................................................................................................................................................................... 423

16. Due to Banks ...................................................................................................................................................................................... 425

17. Debt securities in issue and other borrowed funds ........................................................................................................................... 425

             
 
 
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 Deferred tax liabilities ........................................................................................................................................................................ 425 
 Other liabilities ................................................................................................................................................................................... 425 
EQUITY  427 
 Share Capital ...................................................................................................................................................................................... 427 
 Share premium ................................................................................................................................................................................... 427 
 Other equity instruments ................................................................................................................................................................... 427 
 Reserves ............................................................................................................................................................................................. 428 
 Retained earnings............................................................................................................................................................................... 428 
ADDITIONAL INFORMATION ................................................................................................................................................................................. 429 
 Contingent liabilities and commitments ............................................................................................................................................ 429 
 Risk Management ............................................................................................................................................................................... 430 
1.  Credit Risk .......................................................................................................................................................................................... 430 
2.  Market risk ......................................................................................................................................................................................... 431 
3.  Liquidity Risk ...................................................................................................................................................................................... 432 
4.  Fair value of financial assets and liabilities ......................................................................................................................................... 434 
 Related party transactions ................................................................................................................................................................. 435 
 Auditors’ fees ..................................................................................................................................................................................... 436 
 Assets held for sale ............................................................................................................................................................................. 436 
 Awarding of stock options to employees ........................................................................................................................................... 436 
 Stock awards to employees ................................................................................................................................................................ 437 
 Corporate events ................................................................................................................................................................................ 437 
 Strategic Plan ..................................................................................................................................................................................... 437 
 Events after the balance sheet date ................................................................................................................................................... 438 
Appendix of the Board of Directors’ Annual Management Report ............................................................................................................... 439 
EU TAXONOMY REPORTING FORMS ............................................................................................................................................................ 442 
Availability of Annual Financial Report ........................................................................................................................................................ 535 
 
 
 
 
 
 
   

STATEMENT BY THE MEMBERS OF BOARD OF DIRECTORS

5 | ANNUAL FINANCIAL REPORT

Statement by the Members of the Board of Directors

(in accordance with article 4 paragraph 2 of Law 3556/2007)

To the best of our knowledge, we declare that the annual financial statements that have been prepared in accordance with the applicable

accounting standards, accurately and truthfully represent the assets, liabilities, equity and financial performance of Alpha Services and

Holdings S.A. and of the companies included in the consolidated financial statements taken as a whole, as provided in article 4 paragraph 2 of

Law 3556/2007, and that the Board of Directors’ Annual Management Report presents correctly the evolution, performance and financial

position of Alpha Services and Holdings S.A., and of the companies included in the consolidated financial statements taken as a whole,

including the description of the main risks and uncertainties that they face. The Board of Directors’ Annual Management Report was prepared

in accordance with the sustainability reporting standards referred to in Article 154A of Law 4548/2018 and the specifications approved

pursuant to Article 8 paragraph 4 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020, on the

establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088.

Athens, March 6, 2025

THE CHAIRMAN

OF THE BOARD OF DIRECTORS

THE CHIEF

EXECUTIVE OFFICER

EXECUTIVE MEMBER

OF THE BOARD OF DIRECTORS

DIMITRIS C. TSITSIRAGOS

ID No A 00808440

VASSILIOS E. PSALTIS

ID No ΑΙ 666591

LAZAROS A. PAPAGARYFALLOU

ID. No AK 093634

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

Board of Directors’ Management Report as at

31.12.2024

MACROECONOMIC ENVIRONMENT

Greek Economy

According to the latest available data published by ELSTAT, the Greek economy continued on an upward trajectory in the third quarter of 2024,

with real GDP growing by 2.4% y-o-y and 0.3% q-o-q (Graph 1). In the first nine months of 2024 real GDP rose by 2.3% on an annual basis, on

the back of rising private consumption (+1.8% y-o-y), investment (+2.2% y-o-y) and accumulated inventories. In contrast, public consumption

declined by 4.2% y-o-y, due to the phasing out of the fiscal measures in response to the energy crisis. Net exports also subtracted 2.5

percentage points (pps) from real GDP growth in the first nine months of 2024, owing to strong imports’ growth (5.5% y-o-y), while exports fell

marginally by 0.2% y-o-y. The growth momentum is expected to continue in the fourth quarter of 2024 as signalled by several indicators

relevant to economic activity. The Economic Sentiment Indicator averaged to 106.4 in Q4 2024, remaining well above its long-term average

and the respective euro area indicator (95). In addition, the Purchasing Managers’ Index averaged to 51.8 in the last quarter of 2024,

remaining in expansionary territory, above the threshold of 50 for almost two years.

Inflationary pressures are gradually receding (Graph 2). 2024, inflation based on the Harmonized Index of Consumer Prices (HICP) averaged to

3.1% compared to 4.2% in 2023, as a result of the more moderate increase in food and industrial goods prices. In parallel, in January-

December 2024 energy prices decreased by an average of 1.4% on an annual basis, against a fall of 13,4% in the same period of 2023, marking

a marginal negative contribution to HICP growth. On the other hand, services continued to grow at a similar pace in 2024 (4.3%) compared to

2023 (4.5%), adding 2,1 p.p. on average to HICP increase.

The General Government primary balance is estimated at 2.5% of GDP in 2024, from 2.1% in 2023, whereas it is anticipated to remain at that

level in 2025 as well (2.4%) (Bank of Greece, Interim Monetary Report, December 2024). The better-than-initially-expected performance of

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Graph 1. Real GDP growth and Economic Sentiment Indicator: Greece vs. Euro area

Real GDP - Greece (% quarterly change)

Real GDP - Greece (% annual change)

Real GDP - Euro area (% annual change)

Economic Sentiment Indicator - Greece (3m average, rhs)

Economic Sentiment Indicator - Euro area (3m average, rhs)

Source: ELSTAT, Eurostat, Bank of Greece, European Central Bank

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Graph 2. Headline (HICP) inflation and main components' contribution

Processed food Unprocessed food

Non-energy industrial goods Energy

Services Greek HICP inflation (y-o-y)

Source: Eurostat

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

public finances in 2024 was mainly attributed to the increase of tax revenues, which in turn was the result of employment growth, increasing

incomes for both individuals and businesses, as well as the containment of tax evasion. Furthermore, the debt-to-GDP ratio has recorded the

second steepest decrease among the European Union (EU-27) countries since 2019, after Cyprus, as it is estimated to have reached 154.2% in

2024, while it is expected to further decrease to 145.9% in 2025 (Graph 3).

In 2024, Greece has successfully tapped the international debt capital markets raising a total of Euro 9.55 billion. This was achieved mainly

through two syndicated issuances: a ten-year in February, and a thirty-year in May, amounting to Euro 4 billion and Euro 3 billion respectively.

The coverage ratios were in both cases very high, as demand was almost tenfold compared to the value of the issuances. Additionally, eleven

re-openings of existing bonds were carried out, through which a total of Euro 2.55 billion was raised. The spread of the 10-year Greek

Government Bond (GB) against the respective German GB narrowed from 104 basis points (bps) on 2.1.2024, to 85 bps on 31.12.2024,

remaining below Italy’s corresponding spread since May 2023 and approaching by the end of the year the spread between the French and the

German 10-year GBs.

In 2023, Greece achieved a significant milestone by regaining investment grade status after 13 years according to several rating agencies (S&P,

Fitch, DBRS). Furthermore, as a result of continuous improvement in macroeconomic and fiscal figures, three rating agencies upgraded

Greece’s outlook from stable, to positive in 2024 - S&P in April 2024, DBRS and Moody’s in September- whereas Scope raised Greece's credit

rating in December to BBB, from BBB-, with stable outlook. This was the first upgrade within the investment grade range in more than 20

years, on the back of the improvement of public finances, the resilience of the banking sector, the strengthening of economic prospects and

the implementation of structural reforms.

The unemployment rate stood at 10.0% on average in 2024, compared to 11.1% in 2023. The increase in employment accelerated in 2024

(1.8% vis-à-vis 1.3% in 2023), whereas the number of unemployed persons declined at a milder pace (-8. 8% compared to -11.1%). Since June

2024, the unemployment rate stands below the 10% threshold (Graph 4).

The recovery of the Greek real estate market continues, with both residential and prime commercial prices maintaining an upward trend in

2024. According to the latest reads, nominal residential property prices grew by 7.8% on an annual basis in the third quarter of the year and by

9.2% y-o-y on average in 9m 2024, whereas office and retail prices rose by 4.2% y-o-y and 7.8% y-o-y, respectively in H1 2024. The growth

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Graph 3. Primary balance (% of GDP) and debt-to-GDP ratio

GG primary balance (% of GDP) Public debt to GDP ratio, rhs

Monetary Policy

Interim Report

2024

Sources: ELSTAT, Bank of Greece

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

rates of house and office prices are moderating, where in contrast, the retail price index continues to grow at an accelerating pace. Since 2017

when real estate prices re-embarked on an upward trajectory, residential real estate prices have increased cumulatively by 71%, office prices

by 32% and retail shops prices by 43%.

In 2024, the private sector’s deposits in the domestic banking system increased by Euro 8.7 billion, against a total increase of Euro 5.8 billion

in 2023. In addition, the sum of net credit flows to the private sector amounted to Euro 10.5 billion in the same period. The annual rate of

change of total credit to the private sector stood at 8.9% in December 2024, with credit to non-financial corporations increasing by 13.8% and

credit to households remaining in negative territory (-0.5%).

The prospects of the Greek Economy

According to the latest macroeconomic projections by the Bank of Greece and the European Central Bank (December 2024), real GDP growth

is expected to hover at about 2.3% in 2024 and pick up to 2.5% in 2025, outpacing the euro area average (2024:0.7%; 2025: 1.1%) (Graph 1).

Strong private consumption (2.1%) and investment (8.2%) growth are expected to underpin the 2025 growth outlook. In addition, the

unemployment rate is expected to continue trending downwards in 2025.

Despite the high level of uncertainty surrounding the economic outlook, the Greek economy is heading into 2025 amidst favorable conditions,

including: (i) political stability prevailing in the country, (ii) investment grade status, (iii) commitment to fiscal discipline and (iv) increasing

contribution of investment in the growth mix, as a result of the absorption of the Resilience and Recovery Facility funds, which suggest that the

country is expected to maintain its strong growth dynamics, consistently outperforming the euro area average since 2021. On the other hand,

external factors such as geopolitical tensions, political instability in major European countries and trading partners of Greece, such as France

and Germany, a possible increase in trade protectionism following the US elections, as well as more persistent than expected inflation,

constitute among the important sources of risk surrounding the prospects of the Greek economy in the coming years.

Global Economy

In 2024, the global economy has remained resilient despite the high uncertainty created by geopolitical tensions and the election results,

primarily in United States of America (USA) and Europe. The de-escalation of inflation has underpinned consumer spending and led to interest

rate cuts of central banks in most major economies. The recovery varies among countries, as USA and several emerging markets and

developing economies recorded steady growth, in contrast to euro area.

On the monetary policy front, the US Federal Reserve (Fed) after many months moved to the first rate cut by 50 basis points (bps) in

September 2024 from its 23-year high (5.25% - 5.50%) and by 25 bps in the meetings of November and December 2024. The Fed began its

gradual easing of policy after assessing the following signs: First, the de-escalation of inflation from 9.0% in June 2022, which was the highest

level in 40 years, to 2.6% in August 2024. Second, the mild slowing of employment growth that could lead to a faster rise in unemployment

rate from historically low levels in 2023. In parallel, the Bank of England (BoE), has held interest rates at 4.75% in December 2024, following

two cuts in August and November 2024 by 25 bps each. According to the BoE, a gradual approach to monetary easing remains the most

appropriate policy until the inflation has returned to the 2% target in the medium term. The European Central Bank (ECB) since June 2024

proceeded to four interest rate cuts by 100 bps cumulatively until the end of the year. As a result, the interest rates on the deposit facility, the

main refinancing operations and the marginal lending facility have been decreased to 3.00%, 3.15% and 3.40% respectively. The deflationary

process has started since 2023 and is expected to continue in 2025, until the inflation in the Eurozone reaches the target of 2%. Also, in 2024

other central banks in countries such as Switzerland, Canada, and Sweden cut key interest rates by 125bps to 175 bps (Graph 5).

According to the International Monetary Fund (IMF, World Economic Outlook Update, January 2025), the growth of global economy is

estimated at 3.2% in 2024 from 3.3% in 2023 and is projected at 3.3% in 2025 (Graph 6). Inflation pressures have continued to ease in most

countries during 2024 led by further falls in energy, food and other goods prices. Global inflation is expected to decline further to 5.7% in 2024

from 6.7% in 2023 and 4.2% in 2025, with advanced economies returning to their inflation targets sooner than emerging markets and

developing economies but remaining above the pre-pandemic levels (Graph 7).

Residential real estate prices: Q3 2017; Offices and Retail prices: H1 2017.

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

In 2024, the USA economy recorded a better-than-expected performance despite the significant tightening of monetary policy. In specific, GDP

growth is estimated to reach 2.8% in 2024 from 2.9% in 2023 (IMF, World Economic Outlook Update, January 2025), on account of stronger

private consumption underpinned by real wage gains and nonresidential investment. Growth is projected to be at 2.7% in 2025. In China,

despite persisting weakness in the real estate sector growth, the growth rate is projected to have slowed mildly to 4.8% in 2024 from 5.2% in

2023, mainly due to better-than-expected net exports. In 2025, China’s growth rate is projected to decelerate marginally to 4.6% (IMF, World

Economic Outlook Update, January 2025).

In relation with the above developments, significant challenges remain that could impact the global economy in 2025.

Firstly, the geopolitical tensions which pose short-term risks as they remain elevated. An intensification of the evolving war conflicts in the

Middle East or in Ukraine, could lead to market repricing of sovereign risk in the affected regions and disrupt global energy markets. While the

global oil and gas markets appear adequately supplied at present, potential damage to energy infrastructure could lead to market disturbances

and reassessment of the global economic outlook. In addition, further worsening of the ongoing geopolitical conflicts could create higher

uncertainty that could hit the consumer confidence, investment activity and growth.

Secondly, the risk of global geo-economic fragmentation and greater trade protectionism, especially by the largest economies, in case they

impose higher tariffs and sanctions in trade agreements. The new government of USA possibly will affect further international relations and

the rivalry between the USA and China. Trade policy uncertainty has risen sharply in recent months and increasing trade tensions might risk

hampering international trade growth.

Thirdly, the public debt-to-GDP ratios that are high in some advanced economies, as well as, in certain emerging markets and developing

economies. Therefore, countries like USA and the euro area Member States, in order to ensure macroeconomic stability should implement the

appropriate monetary policy to tackle inflationary pressures in combination with fiscal policies that create sufficient fiscal space for future

spending.

Fourthly, the repercussions of election outcome, particularly in USA, which could reshape the global political landscape. Also, the political

instability in major European countries such as Germany and France, is expected to influence the European Union’s agenda in important fields,

such as fiscal policy, trade policy and migration.

Eurozone

According to the ECB’s macroeconomic projections (December 2024), the main factors that played an important role in the euro area's mild

recovery in 2024 after the stagnation of 2023 were the pick-up of private consumption, the strengthening of foreign demand and the gradual

easing from past monetary policy tightening. The increase in households’ spending, owing to mild wage growth and de-escalating inflation,

should support the recovery in the medium term. Except for that, the resilience of labour market with historically low levels of unemployment

rates enhances the dynamics of growth.

Investment activity is projected to gradually strengthen, mostly reflecting the fading effects of monetary policy tightening, the increasing

business profits, the deployment of funds under the Next Generation EU programme and the improving export growth despite the euro area’s

weak competitiveness.

Real GDP growth is expected at 0.7% in 2024 from 0.5% in 2023 and is projected to strengthen at 1.1% in 2025 and 1.4% in 2026 (ECB

Macroeconomic Projections, December 2024). Following the policy rate cuts since June 2024, the negative effects of the tight financing

conditions on growth is estimated to fade in the next years.

Based on the Harmonised Index of Consumer Prices (HICP), the euro area inflation rate is estimated at 2.4% in 2024 down from 5.4% in 2023

and is forecast to decline further to 2.1% in 2025, close to the ECB's target (ECB Macroeconomic Projections, December 2024). Furthermore,

HICP inflation is expected to reach 1.9% in 2026 driven by the services component. The core inflation, which excludes the volatile prices of

energy and food is expected to decline to 2.9% in 2024 from 4.9% in 2023, before declining further to 2.3% in 2025 and 1.9% in 2026.

Finally, amid geopolitical and trade policy uncertainty, euro area business investment is projected to grow at a modest pace in 2025, while

should be supported by a gradual improvement in domestic and foreign demand, solid unit profit growth and less tight financing conditions. In

2026 and 2027 more favourable financing conditions, the further deployment of Next Generation EU (NGEU) and the private funds to spur the

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

digital and green transitions will also contribute to the recovery in investment. In addition, housing investment is estimated to decline in 2024

reflecting weakness in housing demand in euro area. But on the back of a gradual decline in mortgage lending rates and rising household

incomes, housing Investment is projected to recover with slow pace in the course of 2025 and increase further in 2026.

Countries where the Group operates

Cyprus

Economic activity in Cyprus increased by 3.7% (annual change, seasonally adjusted figures) in the first nine months of 2024, recording the third

highest growth rate among the EU Member States. The expansion of economic activity was supported by both private and public consumption,

whilst the positive contribution of net exports offset the negative contribution of gross capital formation.

The European Commission (Autumn 2024 Economic Forecast) estimates real GDP growth rate to stand at 3.6% in 2024 and 2.8% in 2025.

Economic growth will be supported by domestic demand, with private consumption boosted by employment gains and strong tourism

performance. The gradual easing of monetary policy and the ongoing disinflation process, combined with rising wages, will support real

disposable income. Investment is expected to be boosted by existing and upcoming construction projects (in various sectors including tourism,

education and health) as well as the implementation of Recovery and Resilience Plan (RRP).

Annual harmonised inflation decelerated from 8.1% in 2022, to 3.9% in 2023, while according to the European Commission (Autumn 2024

Economic Forecast), it is forecast to continue to decelerate to 2.2% in 2024 and 2.1% in 2025, mainly due to the gradual easing of base effects

in particular for food and the fall in energy prices.

Public debt decreased significantly from 81% of GDP in 2022, to 73.6% in 2023 and it is expected to fall to 66.4% in 2024 and 61.4% in 2025

mainly due to primary surpluses and continued nominal GDP growth (European Commission, Autumn 2024 Economic Forecast).

United Kingdom

GDP increased slightly, on an annual basis, in the first nine months of 2024 (Q1: 0.3%; Q2: 0.7%; Q3: 0.9%). The European Commission

(Autumn 2024 Economic Forecast) estimates that GDP will increase by 1% in 2024 and 1.4% in 2025. The Bank of England raised its policy rate

five times in 2023, reaching 5.25% due to high inflation. However, in 2024 the Bank of England cut its policy rate twice to 4.75%. Inflation

based on the Consumer Price Index (including owner occupiers’ housing costs-CPIH), averaged 6.8% in 2023, whereas, according to the

European Commission (Autumn 2024 European Economic Forecast), it is expected to decelerate to 3.1% in 2024 and 2.4% in 2025.

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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STRATEGIC PLAN

The Group’s strategy aims on significant growth and value creation 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.

Strategic Plan’s priority areas are profitability enhancement, balance sheet resilience preservation and capital generation and distribution. It

builds upon the successful implementation of the Group’s transformation programme and plays to the unique strengths of the Group.

Our strategy is based on six clearly defined strategic pillars covering all 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 wealth management/private banking and other selected clients while investing in

technology to modernize service model

c) Reinforce position in wholesale lending, structured finance and investment banking and ensure adequate returns for capital while

growing fees and continuing to refine operating model

d) Safeguard profitability in international activities by accelerating lending momentum, also 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. Additionally, theGroup intends to further reduce its

Group NPE ratio while improving the coverage ratio (within a condensed Cost of Risk ratio)

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.

The key financial priorities are summarized as per below:

Profitability

•

Significant business profitability improvement across Business units; continuous balance sheet de-risking allows for capital re-allocation

from NPA Unit to other businesses with significant profit generation potentials

•

Revenues increase on the back of a) strong NII performance, largely attributed to NII growth driven by volumes expansion and b)

growing fees and commissions on the back of product penetration initiatives and recents partnerships announced (Generali, UniCredit).

•

Cost management limiting inflation impact, and execution of initiatives targeting OpEx reduction in selected areas

Balance sheet

•

Diversified and resilient balance sheet

•

Structural NPE reduction through organic and inorganic levels, lowering NPE ratio and improving coverage while further de-escalating

cost of risk

•

Diversified, granular and resilient deposit base

•

Optimize RWA allocation and liquidity towards non-commercial book expansion exploring selective real estate and investment securities

opportunities

Capital generation and distribution

•

Healthy capital generation on the back of strong returns

•

Maintain solid fully loaded capital ratios (FL CET1) across the period

•

Reward shareholders with gradual payouts increase at par with average European Banking levels

ANALYSIS OF GROUP FINANCIAL INFORMATION

As at 31.12.2024, the Group’s Total Assets decreased Euro 346 million (less than 1% decrease ) compared to 31.12.2023, amounting to Euro

72.1 billion. The completion of the sale transactions for AB Romania and project Skyline in 2024 are the main drivers for the reduction in Assets

classified as held for sale of Euro 4.4 billion (and a reduction of Liabilities classified as held for sale of Euro 3.6 billion). As a result of the

derecognition of the net assets in AB Romania and the Skyline subsidiary, the Group recognized as part of the sale consideration, three new

associates at their fair value by holding participation in 9.9% of AB Romania, 9.9% of UniCredit Romania and 35% of Skyline, increasing the

value of Investments in associates by Euro 470 million compared to 2023.

Loans and advances to Customers increased by Euro 2.9 billion compared to 31.12.2023 at Euro 39.0 billion, resulting in a loan-to-deposit ratio

of 77% (31.12.2023: 75%)

. The increase is mainly driven by the credit expansion in the second half of 2024 through net disbursements of Euro

3.2 billion, counterbalanced by the classification as Assets classified as held for sale of the loan portfolios of project Gaia II (which includes

mainly non-performing collateralized retail loans) and a Cypriot portfolio of non-performing loans.

As at 31.12.2024, the balance of Investment securities stood at Euro 17.6 billion (31.12.2023: Euro 16.0 billion) representing an increase of

10%. The acquisition predominantly of higher yielding HQLA securities supports the Group’s profitability and liquidity metrics.

Due to Customers amounted to Euro 51.0 billion, increased by Euro 2.6 billion or 5% compared to 31.12.23, whilst debt Securities in issue and

other borrowed funds increased by 10% compared to 31.12.2023 and reached Euro 3.2 billion. During the year, the Group issued a new

preferred Senior Note of nominal value Euro 400 million, a new subordinated bond with a nominal amount of Euro 500 million and a credit

linked note of Euro 88 million, whilst it repaid early subordinated debt issued in 2020 of nominal value Euro 369 million and senior notes

issued on 1 November 2022 of nominal value Euro 400 million. In 2024, the Bank repaid Euro 5 billion of TLTRO funding and refinanced it with

Euro 1.5 billion LTRO and euro MRO 1.1 billion funding from the ECB, as well as increasing its repo funding with other banks by Euro 2.2 billion,

resulting in an overall decrease of its borrowings from other banks by Euro 388 million or 6%.

Τhe loan to deposit ratio is presented in the Appendix of the Βoard οf Directors’ Management Report.

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ANNUAL FINANCIAL REPORT

Following the changes in its funding mix and the investment in securities, Cash and balances at central banks reduced by Euro 1.2 billion to

reach Euro 3.0 billion (31.12.2023: Euro 4.2 billion), whilst amounts due from other financial institutions increased by Euro 724 million to reach

Euro 2.3 billion (31.12.2023: 1.6 billion).

The Group’s Total Equity amounted to Euro 8.2 billion as at 31.12.2024, increased by Euro 866 million compared to 31.12.2023. The main

drivers of the increase in capital are the issue of new AT1 capital instruments for a nominal value of Euro 300 million and the results of the

period, counterbalanced by the dividend coupon payment for the Additional Tier 1 instruments and the distribution of returns to ordinary

shareholders in the form of Euro 61 million cash dividends and Euro 51 million in share buybacks (another Euro 10 million share buybacks were

completed in early 2025 for a total distribution to shareholders of Euro 122 million). The Total Capital Adequacy Ratio of the Group stands at

21.9%, increased compared to 31.12.2023 (18.8%), allowing the Bank to operate well above its capital requirements. It is noted that Group’s

capital ratios already incorporate the effect of dividends for 2024 results according to its distribution policy. Excluding the provision for

dividends, capital ratios would increase by c. 97 bps and the Total Capital ratio would have stood at 22.9%.

Regarding the results for the year ending 31.12.2024, the Group’s net profits after income tax amounted to Euro 654 million (31.12.2024: Euro

618 million). Below are the main drivers for the results of 2024:

•

Net interest income stood at Euro 1,645 million (31.12.2023: Euro 1,659 million), presenting a decrease of 1% versus the comparative

period. The decrease in NII is mainly attributed to the higher volume of the deposit base and higher cost of term deposit as a result of

higher interest rates on offer. This was partially offset by the expansion of the bond and securities portfolio following new investments.

•

Net fee and commission income for the period was Euro 420 million (31.12.2023: Euro 374 million) showing an increase of 12%,

attributed mainly due to increased commissions for issuing corporate bond loans, increased fees from assets under management and

mutual funds and higher advisory fees and security transaction fees.

•

Gain less losses on derecognition of financial transactions measured at amortised cost for the period were gains of Euro 31 million

(31.12.2023: Euro 17 million loss) and relate mainly to the sale of government bonds.

•

Gains less losses on financial transactions for 2024 amounted to a profit of Euro 80 million (31.12.2023: gains of Euro 70 million),

representing an increase of 14%. Gains are mainly due to the valuation of interest rate swap derivatives. The amount for 2024, includes

also Euro 11 million losses due to the cash Tender Offer that took place in June 2024 on its EUR 500mn Tier 2 notes callable in February

2025, at a purchase price of 99.75%, which attracted 73.7% participation.

•

Other income for the period ended 31.12.2024 was Euro 40 million (31.12.2023: Euro 39 million).

•

Operating expenses for the period amounted to Euro 866 million (31.12.2023: Euro 815 million) and are analyzed as follows:

➢ staff costs of Euro 370 million (31.12.2023: Euro 333 million) increased by Euro 37 million mainly due to wage inflation and higher

variable remuneration programs.

➢ general and administrative expenses of Euro 317 million (31.12.2023: Euro 325 million) decreased mainly as a result of no

contributions required to resolution funds in 2024.

➢ depreciation and amortization of Euro 179 million (31.12.2023: Euro 157 million) increased due to IT additions in 2023 supporting

digital transformation and changes in the estimated useful life of certain assets.

•

Impairment losses and provisions to cover credit risk amounted to Euro 360 million (31.12.2023: Euro 381 million), representing a 6%

decrease compared to 2023, and include impairment losses of Euro 215 million for the new NPEs loan portfolios classified as held for sale

(including the new transactions for Gaia II and Cyprus loans that were classified as held for sale in 2024, as well as loans that were

classified as held for sale for the projects Hermes, Solar, Leasing and Gaia I in the previous year). By comparison, impairment losses to

cover credit risk due to NPE transactions were Euro 162 million in 2023. The underlying cost of risk stood at Euro 144 million

(31.12.2023: 218 million).

•

Gains/ (Losses) on disposal of fixed assets and equity investments for 2024 amounted to gains of Euro 27 million (31.12.2023: Euro 3

million gain) and relate mainly to the gain of Euro 23 million from the disposal of real estate assets for project Skyline which was

concluded in 2024. The comparative figure included a gain of Euro 8 million for real estate assets of project Sky which was concluded in

2023.

•

Provisions and transformation costs amounted to Euro 99 million in 2024 (31.12.2023: Euro 50 million). The amounts for 2024 include

Euro 55 million for the cost of a Voluntary Separation Scheme (VSS) (respective figure for 2023 Euro 39 million) and the cost of Euro 25

million for the funding of school renovations announced by the government. Transformation costs amounted to Euro 14 million in 2024

(31.12.2023: Euro 4 million).

•

Income tax for the year ending 31.12.2024 amounted to Euro 219 million (31.12.2023: 226 million).

•

Net profit/(loss) after income tax from discontinued operations for Euro 57 million (31.12.2023: Euro 64 million) include the results of

subsidiaries Alpha Life and Alpha Bank Romania, that are part of the sale transaction with UniCredit S.p.A., as well as the subsidiaries

Alpha Leasing Romania and Alpha Insurance Brokers (Note 54 to the financial statements). A gain of Euro 7 millions relates to the

conclusion of the sale of Alpha Bank Romania.

Since the Group has committed to specific targets through the announcements of the updated strategic plan, the 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.

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. Indicatively, the main income and expense items that are excluded for purposes of the normalized profit calculation are listed below:

• 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 for 2024 reached Euro 861 million against Euro 787 million in the comparative period of 2023. An analysis of the

normalized profits is presented in the Appendix of the Βoard οf Directors’ Management Report.

Τhe cost of risk is presented in the Appendix of the Βoard οf Directors’ Management Report.

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ANNUAL FINANCIAL REPORT

Other financial information

In December 2024, following announcements by the Prime Minister and the Ministry of National Economy and Finance, systemic banks have

committed to invest €100 million for the establishment of the Fund for the Acquisition and Leasing of Real Estate which is specifically designed

to address the needs of vulnerable debtors who are facing bankruptcy or enforcement actions. The Fund will acquire the debtor's primary

residence following a formal transfer request in order to subsequently lease the property back to the debtor for a period of maximum 12

years. During the lease term or at its expiry, the debtor will be able to exercise his right to repurchase the property. By the date of publication

of the Annual Report, the details of the establishment of the fund and the obligations of the systemic banks had not been determined.

SIGNIFICANT EVENTS OF YEAR 2024

• The Bank has initiated the sale of the following two perimeters of loan exposures and has been working on completing the relevant steps

to execute the transactions.

➢ a perimeter of loanswith a carrying value before impairments as of 31.12.2024 of Εuro 464, mainly comprising of non–

performing mortgage exposures (“GAIA I”) and to be completed within Q1 2025

➢ a perimeter of loans with a carrying value before impairments as of 31.12.2024 of Εuro 565 million mainly comprised of Small

Businesses and SME/Large corporate NPE exposures (“GAIA II”) to be completed within the first semester of 2025.

The transactions are envisaged to be executed through a securitization structure in accordance with the Greek securitization framework

(L.3156/2003) and the Hellenic Assets Protection Scheme (L.4649/2019), as amended and in force. Based on the above, the portfolios

have been classified as held for sale. Additionally, the Bank has initiated the sale of a perimeter of loans with a carrying value before

impairments as of 31.12.2024 of Euro 136 million comprised of Cypriot mainly secured NPE portfolio exposures (“Project ACAC”) and has

been working on completing the relevant steps to execute the transaction. The transaction is envisaged to be completed within 2025.

Based on the above, the particular portfolio has been classified as held for sale.

• On 05.06.2024 Alpha Services and Holdings S.A. received supervisory approval for the distribution of Euro 122 million., equal to a 20%

payout of the 2023 profits, with the half of the amount, or Euro 61 million, distributed in the form of a cash dividend (an equivalent of

Euro 0.026 per share). The remainder to be used to conduct a share buyback under customary conditions and in accordance with all

applicable laws. Supervisory approval for the cancellation of the shares that will be acquired by the Company as part of the buyback

program has been received. Additionally, on 24.07.2024 the Annual General Meeting provided the relevant approval in respect to the cash

dividend payment.

• On 20.6.2024, Alpha Services and Holdings S.A. announced the reorganization of Alpha Leasing Single Member Société Anonyme (“Alpha

Leasing”) to be effectuated by a common demerger of Alpha Leasing (the “Demerger”). The completion of the Demerger will entail (i) the

contribution of the performing leasing contracts along with the relevant real estate interests to Alpha Ereunas Agoras Single Member SA, a

newly-established Group’s entity that will remain part of the Group and will be licensed as leasing company, (ii) the contribution of a

perimeter of non-performing financial leases along with the related real estate interests with a Gross Book Value of app. Euro 0.24 billion

("Andros portfolio"), to Hellas Capital Leasing Single Member Societe Anonyme, a Greek leasing company, wholly owned by funds

managed or advised by Bain Capital ( “HCL”), (iii) the contribution of the repossessed real estate properties of Alpha Leasing which form

part of Skyline perimeter to newly established SPV(s) and (iv) the contribution of remaining repossessed real estate properties of Alpha

Leasing to newly established SPV which will remain part of the Group.

To this end, on 19.6.2024, Alpha Leasing and its sole shareholder Alpha Holding S.A. (“Alpha Holding”) entered into a binding agreement

with HCL and its shareholder, for the i) contribution of Andros portfolio to HCL and ii) the subsequent disposal of the shareholding interest

to HCL that will result from this contribution to HCL’s shareholders, upon completion of the Demerger, which is expected to take place

within 2025 after obtaining all the required regulatory approvals for the Demerger.

• On 12.7.2024 Alpha International Holdings Single Member S.A (“Alpha”) and UniCredit S.p.A. (“UniCredit”) signed the Share Sale and

Purchase Agreement relating to the sale of 90.1% of the issued share capital of Alpha Bank Romania S.A. Οn 4.11.2024 Alpha and

UniCredit announced that, having received approvals from all relevant authorities and following completion of the due diligence process,

UniCredit has acquired from Alpha , a 90.1% stake in Alpha Bank Romania S.A. (“Alpha Bank Romania”) in consideration of (i) 9.9% of the

share capital of UniCredit Bank S.A. (“UniCredit Romania”) and (ii) Euro 254 million in cash. The transaction is part of the strategic

partnership between Alpha Services and Holdings and UniCredit, announced on 23 October 2023. The acquisition starts the process for a

gradual integration of Alpha Bank Romania into UniCredit Group. Subject to legal and authorization stages, integration will be completed

with the merger through absorption of Alpha Bank Romania S.A. within UniCredit Bank S.A. estimated to take place in the second semester

of 2025. The merger will bring together two complementary banks, both with long-standing relationships and expertise in the Romanian

market. Alpha will retain its longstanding presence in the Country by having, post-merger completion, a 9.9% of UniCredit Bank S.A.

•

The Annual General Meeting of Shareholders held on 24.7.2024 approved, among other things, the following:

- The dividend distribution of an amount of Euro 61 million in cash from intragroup dividends reserves to the Shareholders of the Company

for the financial year 2023 in accordance with the legal and regulatory framework .

- The distribution of an amount of Euro 56 thousand of the Company’s Intragroup dividends reserves to Company’s Staff as well as the

distribution of an amount up to Euro 12.6 million by Group Companies’ to their eligible Staff. It is noted that since the distribution is in

essence a benefit to employees, the relevant amount has already been recognized in Group Companies’ profit or loss.

- The amendment to the Company’s Share Buyback Program for the acquisition of own existing common, registered dematerialized shares,

with voting rights, in accordance with article 49 of law 4548/2018, which was approved by the Ordinary General Meeting held on 27.7.2023.

All items of the Ordinary General Meeting of Shareholders are presented in the Corporate Governance Statement for the year 2024 (section

“Shareholders-General Meetings of Shareholders”).

•

In July 2024, the Bank and Unicredit Group completed the operationalization of the commercial partnership in asset management by signing

the relevant distribution framework agreements. Following that, the Bank has initiated the distribution of Onemarkets Mutual funds

through its network.

•

Οn 13.12.2024 Alpha Services and Holdings S.A announced the initiation of the merger process, by way of which Alpha Bank S.A. shall

proceed with a merger by absorption of Alpha Services and Holdings S.A. Upon the completion of the merger, Alpha Bank will retain its

license as a credit institution and will succeed by force of law and by way of a universal succession the Company in any and all of its assets

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

and liabilities. Prior to the Merger completion, the shares of Alpha Bank S.A will be listed on the Athens Exchange and its shares will be

delivered upon Merger completion to the Shareholders of Alpha Services and Holdings S.A in exchange for their shares in the Company.

The December 31, 2023 has been set as the Transformation Balance Sheet date of the Merger .On 27.2.2025 the Board of Directors of Alpha

Bank S.A and the Board of Directors of Alpha Services and Holdings approved and agreed with the publication of the Merger Documents

(the Draft Merger Agreement, the BoD Reports, the Transformation Balance Sheet and (without approval) the Independent Auditor’s

Reports) and amended the Transformation Balance Sheet date to 31.12.2024 compared to 31.12.2023 previously

• On 23.12.2024 Alpha Services and Holdings S.A. through its 100% subsidiary Alpha Group Investments Limited, has completed the sale of

a 65% equity stake in Skyline Real Estate Single Member S.A. to P&E Investments Axiopoiisis kai Anaptyxis Akiniton Société , an

investment vehicle controlled by Dimand S.A., Premia Properties REIC and the European Bank for Reconstruction and Development

(EBRD). More information is presented in the section Real Estate Owned Assets (REOs) Management.

• Τhe significant changes in debt securities in issue and additional Tier 1 instruments performed during the year are presented in the

Liquidity Risk section.

RISK MANAGEMENT

The Group has established a framework for the 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 1st 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 adoption of the Capital Requirements Regulation (CRR ΙΙΙ) in accordance with European Regulation 2024/1623, introduces a series of

significant changes to the regulatory framework established under CRR ΙΙ, particularly in the context of standardized approaches to credit risk,

market risk, operational risk and CVA risk. These modifications aim to enhance the resilience of financial institutions while ensuring greater

consistency and comparability across jurisdictions.

The transition from CRR ΙΙ to CRR ΙΙΙ reflects the European Union’s commitment to implementing the final Basel III reforms (Basel IV). CRR 3 aims

to:

• Enhance the risk sensitivity of prudential frameworks.

• Improve the comparability and transparency of financial institutions’ risk profiles.

• Promote a more resilient banking system capable of withstanding economic shocks.

The CRR III is applicable from January 1, 2025, except for certain articles mostly related to European Banking Authority (EBA) mandates, which

took effect earlier (July 2024), and the market risk component, whose implementation has been postponed by one year. Regarding CRD VI,

European Union (EU) member states have 18 months to incorporate the Directive into their national legislation, after which CRD VI will take

effect the next year, on January 1, 2026.

On specific areas of the regulatory package, it is worth noting that in the market risk section, the European Commission (EC) has activated the

delegated act under Article 461a of CRR 3 to delay the implementation of the new FRTB (Fundamental Review of the Trading Book) framework

until January 2026 as a capital requirement.

At the date of preparation of the Consolidated Financial Statements, minor impact is anticipated from its application in 2025. The fully loaded

CET 1 impact is estimated at 30 bps.

For the implementation of the aforementioned regulatory package, the EBA has around 140 mandates from CRR III and CRD VI to develop Level

2 and Level 3 legislation (RTS, ITS, and guidelines) to facilitate the application of the regulations. Of particular importance is the EBA's final report

on the Implementing Technical Standards (ITS) for entity disclosures, which were approved by the Commission and published in the OJEU as a

Regulation at the end of December, and which include changes to the Pillar 3 framework. These changes encompass new and revised disclosure

requirements for the output floor, crypto-assets (transitional treatment to be replaced by a definitive one before mid-2025, including review by

the BCBS), credit valuation adjustment (CVA) risk, credit risk, market risk, and operational risk, as well as minor modifications to the leverage

ratio. These ITS are applicable from January 1, 2025. Moreover, the EBA has already published several consultations in 2024 regarding credit risk

(off-balance-sheet items, default definition, etc.), market risk, operational risk, sustainability, and reporting and disclosures, for which the final

text is still pending publication.

The Group’s determines and reviews its risk-taking strategy by (a) the determination of the extent to which the Group is willing to undertake

risks (risk appetite), (b) the assessment of potential impacts 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:

• 1

line of defense Units (process owners) have the primary responsibility to own and manage risks associated with day-to-day operational

activities.

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ANNUAL FINANCIAL REPORT

• 2

line of defense Units, comprising the areas of Chief Risk Control Officer, the Chief Credit Officer, as well as the Risk Models & Data

Validation Business Area. These are independent from each other and from the other lines of defense. These areas report to the Chief Risk

Officer, who reports to the Risk Management Committee of the Group. Their function is complementary to controlling 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 Risk Model and Data Validation Business Area, operates as second line of defense to comply with Risk Data Aggregation and Risk

Reporting (RDARR) regulatory 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 2024, the following

actions were implemented:

• Incorporation of the Environmental, Social and Governance (ESG) risk assessment in the credit approval process of business lending, at

obligor, transaction and overall level per transaction.

• Incorporation of the Reputational Risk Assessment of Obligors/Potential Wholesale Banking Obligors in the credit approval process, as

defined in the Reputational Risk Management Policy.

• Update of the Credit Policy Manuals for Retail Banking (Housing and Consumer Lending, Small Business Banking) and Wholesale Banking,

taking into account the regulatory guidelines on credit risk management issues and the Group’s business strategy.

• Update of the Group Credit Risk Control Framework in order to ensure compliance with Credit Risk Policies at Bank and Group level.

• Enhancement of credit risk models, where needed, to keep them up-to-date and expand applicability, including but not limited to Climate

Risk.

• Update of the Group Credit Risk Models Validation Framework in line with the recent regulatory guidelines and best practices, including

qualitative and quantitative validation of significant increase in credit risk (SICR) criteria.

• Update of the Credit Rating System User’s Manual in order to capture the new ESG implementations in Credit Rating Systems (ABRS &

CreditLens).

• Ongoing validation of the Risk Models in order to ensure their accuracy, reliability, stability and predictive power

• Benchmarking key risk indicators with the use of EBA risk dashboard.

• Development of a Risk Data Aggregation and Risk Reporting Validation Framework that provides guidance for the assessment - as a second

line of defence - of the accuracy, completeness and consistency of the procedures and controls across the whole range of the directives of

Basel Committee on Banking Supervision's (BCBS239) and of ECB for all types of risk.

• Update of the Concentration Risk and Credit Threshold Policy regarding the maximum acceptable credit limits for large business groups and

the enhancement of the Sector Rating Methodology.

• Update of the Credit Risk Early Warning Policy regarding the classification of the business early warning triggers into Material or Non-

Material, the enrichment of business early warning triggers as well as the incorporation of the new term "Operating Risk".

• Update of the Loan Collateral Policy regarding the enrichment of methods of real estate property individual valuations with sustainability

and ESG factors.

• Update of the Credit Risk Model Management Policy regarding the review of the the overrides/non systemic ratings list of values.

• Update of the Retail Banking Arrears and Forbearance Policy regarding the addition of new products and changes to the existing Retail

Banking debt settlement products.

• 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 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 monitor, assess, and manage these risks going forward and further enhance its policies and procedures, where deemed

necessary. Leveraging on the work already performed in previous years the Bank has proceeded with targeted enhancements during 2024 in

accordance Group’s ESG plan commitments. More specifically, the following activities have been performed:

i. 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.

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ii. 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.

iii. The Bank has updated its Risk Inventory that it maintains and evaluates (ICAAP Report) to provide a comprehensive overview of -

enhancements and progress achieved in climate and environmental-related risks in the Bank's Risk Registry.

iv. The Group has enhanced its materiality assessment of climate and ESG risks incorporating time horizons (short/ 2025-medium/2030-long

time/2050) and identifying the sectors that are most vulnerable to climate and environmental related risks. In addition, with respect to

nature-related factors, the Bank has examined the “inside-out” and “outside-in” impact by utilizing the UNEP FI and ENCORE tool. 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. More specifically, the outcome of the materiality assessment for each

risk category is outlined as follows:

A. Climate related risks:

▪ Credit risk:

➢ Transition risk: considered to be materially affected, both in the Non-Financial Corporate (NFC) portfolio and the Retail

portfolio secured by Real Estate in the medium and long-term horizons.

- The assessment for the NFC portfolio examines the Bank’s performing exposures within the ESG Sensitive Perimeter

distributed to total average transition risk score for all time horizons (short-, medium- and long-term). The

determination of activities/sectors more sensitive to transition risk was based on the following factors (i) Climate

Policy Relevant Sectors (CPRS) perimeter, (ii) Sensitive sectors to transition risk according to Net Zero Banking

Alliance (NZBA) and Long-Term Strategy for Greece for 2050 (LTS), (iii) Examination of the emission intensities at

sector level and forward-looking Probability of Defaults (PDs) based on the short-term disorderly transition scenario

that ECB published as part of the 2022 ECB climate stress test exercise and (iv) Exclusion of: a) RES loans,b)

dedicated-purpose sustainable loans that are aligned with EU Taxonomy (and substantially contribute to Climate

Change Mitigation (CCM) objective) and c) other loans that are sustainable according to the Bank's Sustainable

Finance Framework, provided that they are linked to and affect Climate Change Mitigation (CCM) objective.

- The assessment for the retail portfolio secured by Real Estate is based on the EPC (Energy Performance Certificate)

distribution of the real estate assets and the minimum EPC requirements set in the “Report on the proposal for a

Directive by the European Parliament and the Council concerning the recast of energy performance standards for

non-residential buildings”.

➢ Physical risk: It is, also, considered to be materially affected in the medium and long-term horizons, leveraging on the

vulnerability assessment outcome per sector and region.

▪ Operational risk: seems to be materially affected by transition and physical risks in the medium and long-term horizons as examined

in terms of the Bank’s Own used Real Estate Properties.

➢ Regarding Legal/Litigation risk, and specifically Greenwashing Risk seems also be materially affected by C&E risks in

medium and long-term horizons, taking into consideration : i) the EBA guideline on Green Mortgages and EBA’s report

“Greenwashing monitoring and supervision” and the relevant EBA report on Green Loans & Mortgages, ii) the limited

current number of exposures and anticipated increased exposures in the future and the iii) the greenwashing risk related

scenario: “Fine imposed to the Bank due to Greenwashing”.

▪ Market / Liquidity risk: currently assessed as immaterial to both transition and physical risks across time horizons.

▪ Reputational risk: materially affected by C&E risks in the medium and long-term time horizons. The assessment has taken into

consideration potential consequences in the reputation of the institution due to either Greenwashing Risk, or the risk associated

with clients with a delayed response to transition risk, i.e. laggards to transition risk.

▪ Business & Strategic risk:

➢ Transition risk: considered to be materially affected by transition risk over the medium- and long-term horizons. The

assessment examines the Gross Interest and Fees & Commissions Income of the Bank’s performing portfolio within the ESG

Sensitive Perimeter, following the same approach as credit risk.

➢ Physical risk: considered to be materially affected by physical risks over the medium and long-term horizons.

B. Nature related risks:

▪ Credit risk: materially affected by nature-related risks (and more specifically by biodiversity) over long-term horizon.

▪ Operational risk: materially affected by nature-related factors in the medium- and long-term horizons.

▪ Market/ Liquidity risk: immaterially affected by nature-related risks across time horizons.

▪ Reputational risk: materially affected by nature-related factors in the medium and long-term horizon.

▪ Business & Strategic risk: materially affected by nature-related risks (and more specifically by biodiversity) over long-term horizon.

C. Social related risks:

▪ Credit risk: no material risks arise from the downstream portfolio due to the processes and controls applied by the institution,

despite the fact that certain part of the NFC portfolio impacts social factors.

▪ Operational risk: considered material in the short-medium and long-term. Specifically, the social topics considered as material are (a)

for own workforce: the training & skills development, and (b) for consumers and end users: privacy, access to (quality) information

and responsible marketing practices.

D. Governance risks:

▪ Corruption and Bribery governance topic is considered material in the short-, medium- and long-term.

v. The Bank designed and implemented a dedicated internal report including ESG metrics for loans and advances, which is presented on a

quarterly basis to the Group Sustainability Committee and the RMC (Risk Management Committee),, and through the RMC, to the Board

members.

vi. ESG-related considerations have been integrated into the Group's Remuneration Policy, aligning executive compensation with

environmental and sustainability goals.

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vii. A dedicated questionnaire was implemented to assess the Group's risk culture awareness, helping to evaluate internal perceptions and

practices.

viii. The Bank delivered several internal ESG trainings regarding the ESG Overall Assessment of obligors including ESG Obligor Assessment,

Transcaction Assessment and Reputational Risk Assessment.

ix. The Bank has centralised data related to the CPRS sector and Physical Risk assessment on obligor and real estate level, ensuring both

credit assessment and reporting needs are efficiently met.

x. The Bank has set up a process for greenwashing assessment in its wholesale loan portfolio in order to safeguard green loan tagging.

More information about Climate and ESG Materiality assessment methodology and other ESG related enhancements is presented in the 2024

Sustainability Statement.

To address the C&E risks, in 2024 the Bank has deployed a comprehensive strategic plan by carrying out the following key actions:

a) Identified, assessed, and prioritized the ESG issues related to its activities that may impact the Group’s operations and/or its Stakeholders.

Under this scope, a Double Materiality Analysis (DMA) was performed by leveraging the UNEP FI Principles for Responsible Banking (PRB)

Tool, the RSCA inherent risk assessment and outcome from the Compliance Risk Assessments to identify the material Impacts, Risks and

Opportunities (IROs) and connect these with the relevant European Sustainability Reporting Standards (ESRS) topics, subtopics or sub-

subtopics under Corporate Sustainability Reporting Directive (CSRD). ,.

b) Enhanced the regular monitoring of ESG Key Performance Indicators (KPIs) in order to cover all material C&E risks (transition & physical

for credit risk in NFCs and Collaterals, operational losses due to physical risk, social and governance risks, reputational risk due to ESG

considerations, business & strategic risk through the monitoring of income reliance from sectors sensitive to transition risk).

c) Developed science-based financed emissions targets for material carbon-intensive sectors covering both lending and investment

portfolios, in alignment with the Paris Agreement on climate change and net zero emissions by 2050.

Moreover, the Group has already incorporated in its Risk Appetite Framework (RAF) a set of quantitative indicators and qualitative

commitments regarding Climate and ESG risks. Specifically:

•

The Group integrated climate risks into its overall risk management framework.

•

In terms of quantitative indicators, the Group has enhanced Climate & Environment indicators designed to cover all material C&E risks

which are included in its Risk and Capital Strategy (RCS). The material indicators have been upgraded to Tier II status, with appropriate

limits set for more effective monitoring and management.

•

Enhanced credit assessment process is in place according to the "Climate related, Environmental, Social and Governance Risk

Management Policy on Group’s Business Lending" incorporating additional dimensions of climate related and governance risks.

•

The Bank expanded its Exclusion List (i.e. the activities that it does not finance) to encompass additional activities with environmental and

social impact, according to the United Nations “Universal Declaration of Human Rights”.

•

The Group has enhanced its due diligence process with respect to the assessment of its Customers’ ESG/climate risk profile, through the

improvement of collection of relevant information.

•

The Group 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.

The Bank has developed climate risk-specific methodologies to estimate the impact of transition on credit risk across different time

horizons (short, medium and long term) by making use of leading global macroeconomic and sectoral models. Additional characteristics

such as buildings’ energy efficiency, geographic and counterparty level characteristics are also incorporated in the estimation to further

account for heterogeneity of impacts inherent in climate risks. These are examined as stand-alone climate scenarios and used under both

the Economic and Normative perspective. Where applicable these scenarios are also applied on operational risk and business & strategic

risks considering the relevant risk materiality assessment that has been performed.

•

Furthermore, the Bank has developed climate risk-specific methodologies to estimate the impact of physical risk (chronic and acute risks

– specifically flood and wildfire) on credit risk across different time horizons (short, medium and long term) by making use of leading

global macroeconomic and sectoral models, as well natural catastrophe models for Greece. Additional characteristics such as geographic

and counterparty level characteristics are also incorporated in the estimation to further account for heterogeneity of impacts inherent in

climate risks. These are examined as stand-alone climate scenarios and used under both the Economic and Normative perspective. Where

applicable these scenarios are also applied on operational risk and business & strategic risks considering the relevant risk materiality

assessment that has been performed.

•

In addition, regarding the Climate risk impact, the Bank has expanded its climate risk-specific methodologies to estimate the impact of

climate scenarios on operational risk and business & strategic risks under Normative perspective apart from the impact quantification on

economic perspective estimated in previous year.

•

The regular monitoring of ESG Key Performance Indicators (KPIs) were upgraded to Tier II status with limits set for more effective

monitoring. If any of these limits are breached, the Bank will follow the same escalation process as with all non-C&E KPIs.

In order to assess the impact of climate risk on the calculation of Expected Credit Loss (ECL), detailed information on the ESG profile of the

obligor and the collateral (e.g. location of collateral as well as information on EPCs) is being collected. The information has been incorporated

into the respective data systems and methodological approaches are examined in the models for calculating the ECL. More specifically, the

following are in progress:

•

Data collections regarding ESG related information of the obligor through the use of the inter-banking ESG platform were ongoing on

2024.

•

Further enhancement and recalibration of the Bank’s ESG scorecards leveraging the data above.

• The models assessing environmental, governance and social risks are validated in line with the updated Group Credit Risk Models

Validation Framework.

•

Identifying enhancements or additions to the current set of models used for risk parameter estimation and prediction, in order to

integrate ESG risks.

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ANNUAL FINANCIAL REPORT

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 refers to the risk arising from an entity's inability to meet its short-term financial obligations due to a mismatch between its cash

inflows and outflows or due to challenges in converting assets into cash without incurring significant losses. There are two main types of

liquidity risk:

1. Funding Liquidity Risk

Funding liquidity risk refers to the risk that an organization will not have sufficient cash inflows to cover its cash outflows. This can happen due

to several factors, including but not limited to:

• Unexpected Cash Outflows: Sudden and large cash demands that were not anticipated, such as emergency expenses, debt

repayments, or withdrawal of funds by depositors or investors.

• Mismatch in Timing: The timing of cash inflows may not align with the timing of cash outflows leading to periods where the

organization faces cash shortages.

• Credit Issues: Difficulty in securing short-term borrowing or rolling over existing debt due to creditworthiness concerns or

unfavorable market conditions.

2. Market Liquidity Risk

Market liquidity risk pertains to the risk that an organization will not be able to quickly sell assets or investments at their current market value

due to changes in market conditions. This type of liquidity risk can arise from:

• Market Volatility: Significant fluctuations in market prices, which can make it difficult to sell assets without incurring a loss.

• Market Depth: The depth of the market, or the volume of transactions that can be conducted without impacting the asset's price,

can influence the ease of liquidating assets. In thin markets, large sales can drive down prices significantly.

• Regulatory and Economic Changes: Shifts in regulations or broader economic conditions can impact market liquidity, making it more

challenging to convert assets into cash quickly and at minimal loss.

In essence, liquidity risk embodies the challenges an organization might face in maintaining adequate cash flow to meet its obligations and the

difficulties in managing and liquidating assets efficiently in changing market environments. Effective liquidity management is crucial to mitigate

these risks and ensure financial stability and operational continuity.

In 2024, customer deposits on Group Level increased by Euro 2.6 billion representing a 5% rise compared to 31.12.2023.

The liquidity buffer, comprising cash and deposits with the Central Banks, government and corporate bonds (both eligible and non-eligible as

collateral by the Central Banks), and other liquid items, stood at Euro 17.5 billion at the solo level and Euro 20.1 billion at the Group level as of

31.12.2024. The Bank’s financing from the Eurosystem was Euro 2.6 billion at year-end, reduced from Euro 5 billion on 31.12.2023.

During year 2024 the following issuances and repayments of bonds have been performed:

▪ In February 2024, Alpha Bank successfully placed a Euro 400 million, senior preferred bond with a coupon of 5.00%. The bond has a

6.25-year tenor and is callable at year 5.25.

▪ In June 2024, Alpha Bank placed a Euro 500 million Subordinated Tier II bond with a coupon of 6%, featuring a 10.25-year tenor and

callable at year 5.25.

▪ In June 2024 , Alpha Services and Holdings S.A. invited holders of its outstanding € 500 million Dated Subordinated Fixed Rate Reset

Tier 2 Notes to tender their Notes for cash at a price of 99.75 per cent. As at 13.6.2024, a principal amount of € 369 million of the

Notes were validly tendered, while a principal amount of € 131 million remained outstanding.

▪ In September 2024, Alpha Bank placed a Euro 300 million Additional Tier I bond with a coupon of 7.5%. The bond has a perpetual

maturity and is callable at year 6.

▪ In November 2024, Alpha Bank exercised the early redemption option on its Euro 400 million Senior Preferred bond, which carried a

coupon of 7% and was set to mature in November 2025.

▪ Ιn December 2024 under the Alpha Bank-Credit Linked Note Issuance Programme, the Group issued a new credit linked bond with a

nominal amount of € 87,6 million and maturity date 30.6.2039, callable on 23.1.2029 and with a floating coupon of Euribor 3M

In June 2024, Alpha Bank was upgraded to Baa3 by Moody’s with a positive outlook. In September 2024, it was upgraded to BB+ by S&P Global

Ratings and to BB with a positive outlook by Fitch.

During 2024, the European Central Bank reduced its deposit facility rate by 100 basis points, from 4% to 3%. Similarly, the Main Refinancing

Operations (MRO) rate was reduced by 135 basis points, from 4.50% to 3.15%, arrowing the spread between the deposit facility and MRO

rates from 50 basis points to 15 basis points.

To monitor liquidity risk, liquidity stress tests are conducted on a regular basis in order to assess potential outflows, contractual or contingent,

and their impact on the liquidity buffer. 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.

Moreover, following the submission of the 2024 ILAAP report the Contingency Funding Plan was reviewed and updated as part of its annual

review cycle. The Contingency Funding Plan complements the Recovery Plan and is designed to support the efficient management of an

emerging liquidity crisis. Its primary purpose is to enable timely remedial actions to mitigate any reduction in the liquidity buffer.

Interest Rate and Credit Spread Risk in the Banking Book

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Interest Rate Risk in the Banking Book (IRRBB) refers to the risk that a change in base interest rates, such as the Euro swap curve, will impact

the Bank’s Net Interest Income and the Fair Value of Assets and Liabilities (Economic Value of Equity). Credit Spread Risk in the Banking Book

(CSRBB) is the risk arising from changes of the market price for credit risk, for liquidity and for potentially other characteristics of credit-risky

instruments, which is not captured by another existing prudential framework such as IRRBB or by expected credit/(jump-to-) default risk.

CSRBB captures the risk of an instrument’s changing spread while assuming the same level of creditworthiness.

Alpha Bank closely monitors the interest rate risk of the banking book and has adopted a strategic and holistic approach to manage the overall

interest rate and credit spread risk. The change in the Net Interest Income and the change in the Economic Value of Equity, which result from a

change in base interest rates, are calculated for internal and prudential stress scenarios on a monthly basis. The Bank has established

appropriate limits at its Risk Appetite Framework to monitor its IRRBB exposure. Additionally, the Credit Spread Risk of the Banking Book

(CSRBB), which is calculated based on pre-defined scenario developed by the Bank, is monitored on a quarterly basis. The relevant IRRBB stress

tests scenarios results, along with the limit usage, are presented to the Assets-Liabilities Management Committee and to the Risk Management

Committee of the Board of Directors.

In 2024, the Bank continued the execution of its hedging strategy to manage the interest rate exposure within its risk appetite. The Bank

remains within the ΔEVE (Economic Value of Equity) to Tier 1 and the ΔΝΙΙ to Tier 1 Risk Appettite Framework limits across all different interest

rate stress scenarios.

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 risk framework for the monitoring of trading limits, investment limits and counterparty limits has been designed and implemented.

This framework 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 1.8 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.

With respect to sovereign yields, the 10-year German Government Bond yield increased by 34 basis points (bps) and the 10-year Greek

Government Bond yield increased by 16.5 bps and the 10-year Italian Government Bond yield decreased by 18 bps.

Non-Financial Risks

Non-Financial 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. Non-Financial Risk includes Legal Risk, Information & Communication

Technology (ICT) Risk, Fraud Risk, Conduct Risk, Compliance Risk, Model Risk, Outsourcing Risk, Data Risk, Human Capital Risk, Physical Damage

Risk, Execution Risk and Reputational Risk.

The Group has developed the Non-Financial 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 Non-

Financial Risk Management Framework is monitored by the Group’s competent Non-Financial Risk and Internal Control Committees.

The Group Non-Financial Risk Management Framework’s main components aim to manage the Non-Financial risk exposures effectively and

proactively. In particular:

•

Non-Financial Risk Events: management of Non-Financial risk events occurring across the Group

•

Risk Assessments and Scenario Analysis: various Non-Financial risk assessments are performed (e.g. Risk & Control Self-Assessment,

Outsourcing Risk Assessment) and Scenarios are developed to proactively identify and mitigate potential Non-Financial risk exposures.

•

Indicators: Key Risk Indicators have been developed to Group Entities (both at Risk Appetite Framework and operational level) to monitor

the Non-Financial risk exposures

•

Risk Transfer: The partial transfer of certain types of Non-Financial Risk through the purchase and activation of certain Insurance Policies

•

Mitigating Actions: Corrective actions are developed and monitored to mitigate the Non-Financial risk exposures

•

Reporting: Internal and regulatory reports are generated and disseminated to various stakeholders across the Group

•

Capital Requirements: calculation of capital requirements for Non-Financial risk (under Pillar I and II).

In 2024, the following developments occurred:

•

Redesign of the Outsourcing Risk Assessment Process, including the Outsourcing Risk Questionnaire in order to meet business needs and

regulatory requirements.

•

Insurance Coverage enhancements: Reinsurance structure for the renewal of the insurance contracts has been completed.

•

Non-Financial Risk Management - New Target Operating Model: The Group introduced a new Operating Model regarding Non-Financial

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 Non-Financial risk management procedures. The new Operating

Model introduces the role of Non-Financial 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.

•

Risk Awareness and Training: a series of risk awareness and training sessions were held regarding Non-Financial risk management.

•

RAF Indicators Update: the Risk Appetite Indicators regarding Non-Financial Risks are updated and enhanced in order to introduce:

Forward-looking Indicators

More risk sensitive and linked to Pillar II Capital Indicators

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ANNUAL FINANCIAL REPORT

Indicators for all Non-Financial Risk subcategories (Reputational Risk, Legal Risk, Outsourcing Risk, etc.)

•

Non-Financial Risk Policies Updates: A number of new Policies were developed, and existing ones were updated.

New Policies: Non-Financial Risk Events related to Credit Risk Management Policy, Reputational Risk Committee Charter, Procedures

Manual for the Management of Non-Financial Risk Events, Non-Financial Risk Profile, Non-Financial Risks Data Quality Checks, NFR

Partners Roles and Responsibilities, Insurance Policies Backtesting Process, COREP Report – Generation Process and Data Quality

Controls, Data Quality Issues Identification Process, Incident Management Workflow User Manual.

Update of existing Policies: Non-Financial Risk Management Policy, Non-Financial Risk Scenario Analysis Policy, RCSA Manual, Key Risk

Indicators Policy, Loss Events’ Management Manual, Group Non-Financial Risk Events Management Committees, Major PSD Incidents

Reporting Procedures Manual, Group Bankers Blanket Bond (BBB) – Cyber Edge Committee, Third Party Lawsuits’ Management

Procedures Manual, Reputational Risk Management Policy, Non-Financial Risks & Internal Control Committee, Fraud Risk Management

Policy, Non-Financial Risks Control Validation Framework.

NON-PERFORMING EXPOSURES (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.

EPerforming Exposures Strategy, Recovery and Monitoring unit (the "NSRM") is responsible for the remedial management of the NP-The Non

portfolio of the Group, setting the strategic principles and actively monitoring the performance of the NPE reduction plan.

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 31.12.2024 decreased by c. 0.7 billion compared to 31.12.2023

and therefore NPE ratio

reduced to 3.8% as at 31.12.2024.

The organic reduction effort focused on long-term restructuring solutions, while the overperformance result in the curing effort led to

surpassing the 2024 target. Targeted campaigns and new product offerings also contributed to the positive results of the organic deleveraging

in 2024, an effort that will continue throughout 2025.

Furthermore, portfolio sales remain pivotal in accelerating the NPE deleveraging of the Group. The Group within 2024 classified the following

NPE perimeters as Assets Held For Sale:

•

A NPE portfolio (Project GAIA I).

•

A NPE portfolio (Project GAIA II).

•

A Cypriot NPE portfolio (Project ACAC)

More information on above are provided in the section “Significant Ecents”.

The macro challenges are expected to continue throughout 2025 – albeit less intense – the Bank intends to capitalize on the proactive

management framework, leveraging 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:

• to successfully defend the strong credit standing of our loan book,

• to further reduce the NPEs inflows, and

• to achieve the ambitious NPEs deleveraging targets

REAL ESTATE OWNED ASSETS (REOs) MANAGEMENT

In addition to the efficient and effective management of its NPEs, the Group has captured within its strategic priorities the successful

management of REOs through the subsidiary Αlpha Real Estate Services S.A. 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 was created to facilitate a more effective promotion of non-own-used properties and REOs. Through the website as a

main point of first contact with interested parties, Alpha Real Estate Services S.A., during 2024, has managed to dispose assets representing a

book value of approximately Euro 22 million in Greece and Euro 39 million in Cyprus and SEE (excluding sales of Project Skyline), achieving the

targeted sale prices. This demand was mainly driven by inflation which traditionally favor less liquid assets.

NPE ratio is presented in the in the Appendix of the Βoard οf Directors’ Management Report.

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The forecasts indicate that the strong interest in the real estate market will continue in 2025, however we acknowledge that the legal

framework for real estate assets sales (transfer of ownership) remains challenging, albeit improving in recent years with advancements such as

real estate cadastre penetration and the e-property platform from AADE which facilitates the sales execution.

At the end of 2024, Alpha Bank, through its 100% subsidiary Alpha Group Investments Limited, has completed the sale of a 65% equity stake in

Skyline Real Estate Single Member S.A. (“Skyline”) to P&E Investments Axiopoiisis kai Anaptyxis Akiniton Société Anonyme (“P&E”), an

investment vehicle controlled by Dimand S.A., Premia Properties REIC and the European Bank for Reconstruction and Development (EBRD)

(the “Transaction”).

The completion of the Transaction marks the conclusion of the largest open market real estate portfolio transaction in Greece in recent years.

The transcaction perimeter consists of a portfolio of assets of multiple types, including offices, commercial real estate, residential and

industrial or logistics assets. The portfolio will be either redeveloped and repositioned for rental use or sold directly to the market. The

perimeter includes approximately Euro 0.2 billion in repossessed assets contributing to Alpha Bank, post project Skyline, having one of the

lowest stock of such assets within the Greek banking system.

In the context of the Transaction, Alpha Real Estate Services SA (“ARES”), the listed real estate servicer, entered into an initial 7-year Asset

Management Services Agreement with Skyline. Benefiting from its long and successful track record, ARES will offer property and facility

management, as well as agency, technical and project management services.

Furthermore, the Group has completed the sale of its remaining properties in Bulgaria and, as a result, will terminate its presence in the

country.

The fundamentals of the Greek economy coupled with the technical characteristics of the domestic market continue to support a favorable

trajectory for real estate assets over the medium term.

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) 2023 decision, communicated by the European Central Bank (ECB), for

2024 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 the Note Capital Adequacy of the financial statements].

The OCR consists of the minimum threshold of the Total Equity Ratio (8%), in accordance with Article 92 (1) of the Capital Requirements

Regulation (“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.

On December 2024 Alpha Services and Holdings S.A. received the SREP decision 2024 regarding the Capital Requirements for the year 2025.

The additional supervisory requirements for Pillar II (P2R) remains unchanged to 3.0%.

The Bank of Greece has set the O-SII buffer at 1 % for 2024, and the Countercyclical Capital Buffer at 0% for Greece, for the year 2024.

In addition, under Executive Committee Act 235/1/07.10.2024 the Bank of Greece has decided to set the countercyclical capital buffer rate for

Greece at 0.25%, applicable from 1 October 2025. The target rate for the positive neutral rate of the countercyclical capital buffer in Greece at

0.5%.

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

22nd 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 was 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.

On June 22, 2020 as a response to the COVID-19 pandemic the EU adopted Regulation No 2020/873 of the European Parliament and of the

Council amending Regulations (EU) No 575/2013 and (EU) 2019/876. The Bank has adopted art 473a of the Regulation (EU) 2020/873. The

purpose of the regulation is to mitigate the negative impact on the regulatory capital of the Bank from the increase in the expected credit loss

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ANNUAL FINANCIAL REPORT

as a result from the Covid-19 pandemic. This article extents to another two year period 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. More specific, the weighting factors were set at 1.00 for the first two years (2020 and 2021), 0.75 in 2022, 0.5 in 2023 and

0.25 in 2024.

3. Capital Adequacy Ratios

On 31.12.2024, the consolidated Common Equity Tier (CET) 1 capital stood at Euro 4.9 billion, while the Risk Weighted Assets (RWAs)

amounted to Euro 30.3 billion, resulting in a CET 1 ratio of 16.3%, up by 1.90% versus 31.12.2023.

4. Shareholder Remuneration Policy

Alpha Services and Holdings has updated its shareholder remuneration policy following the restoration of profitability. The policy document

has been approved by the Board of Directors (BoD) on the Meeting of 12.12.2024. 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.

Alpha Services and Holdings applied and received on 05.06.2024 the approval for the distribution of Euro 122 million to its shareholders (20%

of Group's net profit for financial year 2023). Following the approval of the Annual General Meeting which took place on 24.7.2024 the Bank

proceeded with the Distribution to its shareholders.

Based on the above and in view of the capital accretive Business Plan for 2024-2026, the Bank aims to apply up to a 43% dividend pay out ratio

on FY2024 reported profits and 50% for the following two years (2025 and 2026 results). In this context, from 2025 onwards the Bank is

committed to accelerate DTC amortization for prudential purposes by voluntarily deducting it from capital ahead of the scheduled timeline.

This action will improve Bank’s capital quality and increase its strategic options for capital deployment. The acceleration of DTC will be set

equal to 29% of planned dividends.

5. EU-Wide Stress Test 2025

On July 5, 2024, the European Banking Authority (EBA) published for informal consultation its draft methodology, templates, and guidance for

the 2025 EU-wide stress test. This step marks the beginning of the dialogue with the banking industry and builds upon the methodology used in

the 2023 exercise, with improvements reflecting new insights and regulatory changes. On January 20, 2025, The EBA launched the 2025 EU-wide

stress test and released the macroeconomic scenarios. The EBA expects to publish the results of the exercise at the beginning of August 2025.

The 2025 EU-wide stress test will assess the resilience of the European banking sector in the current uncertain and changing macroeconomic

environment under a baseline and adverse scenario during a three-year time horizon, from 2025 to 2027. The adverse scenario is based on a

narrative of hypothetical worsening of geopolitical tensions, with large, negative, and persistent trade and confidence shocks having strong

adverse effects on private consumption and investments, both domestically and globally. The worsening of economic prospects is associated

with a sustained drop in EU GDP by 6.3% cumulatively, in the period 2025-2027. At the end of the horizon, unemployment in the EU is projected

to be 6.1 percentage points (ppts) above its baseline level. Inflation shifts upwards to 5.0% and 3.5% respectively in 2025 and 2026, before falling

back to 1.9% in 2027. As in the 2023 EU-wide stress test, this year’s scenario includes information on the growth of Gross Value Added (GVA) in

16 sectors of economic activity. Such break-down will help better assess EU banks’ performance depending on their business model and sectoral

exposures.

Some important changes are introduced, notably the integration of the Capital Requirements Regulation (CRR3) that is implemented on January

1, 2025. It also considers the Commission’s announcement to postpone the application date of the fundamental review of the trading book

(FRTB). Other enhancements include the centralization of net interest income (NII) projections and advancements in the market risk

methodology to increase risk sensitivity. For the purpose of the EU-wide 2025 Stress Test, the Bank is part of an EBA sample of 64 banks – thereof

51 from countries which are members of the Single Supervisory Mechanism (SSM) – covering roughly 75% of total banking sector assets in the

EU and Norway. The expanded geographical reach and incorporation of proportionality features aim to boost efficiency while ensuring the

relevance and transparency of the results.

6. Deferred Tax Assets (DTAS)

The Deferred Tax Assets (DTAs) which are included in the Group’s capital base as at 31.12.2024 stand at Euro 4.8 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.

On 31.12.2024, 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 2.4 billion and constitutes 49.2% 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.

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ANNUAL FINANCIAL REPORT

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

On one hand, the deposits’ increase and the new issuance of Εuro 300 million and, on the other hand, the credit expansion and the TLTRO

repayment are the main drivers for the regulatory liquidity ratios’ evolution. As of 31

of December 2024, the Group’s Liquidity Coverage

Ratio (LCR) stands at 199.8% and Group Net Stable Funding ratio (NSFR) is estimated at 125.3% % 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 32.5%.

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.

On 22 April 2024, Alpha Bank S.A. received a communication letter from the European Single Resolution Board (SRB) including its decision for

the minimum requirements for own funds and eligible liabilities (MREL). The requirements are based on the Recovery and Resolution Directive

(“BRRD2”), which was incorporated into the Greek Law 4799/2021 on 18.5.2021. At the same time, by the same decision, the Resolution

Authority defined the single point of entry (SPE) resolution strategy. The letter also sets out the intermediate MREL targets to be met from 1

January 2024 up to 31 December 2024, i.e. 18.81% (excluding CBR) of TREA and 5.91% of LRE. Following the Decision of SRB on 20 December

2024, Alpha Bank received the binding Minimum Requirement of Own Funds and Eligible Liabilities (MREL), according to which the Bank needs

to meet from 30 June 2025 on a consolidated basis an MREL requirement of 23.57%

of Total Risk Exposure Amount (TREA) and 5.91% of

Leverage Exposure (LRE). The Decision also sets out that the binding target of AB SA also reflect the MCC

†

allowance. The said MREL

requirements expressed as a percentage of TREA do not include the Combined Buffer Requirement (CBR), equal to 3.69% as of 31.12.2024.

In Europe, the Single Resolution Board (SRB) published a new package containing Minimum Bail-in Data Templates (MBDT) and released its

2024 MREL policy. This policy allows adjustments in calibrating the Market Confidence Charge (MCC) and monitoring eligibility, among other

changes. Meanwhile, the EBA published two consultations, one on the resolution plan reporting framework and another on independent

evaluators. The EBA also released a monitoring report on AT1, T2, and TLAC/MREL instruments, suggesting that capital instruments (AT1 and

T2) should have a prudential valuation reflecting their loss absorption capacity. It recommended using the carrying amount instead of the

nominal for prudential matters and left open the possibility of extending this treatment to MREL-eligible instruments for resolution, a decision

for the European resolution authority.

Furthermore, the Resolution Authority has decided that Alpha Bank S.A. is not subject to requirement for subordinated MREL . The MREL

requirements, including the multi-year transitional period, are subject to annual review / approval from SRB.On 31 December 2024, the Bank’s

MREL ratio stood at 29.04%, which is well above the interim non-binding target of 22.50% of the Total Risk Exposure Amount (TREA) (effective

01.01.2024, including CBR). The ratio includes the profit of the financial reporting period that ended on 31 December 2024 post a provision for

dividend payout.

REGULATORY ENVIROMENT FOR ANTI-MONEY LAUNDY AND FINANCIAL SECTORS’ DIGITAL

TRANSFORMATION

Without CBR

Market Confidence Charge

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

Developments in the context of the financial sector's digital transformation

A new AML/CFT Regulatory “Package” has been adopted by the European Council and has been published in the EU's Official Journal on 19

June 2024. The EU “Package” consists of four pieces of legislation:

• The EU “single rulebook” Regulation (“AMLR”)

• The 6th Anti-Money Laundering Directive (“AMLD”)

• The Regulation establishing the European Anti-Money Laundering Authority (“AMLA”)

• The revised Transfer of Funds Regulation (“TFR”)

The AMLR contains several new provisions including the extension of the scope of obliged entities, the organizational obligations of the obliged

entities in terms of internal policies, procedures, controls and regular risk assessments in order to implement the risk-based approach against

ML/FT cases. Additionally, harmonised and much tighter Customer Due Diligence measures are introduced, while compliance with targeted

Financial Sanctions is becoming a priority goal under the new EU AML/CTF regime. The provisions on beneficial ownership transparency state

detailed rules for identifying the Beneficial Owners, while new rules are introduced allowing obliged entities to establish partnerships for sharing

of information necessary for compliance with AML/ CTF regulations, including the reporting of suspicious activities.

The AMLD6 provisions cover the delegation of additional powers to Supervisory Authorities and detailed rules on the responsibilities and powers

of the Financial Intelligence Groups, as well as their direct access to financial, administrative and law enforcement information, including tax

information. The AMLR and AMLD6 are to start applying in July 2027.

The AML/CFT Package also establish a new European AML supervisory authority, the Anti Money Laundering Agency (AMLA), based in Frankfurt

that will commence its operations on July 1, 2025. AMLA's most important responsibility is the direct supervision of Selected Obliged Entities

(SOEs) while through its oversight of National Competent Authorities (NCAs), AMLA indirectly supervises Non-Selected Obliged Entities, ensuring

that NCAs proper AML/CTF practices. Moreover, AMLA aims to harmonize supervisory practices across the EU by developing common guidelines,

standards, and methodologies. AMLA will adopt more detailed rules supplementing the AMLR by issuing regulatory technical standards.

The FTR - Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets is a recast of the Regulation (EU)

2015/847 (issued together with the Crypto-asset Regulation - MiCAR) and is applicable since 30 December 2024.

The Bank has incorporated the FTR provisions, as well as the main principles of the AMRD6 and the AMLR in its updated AML Group Policy and

is progressing for the prompt and effective endorsement of all required provisions of the “Package”.

Regulation in the context of the financial sector's digital transformation

In 2024, the European authorities maintained their focus on digitalization and on the strengthening of the pan-European payments market, in

line with the digital strategy defined by the European Commission (EC) in 2020.

The EU approved the first AI Regulation, imposing obligations employing a risk-based approach. AI systems are classified under one of the

following risk categories: unacceptable risk, high risk, transparency risk and minimal risk. General-purpose AI models, including generative AI,

are classified under the systemic risk category if they fulfill specific criteria. High-risk applications, like credit scoring and insurance, will be

regulated from August 2026. General-purpose AI obligations start in August 2025. As part of our Digital Transformation, we have set up a

dedicated team to oversee the development and deployment of Artificial Intelligence (AI) models, to ensure their effectiveness and

compliance with quality standards, including data quality assessment, model development, human oversight, and post-market monitoring. The

EC also consulted on AI's impact on financial services and regulations. In addition, discussions about the European Commission's proposal for

the new Financial Data Access Regulation (FIDA) are ongoing. The regulation sets requirements for financial institutions to facilitate data

sharing with authorized third parties regarding savings, credit, and investment products.

In the Payments space, important legislative initiatives under negotiation include the new Payment Services Regulation (PSR) and Directive

(PSD3), which will update the requirements for payment services in the EU, introduce significant changes in fraud prevention, and account

access services (open banking). The Instant Payments Regulation, effective April 2024, aims to ensure instant payments are fully available by

the end of 2025 across all EU and EEA countries.

The “Payments Package” promoted by the European Commission constitutes an opportunity to establish a seamless pan-European payments

experience for both consumers and merchants. In Greece, we are aligning with this direction through the efforts of Alpha Bank and the

domestic banking system. We have introduced IRIS payments, a Peer to Peer (P2P) and Peer to Business (P2B) service built on instant

payments. Additionally, we are working on enhancing customer experience, strengthening our fraud and risk management framework, and

increasing user adoption.

Moreover, the European project for a potential issuance of a digital euro — a central bank digital currency (CBDC) for retail use — progressed

last year. The European Commission's proposal to establish the legal framework for the potential digital euro, outlining its main features and

distribution model, is under negotiation in the European Council and Parliament. The ECB continues with the preparation phase to lay the

project's foundations and determine several elements of the design. As Alpha Bank, we participate in this process through the Hellenic Bank

Association and the European Banking Federation. This phase will conclude in 2025, after which the ECB Governing Council will decide whether

to proceed to the second preparation phase, paving the way for potential issuance.

Markets in Cryptoassets Regulation (MiCA), has been fully implemented in Europe, setting obligations for crypto-asset issuers and service

providers. ESMA and EBA finalized MiCA's second-level regulation. The ESAs are developing regulations for DORA, effective in 2025, to ensure

financial sector resilience. Internationally, the Basel Committee issued a consultation on principles for third-party risk management

TRANSFORMATION

Transformation Program

In 2024, the Group continued the successful Transformation journey.

In the area of Wholesale Banking, following the successful assessment of the existing service model, the design of the new target operating

model of Wholesale Banking is already in progress and is expected to radically change the way Wholesale Banking operates with significant

anticipated benefits for customers. In addition, increasing the sales time of Relationship Managers by relieving them from time-consuming

administrative tasks remains a priority which will be achieved through new credit tools in full swing ("SME Workflow" / "Corporate Workflow"

/ "Swimlanes - Digital credit papers DCPs") enhancing the level of automation in an effective way. Most of the improvements and new tools

have already been completed or are expected to be completed within 2025 based on existing plan. With regard to new digital products and

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

services offered via digital channels, the first phase of the project for issuing letters of guarantee "eLG" was completed, while Business service

packages, “My Business Benefit” was launched during 2024.

Within the scope of its Wealth Management Services Transformation, the Bank has decided to create a unified wealth ecosystem to support

the ambition of all customer segments, expanding the Services offered and covering all functions across the wealth value chain through all

channels, thereby strengthening the Bank’s position as leader in the wealth management sector. In this context, in 2024, the Bank set forth

several actions to revamp its system infrastructure and redesign its operating model in wealth management. The implementation is to begin in

2025 and will bring significant benefits to customers such as faster service, simplified onboarding processes, improved digital services and at

the same time will optimize internal processes and create further efficiencies to Relationship Managers (RMs).

Finally, the Bank continued the automation, simplification, and centralization of processes that are taking place in the Branches, with the main

goal of enhancing customer experience and operational efficiency.

Digital Transformation and Innovation Activities

The Group, understanding the constantly evolving banking needs of its customers, continues to dynamically execute its Strategic Plan which

emphasizes on the design and implementation of digital solutions aiming to enhance the customer's banking experience.

Following the initial setup of the Digital Factory in 2023, the improvement of its operations was set as a goal, leading to the delivery of

significant digital products and services, which are presented in more detail below and nd to expand further in 2024, reaching 15 agile working

groups (squads) in order to support major projects of the Digital Strategy such as the Mobile App for Individual Customers.

These working groups are supported by User Experience (UX) and Customer Experience (CX) experts, so that the digital services offered are

more user-friendly increasing customers’ satisfaction. The Bank also strengthened the utilization and use of Advanced Analytics, integrating

specific Artificial Intelligence tools for processing Big Data and Unstructured Data. In this manner, the utilization of data and information

expands decision-making processes and functions, thereby enhancing operational efficiency and facilitating more precise and informed

business decisions. In addition, the Digital Sales teams continue to successfully achieve the digital penetration goals, particularly in the

consumer lending segment.

Digital Banking

The year 2024 was marked by strategic decisions and investments for the Group, focusing on enhancing human resources, developing

innovative digital services and upgrading technological infrastructure. Over the course of the year, new digital products were developed that

meet customer needs and expand their choices. Through the digital channels, both individuals and businesses gained access to enhanced

services designed with a focus on ease of use and real time support.

The contribution of digital channels remained crucial reaching the

percentage of 98% of total transaction volumes. This performance

highlights the continued trust that the Group’s customers place in

the digital platforms. Specifically, transactions conducted via e-

Banking presented significant growth, with the number of

transactions increasing by 16% and their value rising by 12%

compared to 2023.

• e-Banking for Retail customers

E-Banking for retail customers recorded substantial growth, with

transaction volumes increasing by 22% and transaction values rising

by 11% compared to 2023. A 7% increase compared to 2023 was also

observed in customer preference for e-Banking registration, with 1 in

3 customers (38%) choosing to complete their registration online. Additionally, noteworthy is the ratio of customers who prefer using the

myAlpha Mobile app, with 4 out of 5 e-Banking users using the mobile app on a monthly basis.

In 2024, significant new products and solutions were made available to the retail customers via the digital channels. Specifically, the ability to

open a privileged account via the myAlpha Mobile App and myAlpha Web for retail users was introduced, alongside with the ability to close a

current account via e-Banking, provided significant convenience to the clientele.

At the same time, the myAlpha Quick Loan became available through the Skroutz.gr marketplace, offering our customers even greater

flexibility in their online shopping experience.

Furthermore, the option to block an e-Banking subscription via myAlpha Web for retail users in case of suspected fraud was introduced, as well

as the ability for freelancers and sole proprietors to initiate their banking relationship with Alpha Bank (open a current account and obtain e-

Banking Business codes) through myAlpha Web for retail users.

In 2024, the automation of certificate issuance continued, with three of them being offered instantly through e-Banking, while as of December,

customers obtain the myAlpha Cyber Security new product solution, for maximum protection of their online transactions and personal data.

Understanding the importance of customer education and continuous support to create a comprehensive digital banking experience and

develop valuable relationships, the e-Banking Walkthrough team’s activity continued dynamically throughout 2024. Through this initiative,

specialized staff provides daily personalized training via video calls, helping individual customers familiarize themselves with using e-Banking

and ensuring the security of their digital transactions.

• e-Banking for Business customers

In 2024, the use of e-Banking for Businesses increased significantly, both in volume and value of transactions, with over 60% of new corporate

clients choosing Alpha Bank's digital channels to start their banking relationship with us.

In year 2024, myAlpha Web for Business users was enriched with new features that facilitate and improve the experience of corporate

customers. Following the mandatory government inscription to IRIS Payments service by freelancers and sole proprietors, we developed a QR

code generation application enabling customers to receive payments up to Euro 10,000 per day. For even safer transfers, the possibility of

98%

Monetary Transactions

Digital Channels

(Web,Mobile,ATM,APS)

Branch

Reference Period: 2024

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

confirming the IBAN to other banks within Greece was also made available. Additionally, corporate e-banking users gained access to all the

documents issued and transmitted by Alpha Bank to the Independent Authority for Public Revenue (AADE) regarding their business activity.

Two new transaction packages for businesses, myBusiness Benefit Standard and myBusiness Benefit Advanced, were introduced via e-Banking,

offering significant financial benefits to businesses and allowing the choice of additional packages for simple import transactions with the new

Imports and Imports Plus packages. For better and more immediate service, the myAlpha Randez-vous service was added to the myAlpha Web

for business users platform, allowing its use without additional authentication, saving valuable time.

To alleviate branch congestion from daily tasks such as updating contact information, corporate users can also update their business contact

details, such as the business mobile phone and email, via the myAlpha Web for Businesses platform.

To further strengthen transaction security in business e-Banking, the Bank has implemented additional measures to ensure the protection of

corporate data and transactions. As of 2024, the 6-digit myAlpha Code is required for all transactions to third parties, as well as upon logging

into myAlpha Web for Business users. In addition, a stricter control system was implemented with the blocking of the corporate e-Banking

subscription after multiple incorrect entries of the myAlpha Code, thus ensuring maximum protection against malicious actions.

• Distinctions

The overall effort to strengthen digital services is reflected by the significant awards received by the Bank in the field of digital banking for

2024:

o Product of the Year 2024 – myAlpha Vibe

Alpha Bank was awarded Product of the Year in the "Services" category for myAlpha Vibe, an innovative online service that allows parents to

give digital (via mobile) pocket money to their children at any time. Through a dedicated application, the child can use their pocket money to

make contactless transactions in Greece and abroad, with parents having full visibility and complete control.

o Digital Finance Awards 2024 – Digital Bank of the Year 2024

Alpha Bank was honored as Digital Bank of the Year at the Digital Finance Awards 2024, winning five additional awards: Best Mobile App (Gold)

and Best Payments and Transactions Processing Digital Initiative (Gold) for the Bizpay application, Best Digital Product Launch (Gold) for

myAlpha Vibe, Best Card Digital Initiative (Gold) for acquiring a credit card via e-Banking, and Best Corporate Financing Initiative (Silver) for

myAlpha Web for businesses.

o Mobile & IoT (Internet of Things) Awards 2024

The Bank received three awards, with myAlpha Vibe winning Gold in the "Digital Innovation via Mobile" category, the myAlpha Mobile app

winning Silver in the "Banking & Financial" category, and the Bonus app winning Bronze in the "Mobile Use for Customer Loyalty" category.

o National Customer Service Awards 2024

For 2024, Alpha Bank won three distinctions at the prestigious annual National Customer Service Awards: for myAlpha Vibe in the category

"Innovation in Customer Experience – Best Use of Innovation in Customer Experience," for the Remote Customer Collaboration Platform &

myAlpha Documents in the category "Best Omni-channel Customer Service," and for the Printec & Alpha Bank collaboration in the category

"Best Outsourcing Partnership".

ATM Network & Automated Transaction Centers

During 2024, we continued to invest in Self Service Banking, so customers choosing to visit the Bank's branches could handle their simple daily

transactions via the ATM and Automated Payment Systems networks..

More specifically:

• The replacement of the ATM fleet with state-of-the-art machines, completed at the end of 2023, offered significant benefits such as

faster transactions, reduced waiting times, improved user experience, and advanced security mechanisms.

• Emphasizing accessibility for all our customers, the voice guidance service for visually impaired users saw an 12% increase in usage

compared to 2023.

• A new system was integrated into the ATM network offering online fault monitoring and dispute resolution, aiming for faster

problem detection and resolution and, consequently, increased network availability.

Overall, the value of transactions via the ATM network increased by 2.4% compared to the previous year. However, there was a significant 7%

increase in the value of cash deposits, highlighting the stable course and value of the Bank's network.

Similarly, we continue providing the ability to carry out transactions via the expanding APS network, available in almost every branch.

Specifically, 98% of the branch network runs at least one APS, enabling customers to make deposits and cash payments with an Alpha Bank

card, further facilitating autonomous customer service for numerous transactions.

Digital Sales

In 2024, there was significant growth in digital sales through the Bank's digital channels. The total percentage of products sold through digital

channels accounted for 27.2% of the total products offered to Retail Banking customers. Special mention should be made of the significant

increase in online sales of the digital consumer loan, myAlpha Quick Loan, available through myAlpha Mobile and myAlpha Web, compared to

2023. The overwhelming majority of disbursed loans were made via mobile phone, representing 76% of the total consumer loans and 46.5% of

the total amounts disbursed (Euros).

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ANNUAL FINANCIAL REPORT

Similarly, the percentage of online issuance of debit cards was also high, reaching 36% of total issuances, as well as the percentage of online

term deposits for individuals (Alpha Online Term Deposit and Alpha Online Term Deposit with Bonus), with 47% of new term deposits being

completed through the Bank's Digital Networks. Additionally, of all the customers who choose to start their collaboration with Alpha Bank,

24% of the accounts opened used the Retail On Boarding service through the myAlpha Mobile application.

Moreover, commercial actions supported the capability for customers to give digital "pocket money" to their children via myAlpha Mobile and

the specially designed myAlpha Vibe application, which was created exclusively for the needs of the product and the management of the card

by teenagers and adopted by more than 5,800 families. At the same time, the new credit card issuance capability achieved excellent results,

representing 41% of the total cards issued by the bank in 2024. Finally, significant new digital products were successfully supported and made

available through digital channels in 2024. The new myAlpha Benefit transaction programs were added to the available online products at the

beginning of 2024, providing Individual customers with the ability to reduce transaction costs.

User Experience (UX)

The Bank’s User Experience Center of Excellence is in the center of our Digital Factory, with a team of 15 UX/UI experts and copywriters. In

2024, there were designed more than 500 User Flows, +500 screens and were run extensive User research to ensure that the Bank offers a

simple and intuitive digital experience in the mobile and web-banking.

In this period, the strategic project of the design of the new mobile app for individuals was completed, along with the new web and mobile

banking for business. The new digital experience created with a study of 1,800 features and validated with deep dive user research (+ 300

users) covering the new and strategic customer segments of the Bank.

To increase the Bank’s velocity and ensure UX consistency between all the digital assets of the bank the UX/UI team has designed a new, re-

usable Digital Guideline system.

Customer Experience (CX)

In 2024 communication was performed with more than 28 thousand Individuals and Business customers to identify customer satisfaction

drivers as well as improvement points across segments along with their Net Promoter Score (NPS) evaluation. Digital and Call Center user data

were analyzed using NLP (Natural Language Processing) by the Advanced Analytics team to identify the critical issues. All issues have been

sorted horizontally across the Bank with the processing of more than 30 thousand user cases. As a result, a series of improvement and close of

the loop actions were identified and designed, and Design thinking workshops were organized between channels and Customer Departments.

In addition, we completed in May 2024, the Front-Line Survey of Wholesale Employees, with 80% participation and critical input for the

customer experience of Commercial Banking sector.

NPS (Net Promoter Score) is more than a metric for the Bank and for this reason we embarked in Q2 2024 into a strategic project with the

support and active participation of all Business Areas in the creation of a new NPS System and governance. This will put CX metrics and insights

in the center of the Bank’s decisions and in the focus of management, along with all key customer journeys that are needed to be re-designed

in order to improve the NPS.

Finally, the CX team is working since January 2024 on the launch of Chat bot in alpha.gr to ensure that an improved digital experience is

provided to all visitors of the public website and since March 2024 , the chatbot engaged with customers to answer more than 230 thousand

conversations.

AI – Advanced Analytics

In 2024, we continued building a technically self-competent team, investing in reskilling and upskilling of our people, being involved in projects

and advanced PoC’s (Proof of Concept) on new technologies and expanding our collaboration to new domains in the Bank. We increased our

advanced analytics (AA) model delivery by 70% compared to previous year, while at the same time invested in training in areas related to data,

analytics and AI.

Several pilot projects leveraging generative AI (genAI) technologies were completed and the new AA platform was successfully deployed ,

migrating all critical AA models (150+ data flows) and laying the foundation for the deployment of the more advanced genAI use cases. We

implemented a pilot digital assistant (chatbot) for our employees, which utilizes genAI to answer our colleagues' questions in natural language

form by searching and summarizing in a few seconds information from documents like bank policies, internal processes and user manuals. We

are planning for the full rollout of the digital assistant to the entire document base within 2025 expecting efficiency gains in employee

productivity.

The Bank has made significant strides in leveraging Generative AI technologies to enhance the productivity and efficiency of its employees.

Through the Copilot Adoption Program, the Bank has successfully integrated Microsoft Copilot 365 AI assistant into the daily operations of

selected business users. This initiative aims to optimize user engagement and deliver measurable business value

The implementation of MS Copilot 365 has resulted in notable improvements in productivity, allowing users to complete tasks more quickly

and with higher quality. This has enabled employees to focus on more valuable activities, thereby increasing overall efficiency and users

satisfaction.

27,2%

72,8%

Retail Banking Sales (#)

Digital Channels

(Web,Mobile)

Branch

Reference Period: 2024

76%

24%

Consumer Loans (#)

Digital Channels

(Web,Mobile)

Branch

Reference Period: 2024

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

28 |

ANNUAL FINANCIAL REPORT

Following the successful pilot phase, the Bank has developed a comprehensive plan to expand the use of MS Copilot 365 to a larger number of

employees. This plan leverages best practices and the expertise gained during the pilot phase to ensure effective activation, engagement,

adoption, and realization of value.

The integration of AI and NLP into our CRM systems has also revolutionized our digital sales strategy, enabling us to deliver highly personalized

and targeted communications across multiple channels, including email, Viber, in-app notifications, and the newly launched messages via

myAlpha Web in 2024. This digital evolution has significantly boosted both the volume and effectiveness of our outreach.

During the year alone, 1,5K campaigns were executed —a remarkable 40.6% increase from 2023—

delivering 34.6 million messages to 2.3million unique customers. This represents a 39.7% increase in

message volume from the previous year, achieving 100% contact coverage across all customer

segments. Our communications strategy prioritizes high-value segments, driving sales related

actions in the high rate of 32.5%, while also addressing key moments throughout the customer

journey and gathering valuable insights through t-NPS (transactional Net Promoter Score) surveys.

Our new digital sales approach, powered by an automated needs recognition mechanism (NBA –

Next Best Action), has further enhanced customer engagement. By offering tailored product

recommendations at the right moment, we have successfully increased both sales growth and

customer loyalty, reinforcing our commitment to delivering relevant, timely, and impactful

interactions.

This comprehensive personalized communication strategy guarantees that each customer receives offers and information tailored to their

specific needs and preferences, significantly enhancing their experience and fostering a deeper connection with our brand.

Innovation

Innovation constitutes a core element of Alpha Bank’s DNA and corporate values. It is what has historically guided the bank to deliver

pioneering products and services that make a positive and lasting difference in the lives of our customers. Recognizing the need to manage

innovation in a systematic manner, the Bank established in 2024, the Digital Strategy and Innovation unit, under the Chief Digital Officer, along

with the associated innovation governance framework and a mandate to explore, test/experiment and deploy value-creation ideas beyond

traditional banking leveraging digital technologies and partnerships with members of the FinTech ecosystem (in Greece and internationally)

In this context, the new unit scouted and assessed more than 60 startups/scaleups during the year for potential collaboration, with 6 of them

already having, either concluded or in-progress pilot tests. Indicative examples include

1. A successful internal pilot with a Spanish startup (3

place winner of Alpha Bank's international innovation competition, FinQuest

2022) offering a mobile app to educate, inspire and mobilize bank employees to complete daily challenges and adopt responsible

daily practices in line with the ESG framework and goals of the bank. During the 3-month pilot, 2,026 actions were completed,

resulting in 194K tons of water saved, a reduction in CO2 emissions by 667kg, and an energy saving of 1200 kWh. This initiative

received the Gold award in the "CSR Apps" category at the Hellenic Responsible Business Awards 2024 and will be rolled out to all

staff in 2025

2. A successful proof-of-concept with a Swedish financial education mobile app for children aged 8-14 that teaches them the concepts

of earning, spending, saving, and managing money using an interactive and gamified environment.

3. A successful pilot for Alpha Bank’s first digital assistant in alpha.gr in collaboration with a Greek AI startup. The assistant successfully

addresses customer queries both in Greek and English, using a combination of three AI technologies: Natural Language Processing,

Natural Language Understanding, and Generative AI. The solution is in full-deployment at alpha.gr with a plan to be embedded in our

digital channels in 2025.

Finally in 2024, the i3 idea pitching and awards event for the 4

internal innovation competition took place. Once again, Alpha Bank employees

embraced innovation, proving that new ideas come, not only from external sources but also from the organization’s own staff, provided they

are given the opportunity. The winning idea aims at improving accessibility of the bank's services to people with hearing disabilities (both in

the physical and digital space) and is scheduled to launch in 2025

International

Significant progress has also been made in the foreign subsidiaries in 2024:

➢ Alpha Bank London:

In 2024, the Bank continued the implementation of infrastructure changes (Core Banking System) which is now planned for completion by

April 2025. At the same time, the analysis and design for the implementation of Finastra's digital application (web and mobile banking) have

already begun, with completion expected in the third quarter of 2025. The application will provide daily banking capabilities to existing

customers of AlphaBank London. It is noted that Finastra's Mobile banking application is a temporary solution as the plan includes

transitioning to the new MyAlpha mobile app of the Group, which is already under development and is expected to be completed for

AlphaBank London by the end of the first half of 2026. The transition of AlphaBank London to the MyAlpha mobile app will unlock new

capabilities and conveniences for cross-border banking as it will support all the functionality planned for the launch of AlphaBlue according to

the subsidiary's new business plan.

➢ Alpha Bank Cyprus

Alpha Bank Cyprus in alignment with its strategic commitment to elevate and accelerate transformation across the Bank, in 2024, has achieved

significant advancements in its customer facing digital platform, Alpha 360, as well as implementing internal automations combined with

processes improvements. Looking forward the Transformation Program 2025-27, will be covering initiatives that focus on delivering tangible

commercial impact, enhancing customer-centricity, significantly improving operational efficiency, optimizing infrastructures along with

strengthened regulatory compliance. Under the Transformation Program 2025-27, there are 61 planned projects, out of which 28 are already

1070

1500

2023 2024

Campaigns

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

29 |

ANNUAL FINANCIAL REPORT

in progress, with the remaining scheduled to be implemented throughout the respective period. These efforts will solidify the foundation for

sustained growth and operational excellence, positioning the Bank to achieve its long-term strategic objectives.

OTHER

Alpha Services and Holdings’ Share and Shareholder Structure

The Alpha Services and Holdings S.A. has been listed on the Athens Exchange since 1925 and is consistently classed as one of the largest

companies in terms of market capitalization. At the end of June 2024, the capitalization of the Alpha Services and Holdings S.A. (“former Alpha

Bank S.A.”) stood at Euro 3,825 million and represented 5.03% and 16.85% of the capitalization of the Athens Exchange’s General and Banking

Indexes companies respectively, while the participation of its share in the FTSE/Athex Large Cap Index was 7.53%.

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 indexes 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 2024 amounted to an average of 5,758,344 shares per session,. with an average daily value of transactions

of Euro 9,165,189.

Share information for the Alpha Services and Holdings S.A

2024

2023

Closing Price (period end, in Euro)

1.62

1.54

Highest Price (period, in Euro)

1.78

1.68

Lowest price (period, in Euro)

1.37

1.03

Market Cap (period end, in billion Euro)

3.8

3.6

Share’s daily trading volume

5,758,344

8,504,513

Average daily value of transactions (in Euro)

9,165,189

11,632,472

Shareholder Structure

On 31.12.2024, the Alpha Services and Holdings S.A (“former Alpha Bank S.A.”) share capital stood at Euro 682,363,415.3 million divided into

2,352,977,294 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"), of which 226,138,299 are owned by Unicredit SPA.

The shares in circulation on 31.12.2024 were held by approximately 104,000 Individual and Institutional Investors.

The breakdown of the Alpha Services and Holdings shareholders on 31.12.2024 was, for descriptive (non-regulatory) purposes, as follows:

Treasury shares

The Company decided at its shareholders Ordinary General Meeting dated 27.7.2023, 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.

In January and September 2024, an amount of 1,890,504 and an amount of 1,799,829 treasury, ordinary, registered, voting shares of the

Company, with a value of Euro 3 million and a value of Euro 3 million respectively were made available free of charge to the Beneficiaries.

The Annual General Meeting of the Shareholders dated 24.7.2024 decided the amendment of the Share Buyback Program for acquisition of

own existing common, registered dematerialized shares, with voting rights, pursuant to provisions of article 49 of law 4548/2018, in order to

complete the Share Buyback program of Euro 61 million. Towards this, an amount of 32,900,866 treasury shares have been purchased, as of

31.12.2024 with a total cost of Euro 52 million.

Subsidiary company Alpha Finance performs transactions with the shares of the company Alpha Services and Holdings in the context of market

making. As at 31.12.2024 the carrying amount of the treasury shares was € 61 million. Below are described the transactions of treasury shares

of the Group.

(Amounts in millions)

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

30 |

ANNUAL FINANCIAL REPORT

Number of shares

Carrying amount

Balance 1.1.2023

1,343,335

Purchases

21,833,960

Sales

(15,935,826)

(22)

Losses from sales

Balance 31.12.2023

7,241,469

Purchases

74,533,313

118

Sales

(38,906,960)

(63)

Share award rights to employees

(3,690,333)

(6)

Gains from sales

Balance 31.12.2024

39,177,489

Number of Branches

As at 31.12.2024 the Group is operating with 263 Branches, out of which 249 are established in Greece and 14 are established abroad.

Events after the balance sheet date

• Under article 48 of Law 5167/2024, pricing amendments are implemented for outgoing and incoming SEPA (Single Euro Payment Area)

transfers. More specifically, a lower price list should apply per transfer order, up to a daily transfer amount limit. Additionally, all bill

payments and direct debits towards Public sector/Insurance funds, Water supply companies, Municipalities, Energy and natural gas

providers, Internet and telephony providers, Insurance companies should be free of charge. The impact of the above is estimated to be a

decrease in income of € 21 mil. annually.

• In the context of the stock option plan for the year 2020, during the exercising period of the stock options and in specific during the period

2.1.2025 until 15.1.2025, 697,462 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. The purchase amount of the above shares was paid in cash and amounted to

a total of € 0.2. On 10.2.2025 the share capital increase was registered in General Electronic Commercial Registry’s (GEMI) while on

14.2.2025 the above 697,462 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 € 683 million, divided into 2,353,674,756 common,

nominal, voting shares with a nominal value of € 0.29 each.

• In January 2025 the Company repurchased 5,649,854 shares with a cost of € 9 mil. and as a result the share buyback program in the

context of the dividend distribution for the fiscal year 2023 was completed. In total 38,550,720 shares were repurchased amounting to €

61 mil.

• On 27.1.2025, the Group's subsidiary, ALPHA HOLDINGS S.A., entered into a binding agreement for the acquisition of 100% of the shares of

FLEXFIN LTD, based in Cyprus, which is the sole shareholder of FlexFin S.A., based in Greece. The completion of the transaction is expected

to take place within Q2 2025.

• On 13.2.2025, Alpha Services and Holdings S.A. repurchased the entire remaining principal amount of the Lower Tier 2 Notes of € 131 mil..

• On 27.2.2025, the Board approved an offer received from an investor regarding the sale of Alpha Leasing Romania and its subsidiary Alpha

Insurance Brokers S.R.L. The SPA agreement is expected to be signed in the first quarter of 2025. Based on the conditions of the sale

agreement an estimated loss of € 4 mil. is expected to be recorded in the results of 2025.

• On 27.2.2025, Alpha Services and Holdings announced the agreement on the key commercial and legal terms for the acquisition of assets

and liabilities of the baking sector, as well as personnel of AstroBank, The transaction will be implemented through Alpha Bank Cyprus Ltd,

a wholly owned subsidiary of the Group. The transaction is expected to be completed by the end of 2025, subject to the finalization of the

transaction documentation, and to the satisfaction of customary conditions precedent, including obtaining all necessary regulatory

approvals and consents. The transaction is expected to have a limited impact on the Group’s CET1 ratio of around 40 basis points. As per

the transaction terms, the acquisition perimeter will exclude certain NPE’s of AstroBank as these will be carved out prior to the completion

of the transaction, effectively making the acquisition NPE-neutral at Group level.

Corporate Sustainability Reporting Directive (CSRD) (2464/2022) of the European Parliament

The Corporate Sustainability Reporting Directive (CSRD) mandates that companies provide more detailed disclosures on environmental, social,

and governance matters in accordance with EU-established sustainability standards. Furthermore, the CSRD stipulates that sustainability

reports are subject to external assurance to ensure accuracy. The financial institutions must disclose ESG data pertaining to their portfolios,

lending practices, and investments, in a standardized, digital format, aligning with the EU's broader sustainability objectives and promoting

transparency and accountability.

Τhe Sustainability Statement as per the provisions of Law 5164/2024 (CSRD) is presented in separate section of Board of Directors’ Report.

Application of par. 3 article 97 and article 99 of Law 4548/2018

During 2024, in application of article 97 par. 3 of Law 4548/2018, the Executive Members of the Board of Directors of Alpha Services and

Holdings S.A. (the “Company”), Messrs. V.E. Psaltis and S.N. Filaretos, abstained from a total of six (6) BoD meetings in which decisions were

made or, as the case may be, the following agenda items were discussed: the Material Risk Takers (MRTs) list for the year 2023 at Group level,

the Combined Bonus Plan, as they are included in the perimeter of the Band Senior Leadership Team (SLT), the approval of the Performance

Incentive Program (PIP) Bonus Pool for 2023 for the Senior Leadership Team (SLT) as well as the award under the Stock Award Plan to the SLT

under the PIP 2023, as they are included in the Beneficiaries of the allocation of the award under the PIP 2023 to the SLT Bonus and the

respective Share Award, the Profit Distribution to Staff Members and more specifically the distribution of an amount of Euro 55,919 of the

Company’s Intragroup dividends reserves to Company’s Staff as well as the distribution of an amount up to Euro 12.6 million by Group

Companies’ to their eligible Staff, as they are Members of the SLT the said distributions apply to, the approval of a recommendation to submit

to the General Meeting of Shareholders of the Company concerning an increase of the maximum ratio between the fixed and variable

components of remuneration for the Members of the Executive Committee, as they are Members of the Executive Committee. Additionally,

the CEO, Mr. V.E. Psaltis abstained from two (2) BoD meetings in which decisions were made or, as the case may be, the amendment of his

contract, was discussed.

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

31 |

ANNUAL FINANCIAL REPORT

Moreover, the Independent Non-Executive Members of the Board of Directors, Mmes. E.M. Andriopoulou, E.R. Hardwick and D.C. Lebot,

abstained from one BoD meeting where a decision was made on the extension of the mandate granted to an advisory company regarding the

Board succession planning for a period of one year.

Furthermore, the Independent Non-Executive Member of the Board of Directors, Ms. E.R. Hardwick, abstained from one BoD meeting where a

decision was made on her participation in the Board of Directors of Euroclear.

Additionally, the Independent Non-Executive Member of the Board of Directors, Mr. D.C. Tsitsiragos, abstained from a total of ten (10) BoD

meetings in which decisions were made or, as the case may be, the following agenda items were discussed: his participation in the Advisory

Board of Chicago Atlantic Fund, the election of the Chair of the Board of Directors and the amendment of the annual remuneration of the

Chair of the Board of Directors.

Moreover, in application of article 99 of Law 4548/2018, the Board of Directors of the Company endorsed on 12.12.2024 the amendments of

the contracts of the CEO and the Deputy CEO, who, as Members of the Executive Committee are related parties with both Alpha Bank S.A. (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 abovementioned contracts as well as the Fairness

Opinion dated 11.12.2024, issued by the Independent Advisor “Willis Towers Watson Greece”, 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 Advisor “Willis Towers Watson Greece” were registered to the General

Commercial Registry (G.E.MI.) on 23.12.2024. On 8.1.2025 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:

(amounts in thousands of €)

31.12.2024

31.12.2023

Assets

Loans and advances to customers

3,181

3,633

Liabilities

Due to customers

5,222

7,346

Employee defined benefit obligations

278

253

Debt securities in issue and other borrowed funds

4,268

4,765

Provisions

1,011

Total

10,779

12,364

Letters of guarantee and approved limits

422

308

(amounts in thousands of €)

From 1 January to

31.12.2024

31.12.2023

Income

Interest and similar income

151

174

Fee and commission income

Gains less losses on financial transactions

Total

157

180

Expenses

Interest expense and similar charges

174

106

Remuneration of Board members, salaries and wages

14,053

9,922

Total

14,227

10,028

Remuneration of key executives and their close relatives is analyzed as follows:

From 1 January to

(amounts in thousands of €)

31.12.2023

Remuneration of Board members, salaries and wages

7,511

6,451

Employee defined benefit obligations

Bonus Incentive program expenses

3,862

2,511

Termination benefits

1,890

Employer contributions

603

728

Other

172

216

Total

14,052

9,927

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

32 |

ANNUAL FINANCIAL REPORT

B. Τhe outstanding balances of Alpha Services and Holdings S.A. with the Group companies and the corresponding results are as follows:

(Amounts in thousands)

Subsidiaries

Name

Receivables

Liabilities

Income

Expenses

Alpha Bank S.A.

1,181,468

24,845

247,390

25,617

Insurance

Alphalife A.A.E.Z.

5,252

12,011

Real Estate and hotel

Alpha Real Estate Management and Investments S.A.

Alpha Investment Property Attikis S.A.

APE Fixed Assets S.A.

AEP Industrial Property S.M.S.A.

AIP Attica Residential Assets I S.M.S.A.

AIP Thessaloniki Residential Assets S.M.S.A.

AIP Cretan Residential Assets S.M.S.A

AIP Aegean Residential Assets S.M.S.A.

AIP Ionion Residential Assets S.M.S.A.

AIP Attica Retail Assets I S.M.S.A.

AIP Attica Retail Assets II S.M.S.A.

AIP Attica Residential Assets II S.M.S.A.

AIP Gis ΙΙ S.M.S.A

AIP Commercial Assets ΙΙ S.M.S.A

AIP Attica Resedential Assets IV S.M.S.A.

AIP Commercial Assets ΙΙI S.M.S.A

SPEs and Holding

Alpha Holdings Single Member S.A.

Other companies

Kafe Alpha S.A.

Alpha Supporting Services S.A.

Emporiki Management S.A

Alpha Bank Notification Services S.A

Associate

Alpha Investment Property Eleona S.A.

Alpha Investment Property Neas Kifissias S.A.

Alpha Investment Property Kallirois S.A

Alpha Investment Property Levadias S.A.

Alpha Investment Property Neas Erythraias S.A

Alpha Investments Property Kallitheas S.A

Alpha Investment Property Irakleiou S.A.

AIP Commercial Assets City Centres S.M.S.A.

AIP Thessaloniki Commercial Assets S.M.S.A.

AIP Commercial Assets Rog S.M.S.A.

Skyline Assets Single Member S.A.

Athens Commercial Assets I

Athens Commercial Assets II

AEP Commercial Attikis MAE

AEP Eppagelmatikon Akiniton Periferia MAE

AIP Retail Assets Rog S.M.S.A.

Joint ventures

APE Commercial Property S.A.

APE Investment Property S.A.

Alpha Investment Property Commercial Stores S.A

Total

1,186,891

24,845

259,950

25,617

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

33 |

ANNUAL FINANCIAL REPORT

C. 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 Real Estate Services S.A., Alpha Services and Holdings S.A., Alpha Supporting

Services S.A., Alphalife A.A.E.Z.

The results related to the transactions with TEA are as follows:

(amounts in thousands)

From 1 January to

31.12.2024

31.12.2023

Expenses

Staff cost and expenses

7,146

9,403

TEA Group Alpha Services and Holdings keeps a deposit with Alpha Bank amounting to € 25 thousand as at 31.12.2024 (31.12.2023: € 61

thousand).

THE CHAIRMAN

OF THE BOARD OF DIRECTORS

THE CHIEF

EXECUTIVE OFFICER

DIMITRIS C. TSITSIRAGOS

ID No A 00808440

VASSILIOS E. PSALTIS

ID No ΑΙ 666591

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

34 |

ANNUAL FINANCIAL REPORT

Explanatory Report of the Board of Directors of Alpha

Services and Holdings S.A. for the year 2024

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 2024 contains detailed information, pursuant to the provision of article 4 par. 7

of Law 3556/2007, with reference date 31.12.2024, in accordance with the order in which it appears in the said provision.

In particular:

I. Company’s Share Capital Structure

On 31.12.2024 the share capital of the Company stood at the total amount of Euro 682,363,415.26, divided into 2,352,977,294 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 31.12.2024 was formed following the share capital increase pursuant to the resolution of 26.9.2024 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 39,903.13, by issuing and granting to the Beneficiaries/Employees of the Company and its Affiliated Companies 137,597

common, registered, dematerialized shares of the Company with voting rights, of a nominal value of Euro 0.29 each.

Each share incorporates all rights and obligations as these derive from the Law 4548/2018 and the Company’s Articles of Incorporation, the

provisions of which are in line with the provisions of the Law. Each share carries one vote in any General Meeting of Shareholders.

II. Restrictions on the transfer of the Company’s shares

The Company’s shares are listed for trading on the Athens Exchange and are transferred according to the law.

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

Αccording to Law 3556/2007, as amended and in force, the following significant shareholdings in the Company’s share capital have been

notified to the Company:

• According to the notification of 30.8.2022 to the Company “REGGEBORGH INVEST B.V.” held on such date common shares with the

corresponding voting rights, represented 5.158% of the total paid-in share capital of the Company.

• According to the notification of 14.11.2023 to the Company “UniCredit S.p.A.” held on such date common shares with the

corresponding voting rights, represented 9.6159% of the total paid-in share capital of the Company.

6.924%

81.266%

1.084%

10.726%

Greek Institutional Investors Foreign Institutional Investors

Legal Retail Investors Individual Retail Investors

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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 legal and regulatory framework,

including 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.

In accordance with article 6 of the Company’s Articles of Incorporation, the General Meeting of Shareholders, by virtue of a resolution may

delegate to the Board of Directors the power to decide, by a majority of two thirds (⅔) of its Members and within five (5) years from the date

of the relevant resolution, on the increase of the share capital with the issuance of new shares. The amount of the increase may not exceed

three times the amount of the share capital existing on the date of the delegation to the Board of Directors of the relevant power to increase

the share capital The above apply accordingly to the issuance of convertible bonds, in accordance with article 71 of Law 4548/2018. The above

authorities of the Board of Directors may be renewed by the General Meeting for a period not exceeding five (5) years for each renewal.

It is noted that, there are no resolutions of the General Meeting of shareholders in force for the concession of the above authorities to the

Board of Directors.

On 31.7.2020, the Ordinary General Meeting of Shareholders approved the establishment and implementation of a five year Stock Options Plan

(2020-2024) in the form of stock options rights for the acquisition of newly-issued shares, according to article 113 of Law 4548/2018, to be

granted to Employees of the Company and its Affiliated Companies within the meaning of article 32 of Law 4308/2014. According to the Plan,

each stock option right corresponds to one (1) new share. The offer price of each new share is equal to the nominal value of the share. After the

timely payment by the beneficiaries of the value of the shares corresponding to the option rights exercised by them, the Board of Directors will

proceed with a corresponding increase of its share capital in accordance with article 113 of Law 4548/2018.

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. In implementation of the Plan, the Board of Directors of the Company by its resolutions dated 30.12.2020, 16.12.2021,

21.07.2022 and 15.12.2022 approved and amended accordingly the Plan’s Regulation.

More detailed information regarding stock options exercised during the reference year are provided at respective note of Staff Costs of Annual

Financial Report.

On 27.7.2023 and 24.7.2024, the Ordinary General Meeting of Shareholders approved, pursuant to article 49 of Law 4548/2018, the

establishment and the amendment, accordingly, 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.

By virtue of its resolution dated 1.8.2024, the Board of Directors repealed its resolution dated 8.11.2023 regarding the appointment of a Third

Party Broker as Lead Manager of the Program, pursuant to article 4 par. 2 (b) of the Commission Delegated Regulation (EU) 2016/1052 and

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resolved the share buyback to be carried out by the Company on the stock market via Alpha Finance Investment Services S.A., which is a

Subsidiary of the Company and an investment firm authorized to provide investment services in Greece. It is further decided that the

remaining terms of the Share Buyback Program, as described in the resolutions of the above General Meetings of Shareholders dated

27.7.2023 and 24.7.2024 and further detailed in the resolution of the Board of Directors dated 8.11.2023 shall remain in full force and effect.

More detailed information regarding own shares having been acquired by the Company are provided at respective Noteof Share Capital of

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

DIMITRIS C. TSITSIRAGOS

ID No A 00808440

VASSILIOS E. PSALTIS

ID. No ΑΙ 666591

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Sustainability Statement FY 2024

GENERAL INFORMATION

[BP-1] General basis for preparation of sustainability statements

The Sustainability Statement has been prepared on a consolidated basis, similar with the basis of preparation for the financial statements. The

Statement covers information for Alpha Services and Holdings Group (hereinafter the “Group”), including material impacts, risks and

opportunities pertaining to its own operations and downstream value chain. Specifically, the information of the sustainability statement is

extended to include information connected with the Group through the offering of financial products/services to its Customers related to the

material impact on climate change. The Group monitors especially the carbon-related data of its Customers, enhancing its business model,

aligning its strategy and incorporating actions, to holistically promote sustainable practices, enhance transparency, and mitigate reputational,

financial, and regulatory risks, while fostering long-term value creation for all stakeholders.

The list of all entities included in the present Sustainability Statement can be found on the ‘Νοte 44 Group Consolidated Companies’ of the

Financial Statement. The largest subsidiary of the Group is Alpha Bank S.A. (denoted hereinafter as “Alpha Bank” or the “Bank”).

The Group is in the process of continuously improving the level of availability of information, methodologies used and alignment of actions and

targets currently implemented from the Bank and all its subsidiaries, as well as improving its monitoring and management approach regarding

its joint ventures and associates.

No subsidiary undertakings included in the consolidation are exempted from consolidated or individual sustainability reporting, and no

information is omitted corresponding to intellectual property, know-how or innovation. Furthermore, no exemption has been used for

disclosures linked to developments in the course of negotiations.

The Sustainability Statement has received an Independent Limited Assurance in accordance with ISAE 3000 (Revised).

[BP-2] Disclosures in relation to specific circumstances

Time horizons

It is noted that any reference in the Sustainability Statement to short, medium and long-term horizons are aligned with the definitions of ESRS

(“short-term” time horizon refers to 2025, “mid-term” to 2026-2030, and “long-term” to the future time period after 2030).

Value chain estimations and relevant uncertainty

Where relevant and applicable, the Group has utilized methods to estimate value chain data. This was the case for the estimation of Scope 3

emissions and their disaggregation per subsidiary, economic activity and source type, as disclosed in [E1-6] Gross Scopes 1,2,3 and Total GHG

emissions. More specifically, indirect sources used for the calculation of some Scope 3 emissions categories were:

• For Alpha Bank S.A. DEFRA 2024 Conversion Factor (Business Travel-land/Cars by size/Medium/CNG) was used.

• For Alpha Bank London Ltd, the equivalent carbon footprint factor from DEFRA Guide (2024), as well as the PCAF’s European building

emission factor database, were deployed.

• For Alpha Bank Cyprus, DEFRA 2024 (Business Travel-land» + «WTT- pass vehs and travel- land.), as well as PCAF’s European building

emission factor database, were deployed.

Adhering to the PCAF Standard guidance, the Group prioritized obligors' actual emissions and activity data in order to calculate financed

emissions. In cases where actual emissions were not publicly available/easily retrievable, proxies have been developed as a means to estimate

emissions, resulting in lower data quality. These proxies were calculated using activity proxies rather than proxies based on financial data.

It is noted that regarding quantitative metrics and monetary amounts that are under disclosure, no case of high level of measurement

uncertainty has been identified and overall, the uncertainty level of methodologies and estimations used is acceptable. However, the Group

continuously aims to increase transparency and accuracy to its sustainability reporting and to improve data quality. Therefore, where primary

data is available, the Group prioritizes the utilization of this data over estimations and assess and improves its methodologies for

measurements.

Changes in preparation or presentation of sustainability information

In comparison to the previous reporting period, no metrics previously used have been replaced. Furthermore, no comparative figures are

included in the present Sustainability Statement, as this is the first Sustainability Statement according to ESRS standards.

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Sustainability reporting stemming from other legislation and standards

In order to compile the present Statement, reporting data stemming from other legislative requirements have been utilized. In addition, to

complement information based on other widely accepted sustainability reporting standards, data using generally accepted sustainability

reporting standards frameworks.

The paragraphs per standard are presented in the following table:

TABLE 1 PARAGRAPHS PER STANDARD

Legislation/Standard

Paragraphs

GRI

417-2,3, GRI 418-1(b)

S4 Consumers and end-users

SASB

FN-CB240a.4, FN-CB-230a.2

S4 Consumers and end-users

Additionally, the Group relies on the following European Standards (ISO) and other management standards, as follows:

ISO 14064 Management System

ISO 50001 Energy Management System

ISO 45001 Occupational Health and Safety Management System

ISO 22301 Business Continuity Management System

ISO 27001 Information Security Management System incorporating ISO 27017 Information Security Controls for Cloud Services and ISO 27018

Protection of Personally Identifiable Information on Public Clouds

ISO 27701 Privacy Information Management

ISO 14001 Environmental Management System

ISO 9001 Quality Management System

ISO 20000-1 Information technology –Service Management System

EMAS Eco-Management and Audit Scheme

ISO 22316 Security and Resilience

ISO 20400 Sustainable Procurement

According to the International Organization for Standardization official website, ISO 22316:2017 and, ISO 20400:2017 and ISO 26000:2010

provide guidance rather than requirements, so they cannot be certified to unlike some other well-known ISO standards. Despite this, Alpha

Bank Group demonstrates full compliance with the guidance offered by these standards, integrating their principles into its practices and

activities.

BS 10012:2017 and Bureau Veritas Technical Standard Private Information Management System

Incorporation by reference

The following information has been incorporated by reference:

TABLE 2 DISCLOSURE REQUIREMENTS INCORPORATED BY REFERENCE

Disclosure requirements

Location

GOV-1

The role of the administrative, management and supervisory bodies

Section “Corporate Governance Statement” of

the Annual Report 2024

Global Reporting Initiative (GRI 2021)

Sustainability Accounting Standards Board (SASB)

Refers to Alpha Bank S.A. excluding category 15, Alpha Leasing S.A., Alpha Finance A.E.P.E.Y., Alpha Asset Management A.E.D.A.Κ.,

Alpha Real Estate Services S.A., ABC Factors S.A., Alpha Supporting Services S.A, Alphalife A.A.E.Z., Alpha Bank Cyprus Ltd

Alpha Bank S.A.

Alpha Bank S.A., Alpha Services and Holdings S.A., Alpha Supporting Services S.A.

It applies to certain divisions of Alpha Bank S.A., and the following subsidiaries: Alpha Leasing S.A., Alpha Finance Investment Services Single Member S.A.,

Alpha Supporting Services S.A.

Alpha Bank S.A. and for Alpha Supporting Services S.A applies only the 27001

Alpha Bank S.A.

Alpha Bank S.A., Alpha Supporting Services S.A.

It applies to certain divisions of Alpha Bank S.A., Alpha Leasing S.A., Alpha Real Estate Services S.A, Alpha Real Estate Management and Investments S.A., Alpha

Supporting Services S.A.

It applies to certain divisions of Alpha Bank S.A., Alpha Supporting Services S.A.

Alpha Bank S.A., Alpha Supporting Services S.A.

Alpha Bank S.A

Alpha Supporting Services S.A.

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GOV-2

Information provided to and sustainability matters addressed by the

undertaking’s administrative, management and supervisory bodies

Section “Corporate Governance Statement” of

the Annual Report

SBM-1

Strategy, business model and value chain (products, markets,

Customers)

Section “Strategic Plan” of the Annual Report

2024

[GOV-1] The role of the administrative, management and supervisory bodies

Board of Directors general information

On 31.12.2024, the Board of Directors of Alpha Services and Holdings S.A. consisted of 12 Members, who are appointed for a 4-year term, 2 of

which Executive Members and 10 Non-Executive Members (out of which 7 are Independent Non-Executive Members), which is in line with the

Group’s target of ensuring a majority of Independent Members. There is no representation of Employees and other workers at the BoD,

however, the BoD interacts regularly with employee representatives.

In terms of gender balance and diversity, the female BoD Members represented the 33%, while male BoD Members represented the 67% with

the average ratio of female-to-male members being 1:2. In terms of age diversity, it is noted that 33% of BoD Members are under the age

of 61.50% between 61-70, and 17% and over 70 years old. In terms of Independent Non-Executive Members, they comprise 58% of the BoD

(based on the composition of the Board of Directors on 31.12.2024).

For the structure and composition of the Alpha Services and Holdings Group, please refer to the Corporate Governance Statement 2024.

Board of Directors relevant experience

The Members of the BoD have strong experience in the Greek and/or international markets and possess deep knowledge and expertise related

to banking and financial markets, regulatory framework and legal requirements, strategic planning, the understanding of the Group’s business

strategy or business plan, risk management, accounting and auditing, Information technology and security, ESG factors and risks. An

assessment of BoD Members’ collective suitability, as well as individual self-assessment, 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”), is conducted annually with the support of the Corporate Governance, Sustainability and Nominations Committee.

The relevant information is stated in the annual Corporate Governance Statement which is included in the Annual Report 2024.

Responsibility for oversight of impacts, risks, and opportunities

Among others, the BoD has the overall responsibility for the Group and approves and oversees the implementation of the Group’s strategic

objectives, risk strategy and ESG strategy, as well as its internal governance and including as it relates to relevant impacts, risks and

opportunities.

There are four (4) Committees that operate at BoD level, each with an advisory role and with the possibility to assume delegated authorities,

as determined by the BoD. The duties and mandates of each Committee are included in their respective Charters, ensuring accountability and

clarity of their respective duties.

The Audit Committee, among others, safeguards the integrity of the financial and sustainability reporting processes, reviews the scope,

frequency and results of the audit assurance on sustainability reporting, including statutory requirements, collaborates with the Risk

Management Committee on the effective oversight of the mitigation of certain key areas of risk, including climate-related or other ESG risks

and liaises with other Board Committees in relation to issues on effective ESG control environment, internal controls and compliance. It also

ensures adherence to and compliance with the Code of Conduct and Ethics, oversees the Alpha Services and Holdings S.A.’s efforts to foster a

culture of ethics and makes recommendations to the BoD for approval the Anti-bribery and Corruption Policy. The full scope of the duties and

responsibilities of the Audit Committee are set out in its Charter, which is posted on the Alpha Services and Holdings S.A. website.

The Risk Management Committee, among others, monitors that the Alpha Services and Holdings S.A. adequately embeds ESG risks in its risk

appetite statement and framework and business strategy framework. Specifically, it collaborates with the Corporate Governance,

Sustainability and Nominations Committee, as well as with the Audit Committee, 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, and

reviews and recommends annually to the BoD for approval the Group’s Risk Appetite Framework and Statement, considering also ESG risks.

The Committee is also responsible for the development of a sound risk culture, including as it relates to conduct of business issues.

The full scope of the duties and responsibilities of the Risk Management Committee are set out in its Charter, which is posted on the Alpha

Services and Holdings S.A. website.

The Remuneration Committee, among others, is responsible for ensuring that ESG risks are reflected in the Group Remuneration Policy, as

appropriate. The Committee assesses the alignment of the Remuneration Policies with the Company’s ESG objectives, e.g. long-term resilience

of the business strategy, including ESG and risk appetite, in order to avoid conflicts of interest when business decisions are made and to

facilitate the implementation of ESG risk-related objectives. The Committee is also responsible for 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

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ANNUAL FINANCIAL REPORT

with the values, culture, business strategy, risk appetite and strategic objectives and discourage excessive risk-taking, promote effective risk

management and prevent the emergence of conflicts of interest or minimize any conflicts of interest that might arise.

The full scope of the duties and responsibilities of the Remuneration Committee are set out in its Charter, which is posted on the Alpha

Services and Holdings S.A. website.

The Corporate Governance, Sustainability and Nominations Committee (CGSNC) is responsible for, amongst others, assisting the Board in

ensuring the implementation of ESG standards based on regulatory requirements and relevant best practices, ensuring effective

communication on ESG issues with the Risk Management, Remuneration, and Audit Committees, reviewing current and emerging ESG trends

and regulatory developments reporting on at least a semi-annual basis and recommending to the Board areas that may require actions, and

reviewing the Group’s Sustainability/ESG Policy, at least annually, proposing amendments and recommending its approval by the Board as

needed. The Committee also assists the BoD in pursuing the implementation of international corporate governance best practices, including

through the implementation of checks and balance throughout the Group. It is also regularly informed from Heads of internal control functions

concerning the risk profile and risk culture of the Alpha Services and Holdings Group, and that there is an effective communication reinforcing

ethical values and good practice in daily business. The full scope of duties and responsibilities of the CGSNC are set out in its Charter, which is

posted on the Alpha Services and Holdings S.A. website.

For more information on the Committees, please refer to Corporate Governance Statement 2024.

Executive Management Level

The Group Sustainability Committee oversees sustainability matter, steers the Group’s ESG Strategy, and oversees its implementation, as well

as supports the BoD overseeing these matters. The Chief Executive Officer (CEO), as a Member of the Board and Chair of the Executive

Committee, is informed on sustainability and ESG matters and, in this capacity, provides input when needed. The Group Sustainability

Committee membership includes five C-level senior leaders as permanent members and C-level Executives, Members of the Executive-

Committee, as well as Executives of the Bank or Group Companies or external partners, may also be invited to participate in the Committee’s

meetings.

In addition, the BoD has established an Executive Committee which is vested with delegated powers and authorities, directly by the CEO. The

specific duties and responsibilities of the Executive Committee are set out in the Alpha Services and Holding Group’s Corporate Governance

Statement of the Annual Report 2024.

The full scope of the duties of the Group Sustainability Committee and Executive Committee is included in the Corporate Governance

Statement 2024 section.

Operational Implementation Level

The Group ESG Coordinator role has been established to lead sustainability-related initiatives and to oversee the ESG objectives within the

cross- functional ESG Working Group and is responsible for its oversight. The Group ESG Coordinator also acts as the Secretariat of the Group

Sustainability Committee and meets regularly with its Chair, the General Manager – Chief of Corporate Center and the General Manager –

Chief Risk Officer.

The ESG Working Group represents all areas of the Group that take ownership of ESG integration and ensures the flow of information across

relevant teams. Those teams consist of ESG specialists and dedicated representatives of relevant functions, including Retail Banking, Wholesale

Banking, Risk Management, Strategy, Human Resources and Wealth Management and Treasury). Representatives from each function form the

Operating Committee, which provides the Group Sustainability Committee with information on the progress of the respective ESG project

areas, including climate- related issues.

The Bank’s Governance and Sustainability Business Area drives the ESG agenda and ensures the adoption of best practices across the Group,

with an emphasis on ESG Strategy and ESG integration Sustainable Finance operationalization, stakeholder engagement and disclosures in line

with relevant regulatory requirements. The Governance and Sustainability Division also leads communication and the exchange of knowledge

and expertise between the Bank and its Group Companies.

Climate, ESG and Enterprise Risk Management is a horizontal risk function which collaborates and coordinates with the rest of the functions

and business units under the supervision of the Chief Risk Control Officer, while undertaking the management of a limited number of risks

under its controlling capabilities, related to Bank- wide and even Group matters. Amongst others, the function is responsible for maintaining a

proficient understanding of climate risk, ESG-related regulations and emerging trends, providing expert guidance for ESG integration into the

risk management framework, and more.

For the full scope of the function’s responsibilities, please refer to Corporate Governance Statement 2024.

Reporting lines for Board of Directors and its Committees

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The BoD, through its direct interaction with the four Committees, approves and oversees the implementation of the Group’s strategic

objectives, risk strategy, ESG strategy and internal governance. The BoD also ensures the integrity of the accounting and financial reporting

systems, including financial and operational controls and compliance with the law and relevant standards. It oversees the process of disclosure

and communications and is responsible for providing effective oversight to the Senior Management.

Directly subordinate to the Board is the CEO / Executive Committee, Group Sustainability Committee, and Group ESG Coordinator. In addition,

through the Risk Management Committee, the Board receives regular reports from the CRO and CFO on the implementation of the risk

strategy and risk appetite of the Company and of the Group, including as it relates to ESG risks. All Committee Chairs regularly inform the BoD

of the work of the respective Committee.

All Committees can be directly reported to from any relevant corporate and control function (e.g. legal, finance, human resources, IT, internal

audit, risk, compliance, including information on AML/CTF compliance and aggregated information on suspicious transaction reports and

ML/TF risk factor), as needed and requested, in order to fully discharge their duties.

For the full scope of potential reporting lines in terms of the Committees, please refer to their respective Charters.

Controls and procedures integration with other internal functions

The consideration of ESG impacts, risks and opportunities are embedded in the Group’s operating model, which defines how roles and

responsibilities concerning sustainability are allocated across the Alpha Bank S.A. ESG risks are considered across all vertical risk types and the

dedicated Climate and ESG Risk Team is involved in their assessment.

Specifically, detailed responsibilities are listed and discharged for all internal processes that are instrumental in ESG Integration. For more

information on these processes, please refer to [GOV-1] The role of the administrative, management and supervisory bodies.

Oversight of target setting and progress monitoring

The Group has set concrete targets in order to ensure the continuous attainment of its strategic and operational objectives. Notably,

commitments and associated targets developed for each of the ESG pillars are described in [SBM-1] Strategy, business model and value chain.

In addition, the BoD has approved the targets, while it is informed on a quarterly basis on the progress of KPIs towards the pledged

commitments and associated targets through a thorough report across the ESG pillars of the Group.

Ensuring appropriate level of skills and expertise

Ensuring adequate training regarding sustainability matters is a central consideration for the overall suitability of the Members of the BoD. In

order to promote effective oversight of sustainability matters, the Members of the BoD receive relevant training. According to the “Induction

and Training Policy and Procedure for the Members of the Board of Directors”, all the newly appointed Members of the BoD 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 Alpha Services and Holdings Group offers to all new Members of the BoD an induction program on, among others, the Group’s structure,

business model, risk profile and governance arrangements, legal and regulatory requirements in relation to the Group and the services it

provides, the Corporate Governance principles, Risk Management, Compliance and Internal Audit, Wholesale and Retail Banking, Wealth

Management and Treasury, External Statutory Audit, Capital Adequacy, Financial and Accounting Services, Credit Risk and NPEs, ESG,

Sustainability Information; Information Technology and Security, Human Resources, International Network, Digitalization, Transformation,

Strategic Planning. Sustainability matters are incorporated horizontally across these topics, as relevant.

Additionally, Alpha Services and Holdings Group, in the framework of the continuous training of the Members of the BoD, 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 Group. The training places emphasis on conceptual and strategic

issues and focus on new developments and on the influence these developments may have on the Group. As a result of these trainings,

Members of the BoD develop concrete skills and expertise linked to the management of the Group’s sustainability impacts, risks, and

opportunities. In particular, the above training programs pertaining to ESG covered several topics such as “ESG as a strategic enabler of

business for innovation and change”, “ESG regulatory environment for banks”, “Climate Policy”, “Adaptation and Resilience” etc.

Further to the above, the Members of the BoD during 2024 participated to the following training programs pertaining to ESG:

TABLE 3 TRAINING PROGRAMS FOR BOARD OF DIRECTORS

BoD Training programs

Duration

ESG Matters- IFRS and CSRD

1.5 hours

Climate

1.5 hours

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More information pertaining to the expertise and training programs of the Members of the BoD is available in the Board of Directors and

Committees, F2 and F14 sections of Alpha Services and Holdings Group Corporate Governance Statement within the Annual Report 2024.

Further to the above, the Alpha Services and Holdings Group also provides its BoD Members with the opportunity to participate in training and

education sessions offered by external institutions. Upon request by any Member, the Group may offer tailor-made programs to further

enhance the Members’ knowledge and competences.

[GOV-2] Information provided to, and sustainability matters addressed by the undertaking’s administrative, management and

supervisory bodies

The BoD, through the Risk Management Committee, receives regular reports, from the CRO and the Chief Financial Officer (CFO) on the

implementation of the risk strategy and risk appetite of the Company and the Group.

The CGSNC acts as the ultimate liaison between the Board Committees with respect to all sustainability/ESG issues and promotes respective

communications and feedback from all the BoD Committees.

The Audit Committee, among others, assists the BoD in safeguarding the integrity of the financial and sustainability reporting processes.

The Risk Management Committee, among others, monitors that the Group adequately embeds ESG risks in the overall risk appetite statement

and framework, business strategy and risk management framework.

The CGSNC, among others, 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 Group to assess the appropriate composition of the BoD. For further

information on the management oversight please refer to [GOV-1] The role of the administrative, management and supervisory bodies.

The Group is committed to identifying and managing the positive and the negative impacts to environmental, social and governance matters

created through its business operations, and across its value chain, through a robust due diligence process. The list of the material IROs

addressed by the administrative, management and supervisory bodies are presented under [SBM-3] Material impacts, risks and opportunities

and their interaction with strategy and business model.

[GOV-3] Integration of sustainability-related performance in incentive schemes

As per the 2024 Remuneration Policy of the BoD Members a Combined Bonus Plan (CBP) has been established which explicitly incorporates

ESG criteria for Material Risk Takers including SLT and directors. This includes short and long-term performance metrics, which may vary

annually and are always approved by the BoD. In terms of short-term metrics and as part of the criteria for the payment of variable

remuneration, specific ESG-related metrics are included that concern actions and initiatives that the Alpha Bank S.A. may be developing. In

terms of long-term performance metrics, the CBP includes KPIs, such as sustainable finance disbursement targets, and female participation at

middle management level and above. These metrics are linked to the material impacts, risks and opportunities identified through our due

diligence processes. As such, ESG criteria are incorporated in long-term incentive remuneration and are weighted at 20%.

Specific GHG targets have not been included yet in the variable remuneration framework, given that the Target setting for the first four sectors

was announced in November 2024.

[GOV-4] Statement on due diligence

TABLE 4 DUE DILIGENCE PROCESS

Core elements of due diligence

Chapters in the Sustainability Statement

Embedding due diligence in governance, strategy and

business model

[GOV-2] Information provided to, and sustainability matters addressed by the undertaking’s

administrative, management and supervisory bodies

[GOV-3] Integration of sustainability-related performance in incentive schemes

[SBM-1] Strategy, business model and value chain

[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and

business model

Engaging with affected stakeholders in all key steps of the

due diligence

[SBM-2] Interests and views of stakeholders

[IRO-1] Description of the process to identify and assess material impacts, risks and

opportunities

[E1-2] Policies related to climate change mitigation and adaptation

[E1-4] Targets related to climate change mitigation and adaptation

[E4-2] Policies related to biodiversity and ecosystems

[E4-4] Targets related to biodiversity and ecosystems

[E5-1] Policies related to resource use and circular economy

[S1-1] Policies related to own workforce

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[S1-5] - Targets related to managing material negative impacts, advancing positive impacts,

and managing material risks and opportunities

[S4-1] Policies related to customers

[S4-5] Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities

[G1-1] Business conduct policies and corporate culture

Identifying and assessing adverse impacts

[IRO-1] Description of the process to identify and assess material impacts, risks and

opportunities

[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and

business model

Taking actions to address those adverse impacts

[E1-3] Actions and resources in relation to climate change policies

[E4-3] Actions and resources related to biodiversity and ecosystems

[Ε5-2] Actions and resources related to resource use and circular economy

Tracking the effectiveness of these efforts and

communicating

[E1-4] Targets related to climate change mitigation and adaptation

[E4-4] Targets related to biodiversity and ecosystems

[Ε5-3] Targets related to resource use and circular economy

[S1-5] Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities

[S4-5] Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities

Contribution to Healthy Economies- Entity Specific

[GOV-5] Risk management and internal controls over sustainability reporting

The Group has established comprehensive risk management and internal control processes and systems specifically for sustainability

reporting.

These ensure the accuracy, reliability, and integrity of our sustainability data and disclosures. This approach leverages the same rigorous

processes applied to financial reporting, ensuring consistency and high standards across both areas. The risk management and internal control

processes cover all aspects of sustainability reporting, including data collection, processing, and disclosure. This includes risk identification, risk

assessment, control activities, information and communication, and monitoring. The Reporting Center of Excellence (RCOE) is critical

component in this process serving as the focal point and internal control mechanism for data reporting.

For the purposes of the CSRD Sustainability Statement in particular, the Steering Committee acts as the first control frontier with the

participation of Directors of the key departments, including Governance and Sustainability, Climate and ESG Risk, Internal Audit, Legal,

Accounting, Group Data Protection, Human Resources. The Group Sustainability Committee Functions as the second level approval, followed

by the Group Sustainability Committee, the CGSNC and the Audit Committee.

The Group’s risk assessment approach is based on the Basel Committee on Banking Supervision's standard 239 (BCBS 239) and the Principles of

Risk Data Aggregation and Risk Reporting (RDARR). RDARR processes are independently validated within the Group, by the second line of

defense.

The Data Governance and Quality Business Area owns the risk assessment process by overseeing the proper implementation of the Data

Governance Framework across the Group, ensuring the valuation, and monitoring of data quality. In that context the use of proxies is

continuously minimized, as referenced in [BP-2] Disclosures in relation to specific circumstances. Through the framework, a well-structured

operating model, with roles and responsibilities concerning data quality, is defined. In addition, the Data Quality Policy provides guidance for

data quality monitoring and remediation actions performed by data stewards and overseen by the Data Governance and Quality Business

Area. The Finance and Risk Reporting Framework defines the responsibilities of the report owners and producers (the respective business

areas within the Group), ensuring consistency and timeliness of reporting. Applied to the entire process, end-user Computing Developed

Applications are governed by the End-User Computing Policy, foreseeing the criteria for risk assessment and respective controls, ensuring data

integrity across the reporting landscape. As part of the Risk Appetite Framework, four Key Risk Indicators (KRIs) have been defined in order to

measure data quality risk – covering data ownership, reliability, accuracy and timeliness. In addition, the Risk Management Committee

oversees the Climate Risk Action Plan, ensuring the effective oversight of the management of climate and environmental risks.

Based on the aforementioned process, Non-Financial Risks (NFRs), including Sustainability Reporting risks are identified through various

methods, spanning across Risk and Control Self-Assessments (RCSA), scenario analysis, internal and external loss data reviews, regulatory and

audit findings, key risk indicators (KRIs), third-party risk assessments, and employee or customer surveys. Once identified, these risks are

prioritized using risk scoring and heat maps, materiality assessments, alignment with risk appetite thresholds, and evaluations of

interdependencies or concentration risks. Mitigation strategies include strengthening internal controls, implementing policies and training,

transferring risk through insurance or outsourcing, and establishing robust business continuity and incident response plans. Continuous

monitoring through regulatory compliance tools, stress testing, assurance reviews, and independent internal audits helps validate the

effectiveness of these measures.

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Once the reporting by the relevant Business Area has been reviewed internally, in line with the aforementioned process, the Governance and

Sustainability Business Area confirms the data and ensures it is properly incorporated into the report. An external auditor is also engaged to

assess the reliability of the data prepared.

In the case of risks being identified, the Group employs several mitigation strategies, including strengthening internal controls, implementing

further policies and training. To bolster the effectiveness of mitigation measures, the Group ensures monitoring through regulatory

compliance tools, stress testing, assurance reviews, and internal audits. The Risk Management Committee, the Corporate Governance,

Sustainability and Nominations Committee and the Audit Committee also collaborate as necessary to promote effective mitigation.

It should be noted that there were no relevant sustainability reporting risks identified in 2024.

The Audit Committee and the Risk Management Committee provide oversight of certain areas of risk management, and their repercussions on

the Internal Control System.

The Risk Management Committee is regularly informed about the quality of the sustainability reporting and convenes at least once a month,

inviting, as appropriate, 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 Committee Chair and Members.

The Data Governance and Quality Committee, Risk Committee and the Board of Directors are periodically updated on data quality issues and

on the implementation of the Data Governance and the development of the Quality Framework.

[SBM-1] Strategy, business model and value chain

Significant groups of products and services offered

The Group’s activities span across the Banking sector, Asset Management, Financing services, Investment Banking and Treasury, Insurance,

Provision of Information technology services and consulting, as well as Real Estate management. During 2024, the Group proceeded on certain

subsidiaries sale, with main activities related to Real Estate management and Banking

. Alpha Bank S.A. represents the largest subsidiary, and

therefore the Group’s significant group of products and services are related to banking products and services.

Its general strategy integrates aspects related to material sustainability matters, targeting to scale-up its sustainable finance strategy across

business and operating model, with key elements including:

• Increased sustainable disbursements

• Commitment to the Net Zero Banking Alliance and Aiming to align its portfolio with the Paris Objectives

• Incorporation of criteria related to sustainability matters in remuneration and risk-management framework.

Significant groups of Customers and location of operations

For information on significant groups of Customers and how the Group’s activities serve these Customers, please refer to [S4.SBM-3] Material

impacts, risks and opportunities and their interaction with strategy and business model in relation to consumers. The Group’s activities span

Greece, Cyprus, the UK, Romania, Ireland, with a limited presence in Serbia and Bulgaria.

Details on the total number of Employees in 2024 in addition to the breakdown across its geographical scope of operations can be found under

[S1-6] Characteristics of the undertaking’s Employees.

Exclusion list and limited activities and revenues from specific sectors

As per its exclusion list, Alpha Bank is not active in financing activities in cultivation and production of tobacco, and controversial weapons

(please see [E1-2] Policies related to climate change mitigation and adaptation).

Furthermore, the Bank measures, monitors and reports investments, loan exposures or financial products related to the activities of fossil fuel

(coal, oil and gas) sector, coal, oil, gas and chemical production according to SFDR requirements.

Alpha Bank S.A. and Alpha Asset Management A.E.D.A.K. comply with Regulation (EU) 2019/2088 (SFDR) on sustainability disclosures in the

financial services sector, as per its Sustainable Finance Statement and ESG sustainability disclosures. Alpha Asset Management ESG product-

level sustainability disclosures are available on its website. Currently, no SFDR Principle Adverse Impact indicators are available regarding

exposures and revenues from companies active in fossil fuel (coal, oil and gas) or chemical productions; however, the Group may have limited

exposure through its financing of clients who may be active in or have exposure to these sectors.

For detailed description of the subsidiaries sold in 2024 please refer to the Section: Assets Held for sale of the Financial Statements.

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Sustainability-related goals and strategy related to sustainability matters

The Group commits to create long-term value for its stakeholders, by setting sustainability-related goals in all areas where it operates and

establishes a comprehensive sustainability strategy to achieve them:

Support an environmentally sustainable economy

• Support its Customers’ decarbonization and align its portfolio emissions with the objectives set in the Paris Agreement

• Mitigate key drivers of biodiversity loss

• Support the transition to a circular economy

• Achieve Net Zero emissions in its own operations

Foster healthy economies and societal progress

• Enhance people’s financial health through inclusive access to financing

• Provide an inclusive and safe work environment

• Support inclusivity and access to Healthcare, Education, Culture and Heritage

Ensure a robust and transparent governance

• Ensure the Diversity and Independence of the Board of Directors

• Embed sustainability in Governance practices and strategy

The Group offers tailored financial products and services to its clients, enabling corporate and SMEs clients to invest in renewable energy,

waste reduction, and transit to sustainable operations, driving in this way a systemic change in industries. Furthermore, it supports retail

Customers through its activities and launching of new sustainability products, to be educated and empowered for making sustainable financial

decisions and have access to finance and affordable housing. Finally, it provides inclusive banking services to targeted underserved

communities, fostering financial inclusion.

In Greece, significant Group products and services include Green Retail and Small Business Banking Products. These products and services

support the sustainability-related goals “Support an environmentally sustainable economy” and “Foster healthy economies and societal

progress”.

To support sustainability in retail housing, the Bank offers a variety of Green Mortgage Loans for eligible activities in line with its Sustainable

Finance Framework and EU Taxonomy guidelines. Programs such as “EXOIKONOMO” is addressed to private property owners who wish to

improve the energy class of their homes.

The Group encourages also consumers to replace their vehicles and other devices with energy –efficient ones, by launching Alpha Green

Solutions. These Green consumer loans are offered in a highly competitive interest rate and flexible payment periods, promoting access to

green financing in everyday operations.

As far as small businesses are concerned, 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 and people’s health and wellbeing. To meet those purposes Alpha Bank offers solutions

such as “Alpha Photovoltaiko” for financing green energy and co- financed loans with EU, such as RRF Loans and “Invest EU”. Refer to [E1-3]

Actions and resources in relation to climate change policies for further details.

The Group has also developed the Sustainable Finance Framework (SFF). The Framework was developed in 2022 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 Group follows a multi-step assessment process at the Customer and transaction level.

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 ESG performance of the Customer 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 Group has put in place the SFF governance model

to ensure a robust decision-making process encompassing all relevant Divisions and lines of defense. 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 SDGs and to

demonstrate its credibility as a tool for capital allocation decisions.

The Framework identifies eligible activities for sustainable financing grouped into the following themes:

TABLE 5 ELIGIBLE ACTIVITIES FOR SUSTAINABLE FINANCING

Green eligible activities for sustainable financing

Social eligible activities for sustainable financing

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Energy Efficiency

Economic Inclusion

Renewable Energy

Access to Essential Services

Sustainable Transport

Affordable Basic Infrastructure

Resource efficiency and pollution control

Affordable Housing

Green Buildings

In 2024 the operationalization of the Sustainable Finance Framework (SFF) towards the support the Group’s commitment to sustainable lending

activities led to Euro 1.809 billion of new financing being classified in alignment with the Sustainable Finance Framework’s criteria.

Main challenges and critical solutions

The rapidly evolving EU regulatory landscape (i.e. Paris Agreement, and EU Taxonomy, Corporate Sustainability Reporting Directive -CSRD and

its transposition into the Greek law

, the Greek National Energy and Climate Plan (NECP)

, SFDR, ECB Disclosure Requirements) is putting

pressure to all industries to adapt and comply rigorously to the new requirements. Balancing economic growth objectives with climate risk

mitigation, decarbonizing operations and financed emissions to align with global net-zero targets and supporting clients in high-emission

industries to transit to sustainable business models without significant financial risk are key challenges for the financial sector. In addition,

promoting workplace DE&I as well as bridging the financial inclusion gap for underserved communities always remain challenging.

To navigate through these challenges, the dedicated Sustainability strategy has been developed by the Group to integrate further sustainability

into its core business model and core strategy for the short-term time horizon (2024-2026). The Sustainability strategy is aligned with the UN

Sustainable Development Goals (UN SDGs) and reflects the Bank’s approach to address Climate change, Biodiversity, and Circularity aspects,

related mainly to its portfolio, and own operations, to deliver positive outcomes for its Own Workforce, and Consumers and End-Users, as well

as to ensure responsible Business Conduct. The Sustainability strategy has been reinforced further with the adoption of a robust Sustainable

Finance Framework from the Bank, as a critical solution to enhance Green and Social Finance, such as renewable energy investments,

decarbonization of operations, Climate risk management and Financial Inclusion. The Sustainability strategy and the Sustainable Finance

Framework is reviewed and updated regularly, in line with the long-term goals set.

Furthermore, Alpha Bank S.A. continuously focuses on the improvement of internal processes and mechanisms for ensuring transparency in all

its sustainability disclosures.

Business model and value chain

The Group invests in its Employees, its network and its infrastructures to develop and place high-quality services and products on the market.

The Group balances its goals for economic growth with the needs of their Customers, the environment and society as a whole. This requires

the Group to consider ESG factors when making business decisions, by supporting a Net-Zero Economy, fostering Healthy Economies that

support Society and Safeguard Robust Governance, in line with its purpose for: “Enabling progress in life and business for a better tomorrow”.

TABLE 6 INPUTS AND EXPECTED AND ACHIEVED OUTPUTS AND OUTCOMES OF THE BUSINESS MODEL

Capitals

Inputs

Outputs

Current and expected benefits

Financial

Interest income, Fees and

commission, Investors’

funds.

Offering financial products and

services, supporting the markets

the Group operates in.

Enhanced access and Inclusion to

financial products and services to

its Customers and improved

customer experience

Increased trust to the Group’s

governance and ethical practices

for all stakeholders, including

investors, Employees, business

partners and suppliers and

Customers

Provision of a healthy inclusive

work environment, with

opportunities for career

development and promotion of

diversity to its Employees

Human

Skill set and development of

the workforce, tools and

processes.

Providing a healthy work

environment and investing in its

People’s development.

Manufactured

The infrastructure, supply

chain, and other external

resources.

Improving its Customers’

experience by investing in the

infrastructure.

Intellectual

Research and Development

(R&D) investments for our

products, services and

infrastructures.

Strengthening advisory and digital

services, to meet Customers’

changing needs.

Natural

Use of natural resources,

including energy for the

operation of the Group.

Constantly improving its

environmental footprint via our

products and operations.

Social

Cooperation with the

stakeholders to support

society and the local

economy.

Focusing on providing a safe and

inclusive work environment, the

financial inclusion of

underrepresented groups and the

On December 10, 2024, the Greek Parliament passed the bill (Law 5164/2024), which, among other things, incorporates into Greek law the European Directive

2022/2464 on the submission of sustainability reports by companies, also known as the Corporate Sustainability Reporting Directive – CSRD.

In August 2024, an Updated version of the NECP 2021-2030 was published and submitted to the European Commission in January 2025.

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provision of access to culture and

healthcare services.

Gathering, developing, and securing these inputs requires structured management approach evidenced by the Group robust governance

mechanisms, processes, and the utilization of resources to ensure accuracy, efficiency, and alignment with regulatory and stakeholder

expectations.

Through its business model the Group aims to create value for its stakeholders across the value chain, i.e. for:

• Upstream value chain, including Main suppliers, providing IT (hardware and software) and multiple other services (e.g. consultants,

legal advisory, marketing companies, etc.)

• Downstream value chain, including Customers, including corporate, SMEs, and retail Customers, Broader society, and communities

• Own operations, including Investors and Employees

[SBM-2] Interests and views of stakeholders

Key stakeholders and stakeholder engagement

The Group has identified four key stakeholder groups, with which engagement activities occur:

• Investors

• Customers

• Employees and Society

• Official and Regulatory Authorities

The communication is performed on annual, bi-annual, quarter, and ad hoc basis for all stakeholder groups mentioned above. During 2024

engagements (roadshows included) with 62 shareholders and other stakeholder groups took place (including Customers, rating agencies,

regulatory bodies). The following communications channels are used per stakeholder group:

TABLE 7 MEANS OF COMMUNICATION PER STAKEHOLDER GROUP

Stakeholder group

Communication method

Investors (including

Investment Analysts and

Advisors) and Bond

Holders, Reinsurers,

Trade Associations

Financial Statements, Quarterly Earnings Reports, Annual Reports, General Meetings, Investor

Briefings, Business Reviews, Sustainability and Climate Reports, One-to-one meetings,

Sustainability and Corporate Governance roadshows, Website, Press releases

Customers

Branch network, Relationship Managers, Customer Newsletters, Sustainability Statement with

Annual Reports, Customer Satisfaction, Surveys, Online Customer Portals, Customer service

center, Website, Social Media

Employees and Society

Internal Newsletters, Intranet, Town Hall Meetings, Training Sessions, Regular Feedback

Surveys, Annual Reports, Sustainability Reports, Community Engagement Reports, Press

Releases, Social Media Updates, CSR initiatives, NGO memberships, Volunteering, Sponsorships

Regulatory

Authorities

Regulatory Filings, Compliance Reports, Official Statements, Direct Communications

Through the engagement, the Group aims to understand the stakeholders’ needs and interests. A dedicated team is in place to analyze further

the feedback received for each group describe them and prioritize key actions. The outcome of this engagement enables the Group to assess

the effectiveness of its strategy, integrate further aspects into its business model and strategy and perform adjustments if necessary. In

particular, the engagement with its Employees and consumers and end-users is analyzed further in ESRS S1-Own workforce and S4- Consumers

and End Users.

Interests and views of key stakeholders in relationship with strategy and business model

The Group prioritizes transparency and collaboration in shaping the future of the sustainability strategy, and identification of its material

impacts, risks and opportunities. Stakeholder engagement in relation to the double materiality assessment process is analyzed in paragraph

[IRO-1] Description of the process to identify and assess material impacts, risks and opportunities. Furthermore, through stakeholder

engagement activities, interest and views of stakeholders are captured throughout the Group’s internal due diligence process are the

following:

Investors: Have shown up high interest to add Net-Zero Targets into their portfolios and increase the overall transparency. They also have high

expectations in diversity and inclusion and in the corporate governance.

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Regulatory Authorities: Following their appetite to comply with the National Laws and EU Regulations, they are also expecting to serve climate

change mitigation purpose.

Customers: The expectations focused mainly on access finance and especially Sustainable Finance and data privacy.

Employees: They are expecting higher standards in diversity and inclusion as well as health safety and wellbeing. They are also adding business

ethics into their views.

Society: Similarly to Employees, their expectations are mainly in diversity and inclusion, health safety and wellbeing, business ethics and

culture and heritage as well.

Engagements with Stakeholders have emphasized the importance of a clear and ambitious climate strategy, expecting the Group to take a

leadership role in advancing the transition to a low-carbon economy. Shareholders in particular, have called for sustainability to be fully

integrated into the Group’s strategic framework and remuneration policies, ensuring that climate considerations drive decision-making and

accountability across all levels. Additionally, there is a strong focus on transparency, with expectations for detailed reporting that tracks

measurable progress and demonstrates our impact in addressing climate challenges.

These expectations are taking into account and actively inform the Group’s strategy, business model and management of material impacts,

risks and opportunities. In response to the aforementioned expectations, the Group has taken concrete steps to deliver on its climate and ESG

ambitions.

As the first Greek bank to join the UN-convened Net-Zero Banking Alliance (NZBA), it is committed to achieving net-zero emissions across the

portfolios by 2050. To meet this goal, science-based targets for key high-emission sectors have been developed, applying the International

Energy Agency's (IEA) Net Zero by 2050 scenario. These targets enabled by a comprehensive sustainability strategy and the SFF.

Furthermore, significant resources are deployed in order to enhance financing renewable energy, circular economy initiatives, and clean

technologies, reinforcing the Group’s commitment to driving meaningful and measurable impact. The Group forms international alliances to

achieve its goals by being signatory of the international initiative of the UNEP FI, and joining the United Nations Global Compact in 2024,

underscoring the commitments to sustainable and responsible business practices and to support the transition to a sustainable economic

model. In addition, recognizing the profound impact of plastic pollution on our planet and future generations, Alpha Bank S.A. has also signed

the Finance Statement on Plastic Pollution introduced by the UNEP FI and other leading organizations.

Further evidencing to its stakeholders its commitment to management of impacts, risks and opportunities related to sustainability matters, the

Group is subject to continuous assessments by international indices and rating agencies (ESG ISS Quality Score, Climate Change CDP,

Bloomberg Gender Equality Index, and others). Alpha Bank S.A. received an “A” rating from MSCI ESG Ratings in 2024, while remained a

constituent of the FTSE4Good Emerging Index, which includes listed companies in emerging markets with a positive financial, environmental,

and social performance.

It is mentioned that no amendments to its business model and strategy occurred particularly in 2024, following the double materiality

assessment process. The strategy is aligned with the views and expectations of the Group stakeholders, however, the Group will consider the

possibility of taking further actions and plan in the future time horizon.

Updates from the stakeholder engagement output are being shared with the BoD members and its Committees, on a regular basis through

designated meetings. The BoD and its Committees are informed about the integration of the views and interests of the stakeholders on

sustainability-related impacts into the strategic planning process, and decision-making.

Recognizing its Employees as internal Stakeholders, the Group ensures effective communication with them by establishing the role of Human

Resources Business Partners, who serve as the first point of contact for Employees, and by facilitating visits by Human Resources Unit

Executives to Units and Branches of Alpha Bank. Employee feedback is instrumental in shaping the policies and practices and therefore the

Group utilizes internal campaigns, training, and inclusion in decision-making processes to ensure its Employees are empowered and aligned

with its sustainability goals. The Group is also committed to meaningful community engagement by investing in community development

projects, hosting forums to discuss community needs and integrate community feedback into its operational and sustainability strategies by

offering banking services that can support local environment and social goals.

As per the sources leveraged for the purposes of the Double Materiality Analysis, within 2025 a tool is expected to be launched for the

submission of Employee queries. Collective bargaining and trade union rights have been established under national and international

regulations. In addition, for the Group there four (4) active employee associations, and one of them is recognized as the responsible

representation body in labor-related bargaining with the Management. Lastly, an Employee Survey is also conducted twice per year.

For more information, please refer to ESRS S1- Own Workforce.

The Groupplaces significant emphasis on the views, interests and rights of Customers to ensure satisfaction and delivery of high-quality

products and services. The Digital Sales and Customer Experience is responsible for Quality Assurance and committed to achieving these

objectives. Beyond regular complaints and survey mechanisms, the Group is using feedback from trained Relationship Managers and

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leveraging data from its digital platforms to understand its Customers’ expectations, concerns and aspirations about its products and services.

For more information, please refer to ESRS S4- Consumers and End Users.

[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

Material impacts, risks and opportunities

The Group performed a double materiality assessment in 2024 for identifying its material impacts, risks and opportunities, taking into

consideration its business operations, and its value chain, drawing also from international best practices. The results of the Materiality Analysis

conducted in 2024 are presented in the following table:

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TABLE 8 MATERIALITY ANALYSIS RESULTS

MATERIAL Impacts, Risks and Opportunities (IROs)

VALUE CHAIN SEGMENTS AND AFFECTED

STAKEHOLDERS

IMPACT

Actual

Impact

Potential Impact

RISK

Current

Financial

Effect

Anticipated Financial

Effect

OPPORTUNITY

Current

Financial

Effect

Anticipated Financial

Effect

2025

2026-

2030

>2030

2025

2026-

2030

>2030

2025

2026-

2030

>2030

Negative impact

to Climate

Stability

√

Climate

Transition Risk

√

Climate Change

Mitigation

√

ACROSS THE VALUE CHAIN

Material negative impact to climate stability

though GHG emissions created indirectly by

the Group’s products/services and business

relationships, energy consumption in own

operations, and associated transition risks

and opportunities for the Group

Climate

Physical Risk

√

Climate Change

Adaptation

√

DOWNSTREAM

Climate physical risks and adaptation

opportunities through Group’s

products/services and business relationships

with Customers

Negative impact

to Biodiversity

and Ecosystems

√

Nature Related

Risk (Habitats

and Species)

√

Protection and

restoration of

biodiversity and

ecosystems

√

DOWNSTREAM

Material negative impact to Habitats (which

affects the status of Biodiversity and

Ecosystems), created indirectly though the

Group’s products/services and business

relationships, and associated transition risks

and opportunities for the Group

Negative impact

to Resource

Security

√

Transition to a

circular economy

√

DOWNSTREAM

Material negative impact to Resource Security

(which affects the development of a Circular

Economy), though the Group’s

products/services and business relationships

and transition opportunities for the Group

Contribution to

Livelihood of own

workforce

√

OWN OPERATIONS

Material positive impact to own workforce

through provision of secure employment,

social dialogue and freedom of association

Contribution to

Equality and

Justice of own

workforce

√

OWN OPERATIONS

Material positive impact to own workforce

through improvement of diversity

Staffing and

training issues

√

OWN OPERATIONS

Material inherent risk through insufficient/

inadequate training and skills development of

own workforce

Access to Housing

√

DOWNSTREAM

Material positive impact to Customers and

broader society/economy through the

Group’s products/services and business

relationships

Access to Finance

√

- Disclosure and

data protection

issues

√

DOWNSTREAM

Material inherent risk through data privacy

issues relating to Customers

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- Unsuitable

promotion

practices

(from

information

disclosure

perspective)

- Inadequate

disclosure of

product terms

√

DOWNSTREAM

Material inherent risk through incomplete/

incorrect information for Customers

- Product

suitability

issues

-Unsuitable

promotion/

sales practices

-Fiduciary

breaches

√

DOWNSTREAM

Material inherent risk through the Group’s

products/services and business relationships

with Customers

Contribution to

Healthy

Economies

√

DOWNSTREAM

Material positive impact to Customers and

broader society/economy through the

Group’s products/services and business

relationships

Contribution to

Transparency and

the Rule of Law

√

ACROSS THE VALUE CHAIN

Material positive impact to stakeholders

across the value chain through initiatives that

foster an ethical corporate culture

AML/CFT

√

ACROSS THE VALUE CHAIN

Material inherent risk through AML issues

across the value chain

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Impacts

Material impacts of the Group for the short-term, mid-term and long-term time horizon are concentrated to its own operations, and

downstream value chain affecting the natural environment and its Employees and Customers in all areas where the Group has main presence.

This is a result from the inherent nature of the Group’s products/services, business model as well as its strategy, which are related to its own

operations, portfolio and its business relationships.

More specifically, material impacts concentrated in the downstream value chain include:

• Climate Stability: Actual and potential negative impact to climate stability in the short-, mid- and long-term time horizon though

GHG emissions created mainly through the financing activities of sectors, contributing negatively to climate stability.

• Biodiversity and Ecosystems: Actual and potential negative impact to Habitats in the short-, mid- and long-term time horizon mainly

through the financing activities of sectors, contributing negatively to habitats, and the preservation of good condition of ecosystems.

• Resource use and circular economy: Actual and potential negative impact to Resource security in the short-, mid- and long-term

time horizon mainly through the financing activities of sectors, contributing negatively to the preservation of natural resources.

• Access to Housing: Actual and potential positive impact to accessibility to Housing in the short-, mid- and long-term time horizon

mainly through the offering of products/services to Customers, that support affordable housing.

• Access to Finance: Actual and potential positive impact to accessibility to Finance in the short-, mid- and long-term time horizon

mainly through the offering of products/services to Customers, that support the financial inclusion.

• Contribution to Healthy Economies: Actual and potential positive impact to Customers, including small and medium enterprises in

the short-, mid- and long-term time horizon mainly through the offering of products/services, that contribute to the creation of

healthy economies.

Furthermore, material impacts have also been identified in its own operations, due to the operation of its facilities and the utilization of

human capital. These material impacts include:

• Climate Stability: Actual and potential negative impact to climate stability in the short-, mid- and long-term time horizon due to the

energy consumption in its facilities, contributing negatively to climate stability.

• Contribution to Livelihood of own workforce: Actual and potential negative impact to its own workforce in the short-, mid- and

long-term time horizon through provision of secure employment, social dialogue and freedom of association.

• Contribution to Equality and Justice of own workforce: Potential positive impact to its own workforce in the mid- and long-term

time horizon through the Group’s plan for improvement of diversity.

• Contribution to Transparency and the Rule of Law: Actual and potential positive impact to all its stakeholders, in the short-, mid-

and long-term time horizon through initiatives that foster ethical corporate culture.

Regarding impacts related to the upstream activities, (supply chain and the natural environment), no material impacts have been identifying,

given their overall low materiality across the entire value chain and the Group’s activities and business model.

Risks

The Group has identified material risks to the following sustainability matters:

• Climate Transition and Physical risk: The Group has identified risks related to climate change as material in the medium- and long-

term time horizon.

o More specifically, in the medium- and long-term horizons the anticipated financial effect of climate change mitigation

(transition risk) is found to be material on an inherent level basis, considering the percentage of the Group’s exposures

towards sectors sensitive to transition risk over the total Group Assets. These risks impact both the creditworthiness of

counterparties and the recovery value of such exposures, e.g., non-compliance with climate-related regulations, increased

cost of raw materials / energy needs, failing to keep up with the pace of technological change, and shift in consumer

preferences. Taking into consideration the above, climate transition risks are primarily related to the downstream portfolio

of the Group.

o Additionally, the anticipated financial effect of climate change adaptation (physical risks) is also considered material in the

medium and long-term horizons on an inherent level basis. This consideration is due to the relatively high anticipated

occurrence of certain physical risk factors (e.g., wildfires in regional analyses and floods in sectoral analyses). These risks

impact affect clients’ ability to meet financial obligations and reduce the value of their properties or premises due to

physical risk events within sectors or geographies vulnerable to physical risk. For instance, there may be lower collateral

valuations in real estate portfolios as a result of increased flood risk. Taking into consideration the above, climate physical

risks are primarily related to the downstream portfolio of the Group.

• Nature Related Risk (Habitats and Species): The Group has identified risks related to biodiversity and ecosystems as material in the

long term, considering the significant impact of biodiversity-related risks on the creditworthiness of its obligors, leading to credit

losses for the Bank. For example, companies unable to comply with biodiversity-related regulations, now and more increasingly in

the future, may face fines, litigation, or operational restrictions, reducing their financial stability, while companies reliant on

ecosystem services, such as agriculture, forestry, fisheries, etc. may face reduced productivity or higher operational costs due to

biodiversity loss, affecting their ability to meet financial obligations. Biodiversity and Ecosystems risks are primarily related to the

downstream portfolio of the Bank.

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• Staffing and training issues: The anticipated financial effect from risks related to the Bank’s own workforce, particularly inadequate

“training and skills development” is assessed as material in the short-, medium-, and long-term. Such risks can reduce productivity

and cause operational disruptions, as Employees may lack the skills needed to adapt to evolving technologies and processes.

Furthermore, insufficient training and development may decrease employee engagement, heighten dissatisfaction, and drive higher

turnover rates. Similarly, prolonged working hours can lead to employee burnout, exacerbating dissatisfaction, reducing productivity,

and further contributing to higher attrition within the Bank. Own workforce risks are related to the Bank’s own operations.

• Disclosure and data protection issues, Fiduciary breaches, Unsuitable promotion practices (from information disclosure

perspective), Inadequate disclosure of product terms, Product suitability issues, Unsuitable promotion/ sales practices: The

anticipated financial effect from risks related to consumers and end-users, in particular “Privacy”, “Access to quality information”

and “Responsible marketing practices” is considered material in the short-, medium- and long-term. Although the financial impact of

these risks is not quantified directly in monetary terms, the rapid technological progress and development in cybersecurity, which

can lead to data breaches, highlights the importance of closely monitoring and adapting to the evolving environment. Failure to do

so could expose the Bank to substantial financial losses due to fines, legal fees, and compensation costs, as well as damage to the

Bank's reputation. In addition, inadequate access to quality information and irresponsible marketing practices can erode consumer

trust and also lead to regulatory penalties, further impacting the Bank's financial stability. Although consumers and end-users’ risks

affect the Bank’s clients, the root cause for risk manifestation lies on the Bank’s own operations (most typically due to potential

failures of internal controls established to prevent such risks).

• Corruption and bribery: The anticipated financial effect of risks related to corruption and bribery is assessed as material in the short-

, medium-, and long-term due to possible reputational damage and material penalties imposed by regulatory authorities. This

outcome is driven by the AML/CFT risks associated with this topic, which have a financial effect deemed material, as these risks

directly impact the institution’s financial stability, reputation, and regulatory compliance. Failure to prevent financial crimes like

money laundering and terrorist financing can result in significant financial penalties and legal consequences. Additionally, it can

damage the Bank’s reputation, erode customer trust, and hinder the ability to attract and retain clients, ultimately affecting long-

term growth and profitability. Corruption and bribery risks are material through AML issues across the value chain.

Opportunities

The Group has identified material opportunities to the following ESRS topics:

• Climate Change: The Group identified opportunities related to climate change mitigation as material in the current year as well as in

the short-, medium- and long-term while climate change adaptation is considered material in the long-term. EU Taxonomy aligned

loans with a substantial contribution to the Climate Change Mitigation and Climate Change Adaptation environmental objectives,

sustainability-linked loans and other relevant sustainable loans based on the Group’s SFF are considered.

• Biodiversity and Ecosystems/ Circular Economy: The Group identified opportunities related to biodiversity and ecosystems/ circular

economy as material in the long-term. EU Taxonomy aligned loans with a substantial contribution to the protection and restoration

of biodiversity and ecosystems and transition to a circular economy environmental objectives and other relevant sustainable loans

based on the Group’s SFF are considered.

The opportunities described above (through sustainable financings) are primarily related to the downstream value chain of the Group.

Connection of material impacts with strategy and business model

The Group’s ESG strategy focuses on its impact generation, addressing both the direct and indirect effects of its operations and financial

activities on various Stakeholders and the environment. Amidst global efforts to address challenges, the Group aligns its objectives with the

Sustainable Development Goals (SDGs), aiming for a lower-carbon future and leveraging digital innovations to empower Customers. Through

concrete targets, the Group demonstrates its commitment to sustainability.

The Group continued to implement the ESG Workplan, which aims to integrate sustainability and climate risk criteria in the decision-making

processes, including strategy, risk management, lending, and operations. This resulted in increased portfolio of green loans and investments,

supporting projects that contribute to renewable energy and sustainable economy.

To this end, the Group developed the SFF in 2022, operationalizing it in 2023. The Framework was developed 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 Group follows a multi-step assessment process at the Customer and transaction level.

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 ESG performance of the Customer 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 Group has put in place the SFF governance model to ensure a robust decision-making process encompassing all relevant Divisions and lines

of defense. 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 SDGs and to demonstrate its credibility as a tool for capital allocation decisions.

The Group recognizes that its impacts on the natural environment and people are closely and significantly related to its financial products and

services. Alpha Services and Holdings Group offers access to financial services through a wide range of high-quality financial products and

services, including retail banking, banking for medium-size and large enterprises, asset management and private banking, insurance products,

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investment banking, brokerage and real estate Management. The Group’s most significant entity, Alpha Bank, a leading financial institution in

Southeastern Europe, has the ambition not only to cause no significant harm to the environment and society via its activities but also to

contribute to the transition of the Greek economy to a sustainable model, through the development of sustainable finance and associated

products to support investments in green projects.

The downstream segment of the value chain (portfolio) is particularly significant due to the inherently higher materiality of impacts created

through the Group’s products and services offered to its clients (lending portfolios) and through its investment activities (own investments

portfolio). Nevertheless, material impacts are assessed across the entire value chain. Refer to [SBM-3] Material impacts, risks and

opportunities and their interaction with strategy and business model for more information.

Current financial effects of material risks

Regarding the current financial effects of the material risks the Group has identified the following:

i. Climate Change: For 2024, the operational risk losses related to climate risk are very limited below Euro 1 million, which are

considered not material.

ii. Biodiversity and Ecosystems: For 2024, there are no operational risk losses related to biodiversity and ecosystems-related risks.

Therefore, the current financial effect from biodiversity and ecosystems -related risks is considered not material.

iii. Own Workforce: For 2024, the operational risk losses related to employee practices are very limited below Euro 1 million. Therefore,

the current financial effect is considered not material.

iv. Consumers and end-users: For 2024, the operational risk losses related to data privacy issues, inappropriate marketing practices and

inadequate access to quality information are very limited below Euro 2.5 million. Therefore, the current financial effect is considered

not material.

v. Business conduct: For 2024, the operational risk losses related to corruption and bribery and AML/CFT-related issues are very limited

below Euro 1 million. Therefore, the current financial effect is considered not material.

Since climate change and biodiversity and ecosystems topics are not material in the short-term, no material adjustments within the next

annual reporting period to the carrying amounts of assets and liabilities reported in the related financial statements are expected. Social and

governance risks are effectively managed and mitigated, resulting in limited residual risk and thus no material adjustments in the Bank’s

balance sheet or PandL are expected.

Current financial effects of material opportunities

Regarding the current financial effects of the material opportunities the Group has identified the following:

vi. Climate Change: For 2024, the Bank has identified climate change mitigation-related opportunities above Euro 2 billion (in terms of

green (climate change mitigation related) loans balances), which are considered material based on the applicable materiality

threshold of Euro 1 billion. For climate change adaptation, the Group has not identified any relevant opportunities for 2024 and

therefore they are considered not material.

vii. Biodiversity and Ecosystems/ Circular economy: For 2024, the Group has not identified biodiversity and ecosystems and circular

economy related opportunities and therefore they are considered not material.

The Group anticipates significant growth of sustainable financings over the next year, which is expected to result in substantial adjustments to

the gross carrying amounts of assets reflected in the financial statements for the next annual reporting period.

Anticipated financial effects of material risks

• Climate Change: The Group, in order to estimate the anticipated financial effect for climate risk, it examines the anticipated financial

effect separately for transition and physical risks.

More specifically, to evaluate the anticipated financial effect for transition risk, the Group leverages on the outcome of the

materiality assessment performed that takes into consideration the following dimensions:

o The identification of the sensitive to transition risk perimeter by taking into consideration several factors such as the CPRS

perimeter, the NZBA and LTS for Greece for 2050, emission intensities and forward-looking PDs, as well as exclusion of

sustainable loans related to climate change mitigation objective.

o The transition risk score derived from the qualitative materiality assessment for transition risk (climate change mitigation)

sub-types (market, technology, reputation, policy and legal) as proposed by the TCFD, that identifies the climate-related

transition risks that materially affect each sector lying within the transition risk sensitive perimeter and under different

time horizons. This score is considered as a proxy for the likelihood of occurrence of an anticipated financial effect for the

Group.

o After recognizing the sectors lying within the sensitive perimeter that have High, Medium, or Low likelihood of occurrence,

the Group proceeded with the calculation of the percentage of the Group’s exposures within the Sensitive perimeter over

Total Group Assets categorized under High, Medium and Low likelihood of occurrence, across the different time horizons

and set thresholds for materiality.

Climate change mitigation is identified as a material sub-topic in the medium and long-term, since the percentage of the exposures over the

Group Total Assets corresponding to High and Medium likelihood of occurrence categories exceed the respective thresholds. The following

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table gives an overview of the Group’s exposures per likelihood of occurrence score. More details regarding the anticipated financial effect

from physical risk are presented under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

TABLE 9 EXPOSURES PER LIKELIHOOD OF OCCURRENCE

Anticipated Financial Effect – Transition Risk (Exposures in Euro million)

Likelihood of

Occurrence

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

High

5,039

Medium

847

4,670

Low

9,113

251

In addition, to evaluate the anticipated financial effect for physical risk, the Group leverages on the outcome of the materiality assessment

performed that takes into consideration the following dimensions:

o The vulnerability assessment outcome per sector and region. The Group has laid down a methodology based on sensitivity

and exposure analysis (when separately assessed) to derive vulnerability to physical risk factors. Vulnerability analysis is

performed to identify potential significant hazards per subsector covered by the analysis for Business portfolio, as well as

across the different geographic regions where real estate properties used as collateral extend. The vulnerability

assessment outcome is considered as a proxy for the likelihood of occurrence of an anticipated financial effect for the

Group.

o After recognizing the sectors and regions that have High, Medium, or Low likelihood of occurrence, the Group proceeded

with the calculation of the percentage of the Group’s exposures over Total Group Assets categorized under High, Medium

and Low likelihood of occurrence across the different time horizons and set thresholds for materiality (the materiality

threshold has been set on Group’s 'exposures over Group Total Assets’ under High Likelihood of Occurrence). The following

table gives an overview of the Group’s exposures per likelihood of occurrence score for Both Chronic and Acute physical

risks. It is noted that the Group also assesses the likelihood of occurrence of Chronic and Acute risks separately.

Climate change adaptation is identified as a material topic in the medium and long-term considering that for some physical risk factors (e.g.,

wildfire in case of the regional analysis and floods in case of sectoral analysis) the anticipated occurrence is relatively high. The following table

gives an overview of the Group’s exposures per likelihood of occurrence score. More details regarding the anticipated financial effect from

physical risk are presented under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

TABLE 10 EXPOSURES PER LIKELIHOOD OF OCCURRENCE SCORE FOR BOTH CHRONIC AND ACUTE PHYSICAL RISKS

Anticipated Financial Effect – Physical Risk – Both Chronic and Acute

(Exposures in Euro million)

Likelihood of Occurrence

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

High

281

1,175

1,251

Medium

16,750

18,373

13,168

Low

3,416

899

6,028

• Biodiversity and Ecosystems: The Group has utilized the UNEP FI Portfolio Impact Analysis tool in order to examine the materiality of

the anticipated financial effect for nature-related risks, assessing the negative impact of the environmental pillar in six different

areas: Waterbodies, Air, Soil, Resource Intensity, Waste and Biodiversity (the latter consisting of the Species and Habitat categories)

within its portfolio per sector. The assessment considered the relevant impact topics and “key sectors”, which are the sectors that

have a direct impact on these environmental areas, as defined by the UNEP FI tool. Moreover, for sectors with a key negative impact

on each environmental topic, a risk assessment was performed using a literature review to estimate the likelihood of occurrence of

the respective nature-related risks, covering short-, medium-, and long-term horizons. This assessment was carried out within the

context of transitioning to stricter regulatory requirements. To evaluate the anticipated magnitude of financial effect for the

Biodiversity and Ecosystems-related ESRS topic, the Group calculated the proportion of exposures assigned to each likelihood

category (high, medium, low) as a percentage of the Group's Total Assets.

Biodiversity and Ecosystems is identified as a material topic in the long-term since the percentage of the exposures over the Group Total

Assets corresponding to High and Medium likelihood of occurrence categories exceed the respective thresholds. The following table gives an

overview of the Group’s exposures per likelihood of occurrence score. More details regarding the anticipated financial effect from biodiversity

and ecosystems related risk are presented under [IRO-1] Description of the process to identify and assess material impacts, risks and

opportunities.

TABLE 11 ANTICIPATED FINANCIAL EFFECT – BIODIVERSITY AND ECOSYSTEMS RISK

Anticipated Financial Effect – Biodiversity and Ecosystems Risk (Exposures in Euro million)

Likelihood of Occurrence

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

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High

1,367

8,125

Medium

7,470

2,077

Low

10,255

1,418

• Social Risks: To evaluate the anticipated financial effect of social risks, the Group conducted a mapping of the respective ESRS sub-

topics with the risk types identified within the Operational Risk Taxonomy framework and the corresponding inherent risk

assessment outcomes derived from the RCSA.

o Own Workforce: The anticipated financial effect from risks related to the Group’s own workforce, in particular

“inadequate training” and “skills development”, are assessed as material in the short-, medium- and long-term. Although

these risks are challenging to quantify, they are considered material due to their potential financial effects to the Group.

They can adversely affect the Group’s human capital by diminishing operational efficiency and contributing to elevated

attrition rates stemming from employee dissatisfaction.

o Consumers and end-users: The anticipated financial effect from risks related to consumers and end-users, in particular

“Privacy”, “Access to quality information” and “Responsible marketing practices” is considered material in the short-,

medium- and long-term. Although the financial effect of these risks is not quantified directly in monetary terms, taking

into consideration rapid technological progress and development in the area of cybersecurity which can lead to data

breaches, highlight the importance of closely monitoring and adapting to the evolving environment otherwise it could be

exposed to substantial financial losses due to fines, legal fees, and compensation costs, as well as reputational damage.

• Governance Risks: To evaluate the anticipated financial effect of governance risks, the Group conducted a mapping of the respective

ESRS sub-topics with the risk types identified within the Compliance Risk Assessment and the corresponding inherent risk assessment

outcomes.

o Corruption and bribery: The anticipated financial effect of risks related to corruption and bribery is assessed as material in

the short-, medium-, and long-term due to possible reputational damage and material penalties imposed by regulatory

authorities. This outcome is driven by the AML/CFT risks associated with this topic, which are challenging to quantify, but

they are considered material since they directly impact the institution’s financial stability, reputation, and regulatory

compliance.

Anticipated financial effects of material opportunities

• Climate change: For the short-term horizon the Group considers climate change mitigation related opportunities material, taking

into consideration the fact that sustainable financings towards climate change mitigation are, already, material (exceeding the

respective threshold) and the growth of sustainable financings in the following year, that according to Business Plan is estimated at c.

Euro 939 million, mainly stemming from Energy and Real Estate sectors in the Business portfolio (with some small amounts being

also located in Accommodation and Travel Agencies, Agriculture, Chemicals and Pharmaceuticals, Construction, Wholesale Trade and

Other sectors), while a small amount comes from Households (c. Euro 80 million). For the medium- and long-term horizons, although

the financial effect of these opportunities is not easily quantified directly in monetary terms, the Group considers climate change

mitigation material in both horizons and climate change adaptation in the long-term based on the Group's expectations for the

growth of climate-related sustainable financings in the future.

• Biodiversity and Ecosystems/ Circular Economy: Although the financial effect of these opportunities is not easily quantified directly

in monetary terms, the Group considers biodiversity and ecosystems and circular economy related opportunities material in the

long-term horizon based on the Group's expectations for those sustainable financings in the future.

Resilience of strategy and business model towards addressing impacts risks and advancing opportunities

Group's strategy and business model demonstrate significant resilience in relation to climate change through a well-structured approach to

managing climate impacts and risks. The Group's comprehensive framework integrates these risks into its overall risk management processes,

addressing both physical risks, such as those arising from extreme weather events, and transition risks associated with the shift to a low-

carbon economy. A detailed materiality assessment has been conducted to evaluate the potential impacts of climate risks on financial

performance, operations, and key stakeholders. This approach aligns closely with global objectives, including the Paris Agreement, and is

supported by the Group’s commitment to achieving net-zero greenhouse gas emissions by 2050 through science-based targets.

Climate Change risks

More specifically, Alpha Bank’s resilience analysis is based on the following factors in order to identify sectors sensitive to transition risk:

i) Climate Policy Relevant Sectors (CPRS) perimeter,

ii) Net Zero Banking Alliance (NZBA) and Long-Term Strategy for Greece for 2050 (LTS),

iii) The dimensions of emission intensities at sector level and forward-looking Probability of Defaults (PDs) based on the ECB short-

term disorderly transition scenario,

iv) Exclusion of:

a. RES loans,

b. dedicated-purpose sustainable loans that are aligned with EU Taxonomy (and substantially contribute to Climate Change

Mitigation (CCM) objective), and

c. other loans that are sustainable according to the Bank's SFF, provided that they are linked to and affect Climate Change

Mitigation (CCM) objective.

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To further examine the impact under different time horizons, the Group has conducted a qualitative materiality assessment for transition risk

sub-types (market, technology, reputation, policy and legal), as proposed by the TCFD. This analysis identifies the climate-related transition

risks that materially affect each sector lying within the transition risk sensitive perimeter and under different time horizons.

Regarding physical risk, the Group performs a materiality assessment based on IPCC AR5 RCP 8.5 for 2025, 2030 and 2050 horizons. More

specifically, the Group utilizes the vulnerability analysis to identify potential significant hazards per subsector as well as across the different

geographic regions where real estate properties used as collateral extend.

Biodiversity and ecosystems risks

The Group has performed a resilience analysis to assess biodiversity and ecosystem risks within its portfolio. The Group utilizes the UNEP FI

Portfolio Impact Analysis Tool to examine the key negative impact of sectors (at NACE code level) of its Non-Financial Corporate portfolio and a

literature review to estimate the likelihood of occurrence of the respective nature-related risks, covering short-, medium-, and long-term

horizons.

The analysis and management of biodiversity and ecosystem-related risks has been improved by conducting dependency analyses using the

ENCORE tool.

For further information related to the materiality assessment methodology for nature-related risks under [IRO-1] Description of the process to

identify and assess material impacts, risks and opportunities.

Changes to the material impacts, risks and opportunities compared to the previous reporting period

Since 2024 is the first year the Sustainability Statement under the ESRS, there are no prior reporting periods to reference.

Specification of impacts, risks and opportunities covered by ESRS Disclosure Requirements

Material impacts, risks and opportunities related to Climate stability, Biodiversity and Circularity, are covered by ESRS E1 Climate Change, ESRS

E4 Biodiversity and ecosystems and E5 Resource Use and Circular Economy.

Moreover, material impacts and risks related to Livelihood, Equality and Justice of Employees, are covered by ESRS S1 Own Workforce.

Material impacts, and risks related to Access to Housing and Finance of Customers, are covered by ESRS S4 Consumers and end-users.

However, the impact related to Contribution to Healthy Economies, is not covered by an ESRS topical standard, therefore, additional entity-

specific disclosures have been included.

Finally, material impacts, and risks related to the Contribution to Transparency and the Rule of Law are covered by ESRS G1 Business Conduct.

[IRO-1] Description of the process to identify and assess material impacts, risks and opportunities

The Group’s double materiality assessment conducted in 2024 aimed to encompass both the impact and financial materiality perspectives,

along with the interconnections between them, in accordance with the double materiality assessment process of the European Sustainability

Reporting Standards (ESRS).

The methodology followed aims to capture impacts across the entire Value Chain (VC) by examining each segment separately. For impact

materiality, assumptions made concerned the perimeter of the Group’s subsidiaries for the double materiality assessment and the utilization

of Alpha Bank S.A. suppliers’ data as representative of the Group. Regarding downstream value chain, the offering of products and services for

the short-term, mid-term and long-term time horizon, static exposures and mix of portfolio.

For financial materiality, the methodology followed concerned Alpha Bank S.A., considering that it is the largest subsidiary of the Group in both

terms of portfolio size and operations.

Process to identify, assess, prioritize and monitor impacts informed by due diligence

Impact Materiality

Phase 1: Design the Impact Materiality Assessment Approach

Understand the Context (Internal and External)

In this phase, an overview of the Bank’s activities and business relationships has been developed, along with the context in which these occur

and identifies its key affected stakeholders:

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a) Entity perimeter definition:

The Group conducted a scoping exercise as a basis for identifying entities to include in the perimeter of the impact materiality

assessment. 112 “micro” entities were excluded (relative business activity with the other Group entities, very small size and

negligible impact), as well as due to the fact that no activities of different nature have been identified.

Among the rest 26 entities of the Group, 5 holding and special purpose entities were excluded from the subsequent analysis; the

impacts of holding and special purpose entities were captured through the activities of other entities’ activities, resulting in a

perimeter of 21 entities.

b) Business activities and relationships/ affected stakeholders' categorization (value chain mapping):

Own Operations:

Activity mapping was performed based on the economic activity description, sector (NACE), and location of operations. The impact

materiality process focused on these 21 entities operating in Greece, Cyprus, Romania, UK and performing the following Group

activities:

Asset Management, Banks, Financing companies, Insurance, Investment Banking, Provision of Information technology services and

consulting, and Real Estate and Hotel.

Downstream Value Chain:

For downstream activities, the results of the most recent PRB portfolio analysis for Alpha Bank S.A. and Alpha Bank Cyprus were

leveraged. For the rest entities, data were requested and collected related to their products and services (where applicable). Alpha

Supporting Services S.A. and Alpha Finance A.E.P.E.Y. were excluded, due to the nature of their activities as they already trigger

impacts at own operations (no downstream/portfolio relevance). It is also noted that, that Alpha Real Estate Services L.L.C. and Alpha

International Holdings M.S.A. could not provide data, however due to similar activities and locations of operation to the other Group

entities in scope, it was reasonably to assume that no additional impacts could be created.

Upstream Value Chain:

The mapping for upstream activities included collecting information for major suppliers based on spending for purchased goods and

services per NACE of suppliers. Alpha Bank S.A. major supply categories were identified, and confirmation was provided by the other

Group entities on similar supply chain activities. It is noted that due to unavailability of data, certain Group entities could not provide

data. Nevertheless, due to similar activities and locations of operation to the other Group entities in scope, it was reasonable to

assume that no additional impacts could be created.

The understanding of business relationships and affected stakeholders was achieved through the review on existing stakeholder mapping.

Through this review, the Bank has identified its key affected stakeholders.

c) Other contextual information: research was conducted on country/sector level sustainability-related priorities and Alpha Bank S.A.'s

external sustainability commitments. The aforementioned contextual information has been utilized as sources for potential impacts,

risks and opportunities in the future time horizons (please refer to Phases 2, 3).

Time horizons were selected for actual impacts (2024) and potential impacts (short term: 2025, mid-term: 2026-2030, long-term: >2030).

Stakeholders were engaged effectively in the subsequent phases of the double materiality assessment, through leveraging existing stakeholder

engagement output in 2024 and performing dedicated meetings with stakeholder representatives.

Phase 2: Identify Actual and Potential Impacts

a) Impact identification - actual impacts

Own operations:

The basis for the identification of material impacts created by the Group’s own operations has been the Group’s prior year material

impacts (2023

) and impacts emerging from ESG Standards Review and Peer Review. Specifically, to ensure completeness, the Bank

further examined whether the identified impacts accurately reflect the actual impacts created to people and the environment

Downstream: Impacts have been identified by using UNEP FI Portfolio impact Analysis Tools (i.e. Investment Portfolio Impact

Analysis Tool, Consumer Banking and Institutional Banking Identification Modules and Real Estate Impact Analysis Tool, for the

Source: Alpha Services and Holdings Sustainability Report 2023

Main Group activities include Asset Management, Banks, Financing companies, Insurance, Investment Banking, Provision of Information technology services

and consulting, Real Estate and Hotel.

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respective portfolios) and specifically by using sector-impact associations (as per the UNEP FI Sector-Impact Map), in accordance with

the UNEP FI Impact Protocol.

Upstream: Similarly to the downstream segment, impact identification has been based on the implementation of the UNEP FI Sector-

Impact Map. Specifically, to capture impacts generated in the upstream segment of the VC, the Sector-Impact Map has been utilized

for selected NACE sectors, which were determined based on the Bank’s supplier spending.

b) Impact identification - potential impacts

Potential impacts have been identified through inherent analysis of shifts and transitions in the materiality of sustainability impact

topics across different time horizons. This analysis is based on desktop research on policies, regulations, sectoral trends,

macroeconomic conditions of sustainability themes, academic and scientific evidence, and other relevant sources. The analysis

focused on how the main sectors of the Group’s portfolio prioritize the identified actual impacts in future time horizons. The results

served as a proxy for the identification of the material impacts for the Group. Furthermore, regarding downstream impacts, portfolio

mix, and exposures were assumed to be the same for the future time horizons.

Phases 3 and 4: Assess and Prioritize Impacts

a) Impact assessment and prioritization - actual impacts

b) Own operations: For own operations, an overall “severity” scoring for negative impacts, and an overall “significance” scoring for

positive impacts, based on the results of the identification phase. The impacts have been evaluated and verified through consultation

and stakeholder engagement with HR and Compliance, and Governance and Sustainability- ESG Strategy.

Downstream and upstream: The materiality of actual impacts connected to the Group through its products and services and

suppliers, for downstream and upstream, respectively, has been assessed based on significance (positive) and severity (negative).

The significance (or severity for negative) of an impact has been evaluated from the viewpoint of the affected people or the

environment. To this end, it has been determined by the characteristics (criteria) of scope, scale and irremediability (for negative

impacts only), taking into consideration monetary figures related to portfolio and supply chain.

Subsequently, based on a top-down approach, significance and severity have been aggregated at the Group level, per impact and

have been prioritized based on quantitative thresholds

c) Impact assessment and prioritization - potential impacts

Regarding potential impacts, an inherent analysis (without considering mitigation actions or changes in the current portfolio) of

sustainability impact topics was conducted. The scoring methodology was applied as an aggregated conclusion of materiality per

impact topic across three-time horizons. Additionally, the likelihood criterion was based on desktop research and has been

incorporated into the analysis. It is noted that for own operations, the potential impacts have been evaluated and verified through

consultation and stakeholder engagement with HR and Compliance, and Governance and Sustainability- ESG Strategy.

Generally, the whole impact materiality assessment process of the Group, informed by the due diligence process, included consultation with

subject matter experts, as an additional source for impact identification, assessment and prioritization.

Phase 5: Report on the Process and Outcome

To map the material UNEP FI topics with the respective ESRS topics, sub-topics and sub-sub topics, the UNEP FI’s Topics Mapping from the

UNEP FI Interoperability Guide has been leveraged.

The reporting phase included the preparation of narratives for the description of the processes to identify and assess material impacts for

inclusion in the sustainability statement, along with the respective outcomes.

Process to identify, assess, prioritize and monitor risks and opportunities that have financial effects

Risks

Current Financial Effect

In order to assess the magnitude of the current financial effect of its material risks, the Bank has evaluated if any P and L impacts (operational

risk losses) have been recognized during the current financial year.

As per IG 1, par. 27, “ESRS 1 sets criteria for the materiality assessment but not specific thresholds to determine when a matter or information is material or

not. Therefore, the assessment requires the exercise of judgement. The undertaking needs to set thresholds based on ESRS 1 criteria as well as its own

specific facts and circumstances.”

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Anticipated Financial Effect

Climate Change (ESRS E1):

The key dimensions considered by the Bank in order to assess the anticipated financial effect of climate change mitigation are described in

[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model.

Further information related to the materiality assessment methodology for climate risks is provided under [IRO-1] Description of the process

to identify and assess material impacts, risks and opportunities.

Nature-Related risks (ESRS E2-E3):

As already mentioned in [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model and above,

the Bank in order to assess the materiality assessment of nature-related risks and identify sectors with key negative impact leverages on UNEP

FI Portfolio Impact Analysis Tool, while for sectors with a key negative impact, a risk assessment was performed using a literature review.

As per the financial assessment materiality that ESRS E2 (Pollution) and ESRS E3 (Water and Marine Resources) are not material.

Further information related to the materiality assessment methodology for nature-related risks, is provided under [IRO-1] Description of the

process to identify and assess material impacts, risks and opportunities.

Social Risks related to workers in the value chain and affected communities (ESRS S2-S3): The financial assessment materiality concludes that

ESRS S2 (Workers in the Value Chain) and ESRS S3 (Affected Communities) are not material. The impact analysis conducted did not identify any

significant impacts related to these topics, nor does the Bank have dependencies on such aspects. Additionally, the Group’s policies and

processes ensure compliance with minimum regulatory requirements.

Social Risks related to Own workforce and Consumers and end-users (ESRS S1 and S4):

• As described under [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business

model, the Bank proceeded with a mapping of the respective ESRS sub-topics with the risk types identified within the

Operational Risk Taxonomy framework and the corresponding inherent risk assessment outcomes derived from the RCSA,

to evaluate the anticipated financial effect of social risks,

• ESRS sub-sub-topics that are assessed as having a High or Medium High inherent risk are deemed material. For ESRS sub-

sub-topics and associated operational risks that encompass multiple RCSA risk events, a conservative approach has been

utilized, taking into account the highest observed risk assessment outcome. It is noted that the inherent risk assessment

considers which is the impact for the Bank in case the risk is manifested within the next year (short-term) without

additional mitigation actions going forward. It is assumed that the same conclusions are, also, applicable in the medium-

and long-term horizons. Qualitative overlays have, also, been performed as applicable.

Governance Risks:

• As described under [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model,

the Group proceeded with a mapping of the respective ESRS sub-topics with the risk types identified within the Compliance Risk

Assessment and the corresponding inherent risk assessment outcomes, to evaluate the anticipated financial effect of

governance risks.

• ESRS sub-sub-topics that are assessed as having a High or Medium High inherent risk are deemed material.

Further information related to the double materiality assessment methodology for Governance risks, is provided under [IRO-1]

Description of the process to identify and assess material impacts, risks and opportunities.

Alpha Services and Holdings Group acknowledges the importance of improving disclosures for its subsidiaries in other countries. As disclosed

in the last Sustainability Report (2023), the Group aims to standardize its materiality assessments and enhance transparency across all regions

of operation. Therefore, for entities or subsidiaries not explicitly covered in the present Sustainability Statement, Alpha Bank confirms that

efforts are underway to extend these frameworks and assessments. Reasons for this stem from varying stages of implementation of

standardized materiality assessments and data collection processes across regions such as local regulatory requirements, operational

structures, and resource availability.

Opportunities

Current Financial Effect

In order to assess the magnitude of the current financial effect, the Bank has evaluated if any material ESG related opportunities (EU

Taxonomy aligned and other sustainable financings according to the Bank’s SFF) have been recognized during the current financial year.

Anticipated Financial Effect

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In the short-term horizon, the Group identifies material opportunities by leveraging the projected growth of sustainable financing, as outlined

in its SFF and reflected in the first year of its Business Plan. For the medium- and long-term horizons, the materiality assessment is based on

the Group’s expectations for the growth of sustainable financing in the future. This is supported by the anticipated increase in relevant risks

where applicable (e.g., physical risks are expected to intensify over time, leading to a rise in adaptation-related financings).

Regarding the monitoring process, the Group integrated climate risks into its overall risk management framework. More specifically, the

Group has already incorporated in its Risk Appetite Framework (RAF) a set of quantitative indicators and qualitative commitments regarding

climate risks. In terms of quantitative indicators, the Bank has defined several C&E indicators designed to improve the sustainability of the

portfolio and mitigate potential exposure to risk and are incorporated in Risk Appetite Framework as supporting elements. Additionally, limits

have been established in part of the existing C&E indicators. The indicators cover the area of business planning and green financing, collateral

vulnerability to physical and transition risk, financial activity vulnerability to physical risk and sustainable investing. In 2024 the Group has

updated its Risk Inventory to provide a comprehensive overview of the enhancements and progress achieved in climate-related risks in the its

Risk Registry, by incorporating additional limits.

Description of how connections of impacts and dependencies with risks and opportunities that may arise from those impacts and

dependencies have been considered

The relationship between risks/opportunities and impacts/dependencies is not considered simple/ one-dimensional. Instead, risks and

opportunities may arise from a combination of underlying factors, including impacts, dependencies, and other external factors such as

regulatory requirements and the associated obligations of the Group .

Generally, risks and opportunities related to climate change mitigation and biodiversity and ecosystems are primarily linked to impacts in the

downstream portfolio and the transition efforts of clients aimed at minimizing these negative effects. In contrast, risks associated with climate

change adaptation are predominantly tied to dependencies and damages from extreme physical events. The training and skills development

related risks are primarily linked to the Bank's dependency on human capital. Privacy risks are mainly connected with external factors,

including regulatory changes such as GDPR and cyber threats, which can undermine trust and reputation and potentially result in significant

financial losses. Risks related to access to quality information and responsible marketing practices are primarily linked to external factors such

as evolving regulatory requirements, industry standards, and societal expectations. Failure to provide accurate, transparent, and accessible

information or to adhere to responsible marketing practices could damage the Group’s reputation, erode customer trust, and potentially result

in regulatory penalties or financial losses. Business conduct-related risks are linked to both impacts and dependencies and are strongly

influenced by strict compliance requirements. Failure to meet these obligations adequately could result in significant financial impacts for the

Group.

Decision-making process and the related internal control procedures

The process was based on existing methodologies and capabilities, such as the ESG Risk Materiality Assessment for financial materiality, as well

as widely adopted tools for impact materiality like the UNEP FI Portfolio Impact Analysis Tool. Various alternative methodological assumptions

were carefully assessed and discussed to conclude to the more appropriate methodology to be followed for double materiality assessment

purposes.

A close collaboration between Divisions of the Group (Governance and Sustainability Division and the Climate, ESG, and Enterprise Risk

Management Division, Human Resources, Compliance and Finance) was ensured to derive the final double materiality assessment outcome.

Oversight and frequent input from senior personnel, along with regular Steering Committee meetings, were key to safeguarding the soundness

of the analysis. The meetings involved the participation of the Heads of the Divisions involved (e.g. Governance and Sustainability Division,

Climate, ESG, and Enterprise Risk Management Division, Internal Audit, Data Privacy, HRBP and International Support, etc.). Governance and

Sustainability Division was responsible for impact materiality assessment and opportunities assessment in the context of financial materiality.

Climate, ESG, and Enterprise Risk Management Division was the primary responsible for the financial materiality assessment of risks.

Additionally, an external consultant provided support by contributing to high-level design principles and assisting with or reviewing and

challenging quantitative and qualitative analyses and key assumptions, review and benchmark of analyses against relevant market practices,

providing recommendations to the working group as needed.

The materiality assessment, along with the calculations and assumptions was subsequently reviewed and thoroughly examined at both the

working group level (involving all process stakeholders) and the Steering Committee level.

Integration of risk and impact assessment into the Group’s overall risk management process

The Group adopts a proactive approach to the management of ESG risks. Emphasis is placed on risks arising from climate change, which is a

key component of its Risk Management Strategy. Following the recommendations of the TCFD, the Group 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 risks related to its activities. 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 Group has proceeded with targeted implementations during

2023 in accordance with Group’s ESG plan commitments, which will continue to be applicable in 2024.

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The Group, 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, 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, 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 updated its Risk Inventory to provide a comprehensive overview of the enhancements and progress achieved in

climate and environmental-related risks in the 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. p.133 Pillar III Disclosures June 30, 2024

• The Group has updated its Materiality Assessment of ESG risks identifying 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 Group 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 abovementioned ESG Risk Materiality assessment process has been leveraged for the financial materiality assessment of risks in the

context of CSRD. Therefore, the foundations of the approach followed are common, while some differentiations are applied in the

methodology followed in order to accommodate the specificities of each assessment.

Furthermore, Risk and Control Self-Assessment (RCSA) and Compliance Risk Assessments, which are considered integral part of the Bank’s Risk

Management Framework, have been leveraged for the financial materiality assessment of social and governance risks.

More information regarding the identification and mitigation of risks associated with other environmental and social factors is provided under

[E1-2] Policies related to climate change mitigation and adaptation.

Description of how the process to identify, assess and manage opportunities is integrated into the undertaking’s overall management process

where applicable

Alpha Services and Holdings Group uses its Sustainable Finance Framework and EU Taxonomy to identify ESG-related opportunities. These

frameworks provide a structured approach to classify and identify sustainable finance opportunities, ensuring that the Group’s opportunity

management practices are aligned with its overall management strategy.

More specifically, the Sustainable Finance Framework (“SFF” or “the framework”) can be defined as a guide that sets out a series of

approaches and procedures required for classifying financing as sustainable. Specifically, the framework stipulates the decision and

classification process, that the Group implements, to categorize its financial products or services as sustainable (i.e., green, or social). The main

purpose of the framework is to enable the identification and categorization of sustainable activities and to lay out the criteria to characterize

specific loans as sustainable.

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 and people’s health and wellbeing. In addition, policies and procedures are developed to reduce the operational environmental

footprint and to strengthen the commitments associated with this objective.

The Group’s strategic plan aims to address the risks and utilize new business opportunities to increase its positive effect on society and the

environment, while effectively generating value for its stakeholders. In this respect, strategic commitments and targets are being updated with

the ultimate objective to effectively manage any ESG related issues and improve environmental and social impacts.

With the operationalization of the framework, information on lending transactions is being processed and stored internally along with any

relevant documentation, analyzed, and monitored by relevant areas of the Group.

The Bank is expected to regularly report its performance against its strategic plan and specifically its progress in meeting the sustainable

financing target. The Bank intends to disclose information in relation to the financings which are characterized as sustainable and to the extent

possible, a breakdown of the use of proceeds by eligible themes, in scope business areas, geographical location and refinancing versus new

financing. Reporting information will be made publicly available on an annual basis through its Sustainability Report or dedicated Sustainable

Finance report.

Integration into Overall Management Process: The process to identify, assess, and manage impacts, risks, and opportunities is fully integrated

into Alpha Bank’s overall risk management process. This integration allows the Bank to evaluate our overall risk profile comprehensively,

ensuring that all potential and actual impacts and risks are identified, assessed, and managed effectively.

Description of how process to identify, assess and manage impacts, risks and opportunities has changed compared to prior reporting period

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As part of our preparation for CSRD reporting, the Group has conducted a double materiality assessment (DMA) in conformance with the ESRS

standards. This marks a significant change from the previous materiality assessment methodology. Specifically:

Transition to Double Materiality: Previously, the Bank assessed and prioritized ESG issues related to its activities that could impact the Group’s

operations and/or its stakeholders through an impact materiality analysis process, in accordance with GRI Standards (2021) for materiality

analysis (impact-based). This year, the Group has adopted a double materiality approach to capture both the inside-out impacts of its

operations on the environment and society, as well as the outside-in risks and opportunities that various ESG matters could generate for the

Bank’s business.

Due Diligence: A more detailed exercise was performed in the content of the CSRD requirements, regarding thorough investigation of its

business activities and operations across geographical areas, business relationships, as well as policies, processes and actions in place for

achieving its strategic targets and long-term goals.

Last Modification Date: The process was last modified in 2024 to incorporate these enhancements and to align with the double materiality

principles outlined in the ESRS.

Future Revision Dates: Future revisions of the materiality assessment have not been planned yet however all three short, medium, and long-

term time horizons shall be considered.

Climate-related impacts, risks and opportunities

Impact

Impact materiality analysis identified that climate-related impact was deemed material as a result of the Group’s activity in the following

sectors (table includes the top 10 contributing sectors, as a result of the Group’s Banking sector activity):

TABLE 12 TOP CONTRIBUTING SECTORS FOR CLIMATE-RELATED IMPACT

a/a

Sectors

50 Water transport

35 Electricity, gas, steam and air conditioning supply

68 Real estate activities

41 Construction of buildings

24 Manufacture of basic metals

19 Manufacture of coke and refined petroleum products

42 Civil engineering

51 Air transport

49 Land transport and transport via pipelines

20 Manufacture of chemicals and chemical products

Risks

Climate risks: Definition and Identification

Climate-related risks are the financial risks posed by the exposure of institutions to counterparties that may potentially contribute to or be

affected by climate change. This could, for example, take the form of physical damage caused by extreme weather events or a decline in the

asset value of a counterparty that operates in carbon-intensive sectors subject to taxation on CO

• Physical: Physical risks are the risks 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 invested assets. They are typically defined as risks

which arise from the physical effects of climate change and environmental degradation and can be categorized as following:

o Acute: which arise from particular/extreme events, especially weather-related events such as droughts, storms, floods,

fires or heatwaves, or other environmental hazards that may damage production facilities and disrupt value chains.

o Chronic: which arise from longer-term trends (progressive shifts in climate and weather patterns or a gradual loss of

ecosystem services), such as temperature changes, rising sea levels, reduced water availability, biodiversity loss and

changes in land and soil productivity.

• Transition: Transition risks are the risks of any negative financial impact on the institution stemming from the current or prospective

impacts of the transition to an environmentally sustainable economy on its counterparties or invested assets, including:

o climate and environment related policy changes, for example, as a result of energy efficiency requirements, carbon-pricing

mechanisms that increase the price of fossil fuels, or policies to encourage a sustainable use of environmental resources;

o technological changes, for example, if a technology with a less damaging impact on the climate or the environment

replaces a technology that is more damaging, hence making it obsolete or uncompetitive;

o behavioral changes, for example, if the choices of consumers and investors shift towards products and services that are

more sustainable; or if it becomes more difficult to attract and retain Customers, Employees, business partners and

investors when a counterparty has a reputation for damaging the climate and the environment.

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• Liability: Liability risk in the context of ESG factors relates to the risk stemming from people or businesses seeking compensation for

losses they may have incurred due to ESG factors, e.g., when institutions’ counterparties are held accountable for the negative

impact, they have on ESG factors through their activities.

In alignment with the relevant external guidance across different sources

, The Grouphas incorporated ESG factors as drivers of existing

financial and non-financial risk categories (e.g. credit risk, operational risk, market risk, liquidity risk etc.) in its risk management framework.

The table below provides an indicative illustration of the way existing risk types could be affected by Climate and Environmental

drivers:

TABLE 13 INDICATIVE IMPACT OF CLIMATE RELATED RISK DRIVERS

Indicative impact of Climate related risk drivers

Risk Type

Transition

Physical

Credit risk

- Impact on the credit risk parameters (PD, LGD,

EAD) as a result of transition risk events,

affecting the creditworthiness of

counterparties (e.g. increased PD of companies

sensitive to transition risk factors, impact on

collateral values from physical risk related

events and from disorderly transition to low-

carbon economy).

- Impact on the credit risk parameters (PD, LGD, EAD) as a

result of physical risk events, within sectors or

geographies vulnerable to physical risk (e.g. through

lower collateral valuations in real estate portfolios as a

result of increased flood risk).

Market risk

- Volatility and reduction in values and risk

returns of financial assets (e.g.

corporate/sovereign bonds, equity) from

climate-related factors (e.g. from transition risk

drivers leading to repricing of securities and

derivatives).

- Volatility and reduction in values and risk returns of

financial assets (e.g. corporate/sovereign bonds, equity)

from climate-related factors (e.g. from physical events

leading to repricing of securities and/or derivatives).

Liquidity risk

- Volatility and reduction in values and risk

returns of financial assets (e.g.

corporate/sovereign bonds, equity) from

climate-related factors (e.g. from transition risk

drivers leading to repricing of securities and

derivatives), which may reduce the value of

high-quality liquid assets, thereby affecting the

liquidity buffer.

- Impact through Bank’s ability to raise funds or

liquidate assets, e.g.:

o The ability to access stable sources

of funding is reduced.

o Climate-related asset

classes/instruments are prioritized

over other traditional asset

classes/instruments.

o Deposits and credit lines are drawn

down by counterparties.

- Volatility and reduction in values and risk returns of

financial assets (e.g. corporate/sovereign bonds, equity)

from climate-related factors (e.g. from physical events

leading to repricing of securities and derivatives), which

may reduce the value of high-quality liquid assets,

thereby affecting the liquidity buffer.

- Impact through Bank’s ability to raise funds or liquidate

assets, e.g.:

o The ability to access stable sources of funding

is reduced.

o Climate-related asset classes/instruments are

prioritized over other traditional asset

classes/instruments.

o Deposits and credit lines are drawn down by

counterparties.

Operational risk

- The Bank may incur fines due to lack of

consideration on compliance with

environmental standards or as a result of the

greenwashing, leading to conduct risk.

- The Bank’s operations may be disrupted due to physical

risk events, (e.g. extreme weather event) leading to

damages to physical assets or critical infrastructure that

is essential for providing services to Customers (e.g.

property, branches, energy supply, data centers etc.).

Business and Strategic

risk

- Failure to account for rising ESG factors, having

as key drivers the potential shift in consumer

preferences, behavioral/ demand patterns,

market sentiment and the potential change in

the competitive landscape, leading to

misalignment of business model to market

- Failure to account for the occurrence of extended

physical risk events (chronic and/or acute) impacting

financed activities /sectors more vulnerable to such risks

and consequently the Bank’s business model-

Liability risks are sometimes considered either physical or transition risks. They could, however, also be considered a separate risk category as they may not only

arise from

Some indicative regulatory and other references are:

i) In the 2020 ECB Guide on climate-related and environmental risks: “Institutions are expected to incorporate climate related and

environmental risks as drivers of existing risk categories into their risk management framework.” and “Climate-related and environmental

risks may, in fact, be drivers of several different risk categories and subcategories of existing risk categories simultaneously.”

ii) In the 2021 EBA Report on management and supervision of ESG risks for credit institutions and investment firms: “The EBA recommends

that institutions manage ESG risks as drivers of financial risks, in a manner consistent with the risk appetite, and as reflected in both the

ICAAP and ILAAP frameworks.” In the 2021 European commission final study, “Development of tools and mechanisms for the integration of

environmental, social and governance (ESG) factors into the EU banking prudential framework and into banks' business strategies and

investment policies”: “The majority of banks mentioned that this requires a clear mapping of ESG risks as drivers of existing risk types,

rather than treatment as a stand-alone risk type”, “Most banks that include ESG risks in their RAF fall under the second category, meaning

they consider ESG risk as a transversal risk driver.” and “Participants acknowledged the impact ESG risks can have on financial and non-

financial risks, as opposed to considering ESG risk as a standalone risk type.” In the Climate Financial Risk Forum Guide 2020, “Risk

Management Chapter”: “Good practice is to treat climate risk as a cross-cutting risk type that manifests through most of the established

principal / standalone risk types.”

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practices (e.g. not being able to finance the

environmental transition).

Reputational risk

- Impact on the Bank’s public perception and

reputation and consequently in its valuation,

considering also changing market and

consumer sentiment, due to its association

with activities and counterparties linked to

adverse environmental impacts (e.g. financing

of companies with significant polluting

activities, investments in sectors with high GHG

emissions etc.).

- Continually rising stakeholder expectations in

the area of climate risk (e.g. Bank’s

commitments regarding the mitigation of

climate risk) could lead to reputational risk, if

the Bank does not deliver fully on its position.

Materiality Assessment Methodology and Results

Current Financial Effect

As already mentioned in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, to assess the

magnitude of the current financial effect, the Bank has evaluated if any material climate related operational risk losses (referring to both

climate change mitigation and climate change adaption) have been recognized during the current financial year. For 2024, the Bank has not

identified any material losses from climate-related risks. Therefore, the current financial effect from those risks is considered not material.

Anticipated Financial Effect – Transition risk

Time Horizons

For financial materiality purposes, Alpha Bank S.A. defines the reference time horizons in alignment with CSRD guidance as follows:

Transition risks have been estimated in different time horizons, in alignment with ESRS recommendations: (a) for the short-term time horizon:

year (2025); (b) for the medium-term time horizon: from the 2

year and up to 5 years (2026-2030); and (c) for the long-term time horizon:

more than 5 years (>2030).

These horizons were chosen to also align with scientific pathways that limit warming to 1.5°C. This requires halving global GHG emissions by

2030 and approaching zero by 2050. These time horizons are also in line with the Greek Climate Law that has set a target for net zero by 2050,

and an interim target of reducing GHG emissions by 55% in 2030 compared to 1990 emissions.

Materiality Assessment

As already mentioned in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, the Bank has

recognized the sectors that are sensitive to transition risk (climate change mitigation), by taking into consideration several factors (e.g., CPRS

perimeters, NZBA/ LTS 2050, emission intensities, etc.).

In addition to the above, the Bank conducted a top-down qualitative materiality assessment for transition risk sub-types (market, technology,

reputation, policy and legal) as proposed by the TCFD, in order to identify the climate-related transition risks that materially affect each sector.

Each transition risk sub-type is comprised of risk drivers, such as:

• Policy and legal: policy developments (carbon pricing mechanisms, reporting obligations, policy mandates) that attempt to constrain

actions that contribute to the adverse effects of climate change or policy developments that seek to promote adaptation to climate

change, as well as climate-related litigation claims.

• Market: all shifts in supply and demand for certain commodities, products, and services. Capital markets are well-versed in

identifying and assessing market risks. However, climate change will have unique implications in the supply and demand of certain

commodities, products, and services.

• Reputation: all risks tied to changing customer or community perceptions of an organization’s contribution to or detraction from the

transition to a lower-carbon economy.

• Technology: all risks associated with technological improvements or innovations that support the transition to a lower-carbon,

energy-efficient economic system. Financial risks may arise if no new investments are made in new technologies that contribute to

climate-related adaptation and risk mitigation.

To estimate the likelihood of the transition risks, in alignment with the net zero scenario, more recent literature scenarios, strategic plans and

roadmaps were used, to qualitatively estimate the probability of occurrence of each transition risk driver:

• IEA, 2021, Net Zero by 2050 “A roadmap for the global energy sector”

• Ministry of Energy and Environment, 2023, National Plan for Energy and Climate (Draft version)

• Ministry of Energy and Environment, 2019, National Plan for Energy and Climate

• National Inventory of Greece Report 2023

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• UN Environment Program, Sectoral Risk Briefings: Insights for Financial Institutions, 2024

• Ministry of Energy and Environment, 2024, National Plan for Energy and Climate

• UNEP FI – Climate Risks in the Power Generation Sector, 2024

• UNEP FI – Climate Risks in the Metals and Mining Sector, 2024

• UNEP FI – Climate Risks in the Transportation Sector, 2024

• UNEP FI – Climate Risks in the Industrials Sector, 2023

• European Cement Association, 2021

• Science-based decarbonization pathways for the European Aluminum Industry – European Aluminum

• European Commission – Reducing emissions from the shipping sector

Following the assessment for transition risk sub-types, a Total Average transition risk score per sector and for all the time horizons is

calculated.

Likelihood of occurrence

As outlined in [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model, the Bank undertook a

qualitative materiality assessment for transition risk sub-types to identify the climate-related transition risks that materially impact each sector

within the transition risk-sensitive perimeter across different time horizons. The scale of the transition risk is defined by combining the

outcome of the Likelihood and the Impact analysis which are performed at sector level:

• Likelihood: the probability of occurrence within a provided time horizon

• Impact analysis: the extent to which the impact, if occurred, would affect the business

Following the assessment for transition risk sub-types, a Total Average transition risk score per sector and for all the time horizons is

calculated. This score is considered as a proxy for the likelihood of occurrence of an anticipated financial effect for the Bank.

Anticipated Magnitude of Financial Effect

In order to evaluate the potential magnitude of financial effects for transition risk, the Bank has calculated the percentage of the Bank’s

exposures lying within the Sensitive perimeter over Total Group Assets categorized under High, Medium and Low likelihood of occurrence

categories across the different time horizons.

The following materiality thresholds (that should apply simultaneously) are considered, in order to characterize climate change mitigation risk

as material:

• at least 5% of exposures within the Sensitive perimeter over Group Total Assets under High likelihood of occurrence, and

• at least 10% of exposures within the Sensitive perimeter over Group Total Assets under a combination of High and Medium

likelihood of occurrence.

The results of the materiality assessment performed are illustrated in the table below:

TABLE 14 ANTICIPATED FINANCIAL EFFECT – CLIMATE CHANGE MITIGATION

Anticipated Financial Effect – Risks

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Climate change mitigation

Not material

Material

As shown on the table above, in the medium- and long-term horizons the anticipated financial effect is found to be material on an inherent

level basis, considering that the percentage of the Bank’s exposures towards sectors sensitive to transition risk over the total Group Assets

exceeds the established materiality threshold. In the short-term horizon, the anticipated financial effect is found to be below the established

materiality threshold and, therefore, considered not material.

Anticipated Financial Effect – Physical risk

As already mentioned in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, the Group performs

a vulnerability assessment (at both sectoral and regional level) to identify potential significant hazards per sector covered by the analysis for

Business portfolio, as well as across the different geographic regions where real estate properties used as collateral are located.

Sectoral analysis - Vulnerability analysis of Business Portfolio on Physical climate risk

Sensitivity Analysis

Regarding the sectoral analysis conducted at NACE code level, the sensitivity analysis is focused on the sensitivity of the top 20 subsectors, for

the 16 climate hazards [Changing temperature (air, freshwater, marine water), Changing wind patterns, Changing precipitation patterns and

types (rain, hail, snow/ice), Sea level rise, Soil and coastal erosion, Soil degradation, Coldwaves/frost, Wildfire, Cyclone, hurricane, typhoon,

storm and tornado, Heavy precipitation (rain, hail, snow/ice) , Landslide and subsidence]. The sensitivity is assessed for each sub-sector per

climate hazard using a 3-level score of ‘High’, ‘Medium’ or ‘Low’:

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• High sensitivity: the climate hazard may have a significant impact

• Medium sensitivity: the climate hazard may have a moderate impact

• Low sensitivity: the climate hazard has no (or an insignificant) impact

The sensitivity has been assessed in three different time-horizons in alignment with the ESRS recommendations: (a) for the short-term time

horizon: one year (2025); (b) for the medium-term time horizon: from the 2nd year and up to 5 years (2026-2030); and (c) for the long-term

time horizon: more than 5 years (>2030). These horizons were chosen due to their alignment with scientific pathways and in line with the

Energy and Climate National Plan and the Greek Climate Law.

Exposure Analysis

The analysis resulted in the assessment of the exposure to future climate risks in country level using the maximum value in the geographic unit

under assessment (country or climate zone) for the three-time horizons (2025, 2026-2030, >2030).

For the estimation of exposure to existing climate conditions, available historical data are used for the specific geographical regions falling

under the scope of the current analysis. For the estimation of exposure to future conditions, climate simulation models and climate projections

were considered for the adverse scenario of evolution of greenhouse gas emissions RCP8.5, with horizons of 2030 and 2050.

RCP8.5 projects the reasonable worst-case scenario and is widely used for climate risk assessment and stress-testing. RCP8.5 was specifically

selected as a high-end baseline scenario and was not intended to be portrayed as the most likely “business as usual” no-policy outcome. It is

important to note that climate variables’ values and impacts will only strongly differ with other scenarios in the long-term (2070-2100), while

being close to others up to 2050.

Different time horizons have been defined by means of 30-year or 20-year timeframes following literature best practices

The assessment of

the exposure level provides a detailed analysis of physical climate risks at a corporate level. This is based on a common clear and defined

system for all climate parameters, accepted by the scientific community, that takes into account changes in climate parameters in different

chronological periods and corresponds to percentage changes in corresponding exposure categories.

Inputs are composed of experiments under the CORDEX initiative, which combines global and regional climate models with a horizontal spatial

resolution of 11 km

. For the current conditions, the timeframe climate (1981-2010) was considered, whereas two different timeframes (2030

and 2050) were used for the analysis of future conditions. For each climate risk, indicators are provided to measure exposure, based on the

climate scenarios of the evolution of GHG gas emissions (RCP 8.5, which is considered a high-emission scenario), as determined by the IPCC

and the scientific community.

The analysis focuses on a subset of selected climate physical risks, which are considered the most relevant to the structural characteristics of

real estate properties in Greece, based on relevant literature. The selected climate physical risks are divided into chronic and acute risks based

on TCFD and EU taxonomy classification:

• Chronic: sea level rise, soil erosion

• Acute: wildfire, cyclone/ hurricane/ typhoon/ storm/ tornado, floods.

These climate risks have been analyzed using the following climate indicators. Where datasets were not available, dynamic maps and variables

were used to estimate the local exposure. An example of this is the sea level rise indicator, for which some locations are not covered. In this

case, the external source of NASA - IPCC AR

Sea Level Projection Tool

is used, in order to complete the exposure assessment. For the flood

risk, the retention of the worst-case scenario for either pluvial or fluvial floods in each NUTS 3 region, alternating between the two indicators

each time, is ensured.

TABLE 15 CLIMATE PHYSICAL RISK HAZARDS

See for instance DRIAS, Les futurs du climat - Accueil (driasclimat.fr), French most renowned open-data portal hosted by MeteoFrance, IPSL and CERFACS

laboratories.

EURO-CORDEX - Coordinated Downscaling Experiment - European Domain

NASA, IPCC AR6 Sea Level Projection Tool

Hazard

Indicator description

Unit

Acute

Wildfire

Annual average FFDI for days where FFDI > 10

index

Cyclone, hurricane, typhoon, storm and tornado

Annual maximum of daily wind speed

m/s

Flood (fluvial)

Average fluvial flooding elevation related to a 100-year frequency event

Flood (pluvial)

Average pluvial flooding elevation related to a 100-year frequency event

Chronic

Sea level rise

Mean local sea level rise compared to the reference period baseline

Soil erosion

Annual average of soil erosion

t/ha/year

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Greek territory is divided in four climate zones based on the temperature conditions that prevail in each prefecture. According to the current

building energy efficiency regulation, our country is divided into four climate zones, as shown in the figure below.

Climate data of the RCA4 results were retrieved at a horizontal resolution of ~11 km for the Greek domain. The domain consists of

approximately 75 x 82 grid cells. NUTS 3 level results are an outcome of an aggregated approach, by taking the average of the corresponding

grid-cell points belonging in this NUTS 3.

For each indicator and each point of the grid, the value displayed is computed by averaging the projections of several climate models for a

given combination of {geography x scenario x horizon} and corresponds as such to the “mean” value of the indicator for the given combination.

The value displayed for each indicator and grid point is computed by averaging the projections specifically for the RCP 8.5 scenario and the

horizons 2030 and 2050. Exposure fields are defined for each combination of indicator, RCP 8.5 scenario, time horizons 2030 and 2050, and

climate type, based on predefined global thresholds derived from scientific literature for assessing exposure levels (low, medium, high).

Regarding the definition of the thresholds, whenever possible, absolute thresholds across all climate types have been derived from recognized

scale as presented in the following table. For instance, flooding thresholds defined are based on World Bank classification, while water stress

thresholds directly derive from WRI classification.

TABLE 16 SOURCES USED FOR CLIMATE RISK

Climate risk

Source

Wildfire

Using alternative soil moisture estimates in the McArthur Forest Fire Danger Index

Cyclone, hurricane, typhoon, storm and tornado

Quantifying the Occurrence of Multi-Hazards Due to Climate Change

Max value of Flood (fluvial – pluvial)

AMBIENTAL GlobalFloodMap dataset, 30m resolution resampled

Sea level rise

NASA - IPCC AR6 Sea Level Projection Tool

Global and European sea level rise

Soil erosion

European Soil Data Centre (ESDAC)

Vulnerability Analysis

The vulnerability analysis is derived by combining the outcome of the sensitivity analysis and the exposure analysis. 3-level scores have been

used to assess both the sensitivity and the exposure, which, when combined, form a 9-level score that can be mapped to a 3-level vulnerability

score (High – Medium – Low).

Regional analysis - Vulnerability analysis of Real Estate properties on Physical climate risk

It is worth noting that some of the loan exposures of the Bank may be covered by both the approach applied at NACE sector level (covered in

previous section) and the approach described here. The previous approach examines the activity/sector of borrowers and their degree of

vulnerability to physical risk, while this approach examines the vulnerability of real estate property collaterals that may exist and, to that

extent, the potential vulnerability of loan exposures is linked to these collaterals. Therefore, the drivers or “transmission mechanisms” of

physical risks are different between these two cases.

To achieve a higher granularity level in the exposure analysis regarding real estate properties portfolio, a location-specific risk analysis has

been conducted, using geospatial mapping and local geographical characteristics based on identified NUTS 3 levels. In this way, the Bank can

assess materiality to different hazards in more detail in terms of location of collaterals. The final assessment outcome is presented in terms of

High/Medium/Low exposure levels, using relevant hazard metrics averaged to provide the results resolution of location data of the Bank under

the three time horizons (short – 2025 / medium –2026-2030 / long – >2030). For each NUTS 3 level region, a comprehensive grid of points is

plotted on the map to ensure detailed coverage of each different prefecture. The physical risk level presented is an average derived from these

specific locations (with averaging over several nearest neighbor grid points), for each NUTS 3 level, ensuring a comprehensive understanding of

risks at a localized level. However, variations from the reported average risk level may occur when compared to the individual grid points

within a NUTS 3 level region.

Likelihood of occurrence

Based on the Vulnerability assessment (at both sectoral and regional level) as described above, the vulnerability assessment outcome is

considered as a proxy for the likelihood of occurrence of an anticipated financial effect for the Bank.

Using alternative soil moisture estimates in the McArthur Forest Fire Danger Index, 2017

Quantifying the Occurrence of Multi-Hazards Due to Climate Change, 2022

Flood Exposure and Poverty in 189 Countries

Sea Level Projection Tool, Nasa

Global and European sea level rise, 2024

Global Soil Erosion

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For the regional analysis the factors taken into consideration are wildfire, flood, cyclone, sea level rise and soil erosion. For the sectoral

analysis the factors that are considered are changing temperature, heat stress and permafrost thawing, changing wind patterns, changing

precipitation patterns and types (rain, hail, snow/ice), sea level rise, water stress, soil and coastal erosion, soil degradation, heatwaves, cold

waves/ frost, wildfire, cyclone, hurricane, typhoon, storm and tornado, droughts, Heavy precipitation (rain, hail, snow/ice), floods and

landslide and subsidence.

Potential Magnitude of Financial Effects

Following the aforementioned vulnerability assessment, the Bank has identified sectors and regions categorized under High, Medium, and Low

Likelihood of Occurrence. Subsequently, the Bank calculated the percentage of its exposures classified as High, Medium, or Low Likelihood of

Occurrence over the Total Group Assets, considering regional and sectoral analyses over different time horizons.

A materiality threshold has been set, taking into consideration Bank’s 'exposures over Group Total Assets’ lying under High Likelihood of

Occurrence category (set at 10% of the Bank’s 'exposures over Group Total Assets’ under High Likelihood of Occurrence).

The results of the materiality assessment performed are illustrated in the table below:

TABLE 17 ANTICIPATED FINANCIAL EFFECT – RISKS (CLIMATE CHANGE ADAPTATION)

Anticipated Financial Effect - Risks

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Climate change adaptation

Not material

Material

As shown on the table above, in the short-term horizon, the anticipated financial effect is found to be below the established materiality

threshold (that is set at 10% of the Bank’s 'exposures over Group Total Assets’ under High Likelihood of Occurrence) and, therefore, it is

considered not material. In the medium- and long-term horizons the anticipated financial effect is found to be material on an inherent level

basis, considering that for some physical risk factors (e.g., wildfire in case of the regional analysis and floods in case of sectoral analysis) the

anticipated occurrence is relatively high.

Opportunities

Current Financial Effect

As mentioned under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, in order to assess the

magnitude of the current financial effect, the Bank has evaluated if any material related opportunities related to climate change mitigation and

climate change adaptation (EU Taxonomy aligned and other sustainable financings according to the Bank’s SFF) have been recognized during

the current financial year. A threshold of Euro 1 billion has been set in order to consider an opportunity as material. For 2024, material climate

change mitigation opportunities have been identified (exceeding the threshold of Euro 1 billion), while no climate change adaptation related

opportunities were identified.

Anticipated Financial Effect

The materiality assessment performed by the Bank indicates that there is material opportunity for climate change mitigation in the short-,

medium- and long-term. Regarding the short-term horizon the Bank expects increase of the sustainable financings towards climate change

mitigation objective (thus they will continue, exceeding the relevant threshold) in the Business Plan horizon. Accordingly, in the medium and

long-term horizon the expectation is that this type of financings will continue increasing. A threshold of Euro 1 billion has been set in order to

consider an opportunity as material.

Climate change adaptation is considered a material opportunity only in the long-term horizon, as physical risks are anticipated to intensify over

time and therefore financings related to adaptation are expected to grow, surpassing the materiality threshold of Euro 1 billion. Regarding the

short-term horizon the Bank does not expect material opportunities – that exceed the threshold of Euro 1 billion (i.e., sustainable financings

towards climate change adaptation activities) in the Business Plan horizon. Accordingly, even in the medium -term horizon the Bank does not

expect material opportunities – that exceed the threshold of Euro 1 billion.

TABLE 18 ANTICIPATED FINANCIAL EFFECT – OPPORTUNITIES (CLIMATE CHANGE MITIGATION AND ADAPTATION)

Anticipated Financial Effect - Opportunities

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Climate Change Mitigation

Material

Climate Change Adaptation

Not material

Material

For financial materiality purposes, Alpha Bank has defined the time horizons in alignment with CSRD guidance as follows:

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• Short-term horizon: Defined at 1 year ahead of the assessment; (aligned with the assumptions for the first year of budgeting and

business planning process, as well as the regular stress testing scenarios for solvency and liquidity purposes).

• Medium-term horizon: Defined from the 2

year and up to 5 years beyond the assessment (2026-2030). This horizon is closely

aligned with the strategic planning horizon of Alpha Bank, representing the core timeframe within which the bank's strategic

objectives, financial goals, and key sustainability initiatives are designed and implemented.

• Long-term horizon: Defined as a minimum of 6 years beyond the assessment date, extending further as appropriate to align with the

type of climate risk being assessed and the timeframe over which it can be reliably addressed. (>2030).

The average maturity of the Bank’s NFC portfolio is approximately five years and therefore the majority of the Bank’s NFC portfolio (c. 63%)

has a residual maturity equal or below five years, while the average maturity of the Bank’s real estate portfolio is c. 14 years, with the majority

of the Bank’s real estate portfolio (c. 58%) having a residual maturity between one and 16 years.

Identification of assets and business activities that are incompatible with or need significant efforts to be compatible with a transition to a

climate-neutral economy

The Group does not have any operational or financed locked-in emissions, or any other assets or activities that could jeopardize the

achievement of its net zero target.

Compatibility of climate scenarios with climate-related assumptions made in the financial statements

As part of its financial materiality assessment, the Bank utilizes widely recognized science based decarbonization scenarios (e.g., IEA NZE) and

other climate scenarios to evaluate the likelihood of transition risks, quantify the anticipated financial effects of climate risk, and derive the

financial materiality outcome. In the context of its decarbonization strategy, the Bank has incorporated decarbonization targets in specific

sectors (Cement, Power generation, Oil and Gas, Iron and Steel), leveraging on the IEA NZE scenario, which is closely aligned with the scenarios

utilized for DMA purposes. In addition, the scenarios utilized in the context of the financial materiality assessment of climate physical risks

reflect the resilience analysis performed by the Bank to estimate the impact of climate physical risks, in the context of ICAAP or other similar

processes or one-off exercises.

Pollution-related impacts, risks and opportunities

Impact

The process followed is described in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

The Impact materiality analysis has not identified any Pollution impact as material to the Group’s downstream activities.

No material impacts to Pollution of water, soil and air have been concluded deriving from the Group’s products/services (downstream value

chain), as the Group’s portfolio did not indicate material association with sectors contributing significantly to pollution. Furthermore, currently

there is no projection of significant changes to the mix of portfolio indicating a material impact to Pollution for the future time horizons.

Risks

Current Financial Effect

In order to assess the magnitude of the current financial effect, the Bank has evaluated if any material pollution-related operational risk losses

have been recognized during the current financial year. For 2024, no pollution-related operational losses have been recognized.

Anticipated Financial Effect

The materiality assessment performed by the Bank indicates that pollution is not material in the short- (2025), medium-(2026-2030) and long-

term (>2030), following the same methodology with biodiversity and ecosystems explicitly described under [IRO-1] Description of the process

to identify and assess material impacts, risks and opportunities.

Likelihood of Occurrence

The risk assessment methodology utilized in order to estimate the likelihood of occurrence is explicitly described under [IRO-1] Description of

the process to identify and assess material impacts, risks and opportunities.

Anticipated Magnitude of Financial Effect

Based on this methodology pollution is considered immaterial across time horizons, since the percentage of the exposures over the Group

Total Assets does not exceed the respective thresholds.

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TABLE 19 ANTICIPATED FINANCIAL EFFECT – RISKS (POLLUTION)

Anticipated Financial Effect - Risks

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Pollution

Not material

More details regarding the methodology and the thresholds applied are available under [IRO-1] Description of the process to identify and

assess material impacts, risks and opportunities.

Opportunities

Current Financial Effect

As described under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, in order to assess the

magnitude of the current financial effect, the Bank has evaluated if any material pollution-related opportunities have been recognized during

the current financial year. For 2024, no pollution-related opportunities were identified.

Anticipated Financial Effect

The materiality assessment performed by the Bank indicates that there is no material Opportunity related to pollution (i.e., sustainable

financings towards pollution prevention and control related activities) in the short- (2025), medium-(2026-2030) and long-term (>2030)

horizons, following the same methodology with biodiversity and ecosystems explicitly described under [IRO-1] Description of the process to

identify and assess material impacts, risks and opportunities.

TABLE 20 ANTICIPATED FINANCIAL EFFECT – OPPORTUNITIES (POLLUTION)

Anticipated Financial Effect - Opportunities

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Pollution

Not material

Water and marine resources-related impacts, risks and opportunities

Impact

The process followed is described in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

The Impact materiality analysis has not identified any Water and marine resources impact as material to the Group’s downstream activities.

No material impacts to Water and Marine Resources have been concluded deriving from the Group’s products/services (downstream value

chain), as the Group’s portfolio did not indicate material association with sectors contributing significantly to pollution. Furthermore, currently

there is no projection of significant changes to the mix of portfolio indicating a material impact to Water and Marine Resources for the future

time horizons.

Risks

Current Financial Effect

In order to assess the magnitude of the current financial effect, the Bank has evaluated if any material water and marine resources-related

operational risk losses have been recognized during the current financial year. For 2024, no water and marine resources-related operational

losses have been recognized.

Anticipated Financial Effect

The materiality assessment performed by the Bank indicates that water and marine resources is not material in the short- (2025), medium-

(2026-2030) and long-term (>2030) horizons, following the same methodology described under [IRO-1] Description of the process to identify

and assess material impacts, risks and opportunities.

Likelihood of Occurrence

The risk assessment methodology utilized in order to estimate the likelihood of occurrence is explicitly described under [IRO-1] Description of

the process to identify and assess material impacts, risks and opportunities.

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Anticipated Magnitude of Financial Effect

Based on this methodology water and marine resources is considered immaterial across time horizons, since the percentage of the exposures

over the Group Total Assets does not exceed the respective thresholds.

TABLE 21 ANTICIPATED MAGNITUDE OF FINANCIAL EFFECT – RISKS (WATER AND MARINE RESOURCES)

Anticipated Financial Effect - Risks

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Water and Marine

Resources

Not material

More details regarding the methodology and the thresholds applied are available under [IRO-1] Description of the process to identify and

assess material impacts, risks and opportunities.

Opportunities

Current Financial Effect

As described under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, in order to assess the

magnitude of the current financial effect, the Bank has evaluated if any material water and marine resources -related opportunities have been

recognized during the current financial year. For 2024, no water and marine resources -related opportunities were identified.

Anticipated Financial Effect

The materiality assessment performed by the Bank indicates that there is no material Opportunity related to water and marine resources (i.e.,

sustainable financings towards sustainable use and protection of water and marine resources related activities) in the short- (2025), medium-

(2026-2030) and long-term (>2030) horizons, following the same methodology with biodiversity and ecosystems explicitly described under

[IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

TABLE 22 ANTICIPATED MAGNITUDE OF FINANCIAL EFFECT – OPPORTUNITIES (WATER AND MARINE RESOURCES)

Anticipated Financial Effect - Opportunities

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Water and Marine

Resources

Not material

Biodiversity and ecosystems-related impacts, risks and opportunities

Impacts

Please refer to [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

Impact materiality analysis identified that Habitat impact was deemed material as a result of the Group’s downstream activities. The following

table lists the top 10 sectors (2 digits NACE codes) with the highest negative impacts on Habitats as this derived from Group’s downstream

portfolio analysis:

TABLE 23 TOP 10 SECTORS WITH HIGHEST NEGATIVE IMPACTS ON HABITATS

a/a

Sectors

50 Water Transport

35 Electricity, gas, steam and air conditioning supply

68 Real estate activities

42.11 Construction of roads and motorways

41 Construction of buildings

51 Air transport

24 Manufacture of basic metals

42 Civil Engineering

19 Manufacture of coke and refined petroleum products

52 Warehousing and support activities for transportation

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Risks

Current Financial Effect

As already mentioned in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, in order to assess

the magnitude of the current financial effect, the Bank has evaluated if any material biodiversity and ecosystems related operational risk losses

have been recognized during the current financial year. For 2024, has not identified any losses from biodiversity and ecosystems-related risks.

Therefore, the current financial impact from those risks is considered not material.

Anticipated Financial Effects

Impact Analysis

As already mentioned in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, the materiality

assessment performed by the Bank indicates that biodiversity and ecosystems topic is material in the long-term (>2030) horizon.

More specifically, the Bank performed an analysis based on UNEP FI Portfolio Impact Analysis tool to assess the negative impact of the sectors

(analyzed at the 4-digit NACE level) within its Non-Financial Corporate portfolio to UNEP FI impact topics. For the purposes of the analysis, the

relevant impact topics are mapped with ESRS Topics/Sub-Topics and Sub-sub-topics (in the case of biodiversity and ecosystems to habitats and

species). The Bank has adopted a conservative approach, assuming that if a sector significantly impacts either Species or Habitat, it

consequently has a key negative impact on Biodiversity. As mentioned, the assessment considered relevant impact topics and "key sectors,"

which are the sectors directly affecting Biodiversity.

Likelihood of Occurrence

More specifically, and as described in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities., for

each environmental topic (including biodiversity and ecosystems) and for each sector was assigned a transition risk score across different time

horizons (short-, medium-, long-term), taking into consideration key environmental regulations or policies which reflect the EU’s commitment

to environmental protection and sustainable development. These factors may affect the financial performance and credit capabilities of

companies in affected sectors that lag in the transition, posing a risk for the Bank relative to its exposure to these sectors. A three-level scale

was adopted:

• Low: There are no specific regulations or policies affecting this sector.

• Medium: There are specific regulations or policies affecting this sector, but there is no defined or pressing time-horizon.

• High: There are strict regulations and/or policies in place, with specific time-horizons.

This score is considered as a proxy for the likelihood of occurrence of an anticipated financial effect.

Anticipated Magnitude of Financial Effects

As outlined under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, the Bank assessed the

potential magnitude of financial effects of biodiversity and ecosystems by calculating the percentage of exposures corresponding to each

likelihood of occurrence category (high, medium, low) relative to the Group Total Assets across different time horizons.

The following materiality thresholds (that should apply simultaneously) are considered, in order to characterize Biodiversity and Ecosystems as

material:

• at least 5% of exposures (of key negative sectors as defined by UNEP FI per environmental topic) over Group Total Assets under High

likelihood of occurrence, and

• at least 10% of exposures (of key negative sectors as defined by UNEP FI per environmental topic) over Group Total Assets under a

combination of High and Medium likelihood of occurrence.

The results show that biodiversity and ecosystems topic is material, in the long term-horizon since the percentage of the exposures over the

Group Total Assets exceed the respective thresholds.

TABLE 24 ANTICIPATED FINANCIAL EFFECT – RISKS (BIODIVERSITY AND ECOSYSTEMS)

Anticipated Financial Effect - Risks

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Biodiversity and

Ecosystems

Not material

Material

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.Dependency Analysis

The Bank proceeds with the dependency analysis, adhering to EBA’s Consultation paper on draft Guidelines for managing ESG risks, which

states that “Large institutions should develop methods to identify natural capital dependencies, as part of analyses of nature-related or

biodiversity risks.” More specifically, in addition to the previously described Impact analysis, the Bank evaluates the environmental

dependencies of its business portfolio on natural and ecosystem services.

For this purpose, the bank utilizes the ENCORE (Exploring Natural Capital Opportunities, Risks and Exposure) tool, which is designed to assist

with evaluating nature-related risks by providing insights into the dependencies on natural resources. For each ecosystem service and

economic activity combination, literature reviews were conducted using scientific journals, peer-reviewed papers, key document searches, and

grey literature. Standardized search terms and targeted website searches, including leading sector companies and industry initiatives, were

also utilized. Industry experts from various economic sectors reviewed the identified dependency links, resulting in a complete evaluation of

which of the 25 ecosystem services are essential for the production of each of the 271 economic activities. As a result, a materiality rating was

assigned for each identified dependency link between an economic activity and an ecosystem service. When no connection was established,

the combination of the economic activity and ecosystem service was marked either as N/A (Not Applicable) or, in cases of insufficient data, as

ND (No Data). The materiality rating varies based on the following:

• the significance of the loss of functionality in the production process if the ecosystem service is disrupted, and

• the significance of the financial loss due to the loss of functionality in the production process.

In this context the Bank acknowledges the 25 ecosystem services set out in the ENCORE tool and assesses the economic sectors’ potential

dependency on these ecosystem services, by using existing classifications of ecosystem services and economic sectors. At this stage, Alpha

Bank applies a mapping of the ISIC sectors (sourced by the ENCORE tool), to the 4-digit NACE sectors classification which is used for monitoring

its Non-Financial Corporate (NFC) portfolio.

Dependency to an ecosystem service (such as Water purification, Soil quality regulation), is assessed in terms of materiality, by examining the

exposures’ distribution to High and Very High scores. The analysis depicts that a significant percentage of its obligors are dependent on some

ecosystem services including “Visual Amenity services”, “Recreation-related services”, “Water purification” and “Flood mitigation services”.

Even though material dependencies to ecosystem services do not reflect material risks on their own, the analysis is well aligned to the

materiality conclusions drawn by the Bank, in particular with respect to Physical Climate risk and Biodiversity risks (mentioned in impact

analysis above).

Opportunities

Current Financial Effect

As already mentioned in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, in order to assess

the magnitude of the current financial effect, the Bank has evaluated if any material biodiversity and ecosystem related opportunities have

been recognized during the current financial year. For 2024, no material biodiversity and ecosystem related opportunities were identified,

since they do not exceed the threshold of Euro 1 billion that has been set.

Anticipated Financial Effect

The materiality assessment performed indicates that opportunities related to biodiversity and ecosystem are considered material in the long-

term (>2030) horizon, since the Bank anticipates material opportunities towards protection and restoration of biodiversity and ecosystems

activities that exceed the threshold of Euro 1 billion (i.e., sustainable financings). Regarding the short- and medium-term horizon the Bank

does not expect material opportunities (i.e., material sustainable financings towards protection and restoration of biodiversity and ecosystems

related activities) that exceed the threshold of Euro 1 billion based, also, on the Business Plan.

TABLE 25 ANTICIPATED FINANCIAL EFFECT – OPPORTUNITIES (BIODIVERSITY AND ECOSYSTEMS)

Anticipated Financial Effect - Opportunities

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Biodiversity and

Ecosystems

Not material

Material

The methodology and the tools utilized for the materiality assessment of biodiversity and ecosystems (UNEPFI for the impact analysis and

ENCORE for the dependency analysis) are inherently systemic, taking into consideration that it is applied across NACE sectors and

environmental topics. Similarly, the transition risk analysis that is performed for each environmental topic and for each sector is, also

considered systemic, as it incorporates key environmental regulations or policies which reflect the EU’s commitment to environmental

protection and sustainable development.

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Resource use and circular economy-related impacts, risks and opportunities

Impacts

Please refer to [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities for more information.

Impact materiality analysis identified that Resources impact was deemed material as a result of the Group’s downstream activities. The

following table lists the top 10 sectors (2 digits NACE codes) with the highest negative impacts on Resources as this derived from Group’s

downstream portfolio analysis:

TABLE 26 TOP 10 SECTORS WITH HIGHEST NEGATIVE IMPACTS ON RESOURCES

a/a

Sectors

50 Water Transport

35 Electricity, gas, steam and air conditioning supply

68 Real estate activities

19 Manufacture of coke and refined petroleum products

42 Civil Engineering

41 Construction of buildings

51 Air transport

24 Manufacture of basic metals

20 Manufacture of chemicals and chemical products

27 Manufacture of basic metals

Risks

Current Financial Effect

In order to assess the magnitude of the current financial effect, the Bank has evaluated if any material circular economy-related operational

risk losses have been recognized during the current financial year. For 2024, no circular economy -related operational losses have been

identified.

Anticipated Financial Effect

The materiality assessment performed by the Bank indicates that Circular Economy is not material in the short- (2025), medium-(2026-2030)

and long-term (>2030) horizons, following the same methodology described under [IRO-1] Description of the process to identify and assess

material impacts, risks and opportunities.

Likelihood of Occurrence

The risk assessment methodology utilized in order to estimate the likelihood of occurrence is explicitly described under [IRO-1] Description of

the process to identify and assess material impacts, risks and opportunities.

Anticipated Magnitude of Financial Effect

Based on this methodology water and marine resources is considered immaterial across time horizons, since the percentage of the exposures

over the Group Total Assets does not exceed the respective thresholds.

TABLE 27 ANTICIPATED FINANCIAL EFFECT – RISKS (CIRCULAR ECONOMY)

Anticipated Financial Effect - Risks

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Circular Economy

Not material

More details regarding the methodology and the thresholds applied are available under [IRO-1] Description of the process to identify and

assess material impacts, risks and opportunities.

Opportunities

Current Financial Effect

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As described under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities, in order to assess the

magnitude of the current financial effect, the Bank has evaluated if any material opportunities related to circular economy have been

identified during the current financial year. For 2024, no material circular economy -related opportunities were identified, since they do not

exceed the threshold of Euro 1 billion that has been set.

Anticipated Financial Effect

The materiality assessment performed indicates that opportunities related to circular economy (i.e., material sustainable financings towards

transition to circular economy related activities) are considered material in the long-term (>2030) horizon, while for the short- and medium-

term horizon the Bank does not expect material opportunities, following the same methodology with biodiversity and ecosystems explicitly

described under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

TABLE 28 ANTICIPATED FINANCIAL EFFECT – OPPORTUNITIES (CIRCULAR ECONOMY)

Anticipated Financial Effect - Opportunities

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Circular Economy

Not material

Material

Business Conduct-related impacts, risks and opportunities

The process to identify material impacts, risks and opportunities in relation to business conduct matters are the following:

Impacts

Please refer to [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities for more information.

Risks

Current Financial Effect

In order to assess the magnitude of the current financial effect, the Bank has evaluated if any material business conduct related operational

risk losses have been recognized during the current financial year. For 2024, no material business conduct related operational losses have been

recognized.

Anticipated Financial Effect

To evaluate the anticipated financial effect of business conduct related risks, the Bank conducted a mapping of the respective ESRS sub-topics

with the risk types identified within the Compliance Risk Assessment and the corresponding inherent risk assessment outcomes. A four-level

scale (Low, Medium Low, Medium High, High) is utilized in the context of the Compliance Assessment. The following dimensions are

considered to derive the inherent risk assessment outcome:

• Impact: the potential effect on the entity’s objectives should the risk be manifested (Magnitude of financial effects).

• Likelihood: the possibility that the risk will manifest over a pre-defined period of time (Likelihood of occurrence).

ESRS sub-sub-topics that are assessed as having a High or Medium High inherent risk are deemed material. It is noted that the inherent risk

assessment considers which is the impact for the Bank in case the risk is manifested within the next year (short-term) without additional

mitigation actions going forward. It is assumed that the same conclusions are, also, applicable in the medium- and long-term horizons. The

outcome of the above analysis is presented below:

TABLE 29 ANTICIPATED FINANCIAL EFFECT – RISKS (CORRUPTION AND BRIBERY)

Anticipated Financial Effect - Risks

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Corruption and Bribery

Material

As seen in the above table, business conduct and in particular corruption and bribery is considered material in the short-, medium- and long-

term given that AML/CFT risk is assessed as High from an inherent risk perspective.

[IRO-2] Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement

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TABLE 30 TABLE OF ALL THE DATAPOINTS DERIVING FROM OTHER EU LEGISLATION

Disclosure Requirement and

related datapoint

SFDR Reference

Pillar 3 Reference

Benchmark Regulation

reference

EU Climate Law

Reference

Location in the

sustainability

statement/ Not

Material

ESRS 2 GOV-1

Board's gender diversity

paragraph 21 (d)

Indicator number 13 of

Table #1 of Annex 1

Commission Delegated

Regulation (EU)

2020/1816 ( 27 ) , Annex

[GOV-1] The role of the

administrative,

management and

supervisory bodies

ESRS 2 GOV-1

Percentage of board members

who are independent

paragraph 21 (e)

Delegated Regulation

(EU) 2020/1816, Annex

[GOV-1] The role of the

administrative,

management and

supervisory bodies

ESRS 2 GOV-4

Statement on due diligence

paragraph 30

Indicator number 10

Table #3 of Annex 1

[GOV-4] Statement on

due diligence

ESRS 2 SBM-1

Involvement in activities

related to fossil fuel activities

paragraph 40 (d) i

Indicators number 4

Table #1 of Annex 1

Article 449a Regulation

(EU) No 575/2013;

Commission Implementing

Regulation (EU) 2022/2453

( 28 ) Table 1: Qualitative

information on

Environmental risk and

Table 2: Qualitative

information on Social risk

Delegated Regulation

(EU) 2020/1816, Annex

[SBM-1] Strategy,

business model and

value chain

ESRS 2 SBM-1

Involvement in activities

related to chemical production

paragraph 40 (d) ii

Indicator number 9

Table #2 of Annex 1

Delegated Regulation

(EU) 2020/1816, Annex

[SBM-1] Strategy,

business model and

value chain

ESRS 2 SBM-1

Involvement in activities

related to controversial

weapons paragraph 40 (d) iii

Indicator number 14

Table #1 of Annex 1

Delegated Regulation

(EU) 2020/1818 ( 29 ) ,

Article 12(1) Delegated

Regulation (EU)

2020/1816, Annex II

[SBM-1] Strategy,

business model and

value chain

ESRS 2 SBM-1

Involvement in activities

related to cultivation and

production of tobacco

paragraph 40 (d) iv

Delegated Regulation

(EU) 2020/1818, Article

12(1) Delegated

Regulation (EU)

2020/1816, Annex II

[SBM-1] Strategy,

business model and

value chain

ESRS E1-1

Transition plan to reach climate

neutrality by 2050 paragraph

Regulation (EU)

2021/1119, Article 2(1)

[E1-1] Transition plan for

climate change

mitigation

ESRS E1-1

Undertakings excluded from

Paris-aligned Benchmarks

paragraph 16 (g)

Article 449a

Regulation (EU) No

575/2013; Commission

Implementing Regulation

(EU) 2022/2453 Template

1: Banking book-Climate

Change transition risk:

Credit quality of exposures

by sector, emissions and

residual maturity

Delegated Regulation

(EU) 2020/1818,

Article12.1 (d) to (g),

and Article 12.2

[E1-1] Transition plan for

climate change

mitigation

ESRS E1-4

GHG emission reduction

targets paragraph 34

Indicator number 4

Table #2 of Annex 1

Article 449a

Regulation (EU) No

575/2013; Commission

Implementing Regulation

(EU) 2022/2453 Template

3: Banking book – Climate

change transition risk:

alignment metrics

Delegated Regulation

(EU) 2020/1818, Article

[E1-4] Targets related to

climate change

mitigation and

adaptation

ESRS E1-5

Energy consumption from fossil

sources disaggregated by

sources (only high climate

impact sectors) paragraph 38

Indicator number 5

Table #1 and Indicator n.

5 Table #2 of Annex 1

[E1-5] Energy

consumption and mix

ESRS E1-5 Energy consumption

and mix paragraph 37

Indicator number 5

Table #1 of Annex 1

[E1-5] Energy

consumption and mix

ESRS E1-5

Energy intensity associated

with activities in high climate

impact sectors paragraphs 40

to 43

Indicator number 6

Table #1 of Annex 1

[E1-5] Energy

consumption and mix

ESRS E1-6

Gross Scope 1, 2, 3 and Total

GHG emissions paragraph 44

Indicators number 1 and

2 Table #1 of Annex 1

Article 449a; Regulation

(EU) No 575/2013;

Commission Implementing

Delegated Regulation

(EU) 2020/1818, Article

5(1), 6 and 8(1)

[E1-6] Gross Scopes 1, 2,

3 and Total GHG

emissions

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Disclosure Requirement and

related datapoint

SFDR Reference

Pillar 3 Reference

Benchmark Regulation

reference

EU Climate Law

Reference

Location in the

sustainability

statement/ Not

Material

Regulation (EU) 2022/2453

Template 1: Banking book –

Climate change transition

risk: Credit quality of

exposures by sector,

emissions and residual

maturity

ESRS E1-6

Gross GHG emissions intensity

paragraphs 53 to 55

Indicators number 3

Table #1 of Annex 1

Article 449a Regulation

(EU) No 575/2013;

Commission Implementing

Regulation (EU) 2022/2453

Template 3: Banking book –

Climate change transition

risk: alignment metrics

Delegated Regulation

(EU) 2020/1818, Article

8(1)

[E1-6] Gross Scopes 1, 2,

3 and Total GHG

emissions

ESRS E1-7

GHG removals and carbon

credits paragraph 56

Regulation (EU)

2021/1119, Article 2(1)

Not material

ESRS E1-9

Exposure of the benchmark

portfolio to climate-related

physical risks paragraph 66

Delegated Regulation

(EU) 2020/1818, Annex

II Delegated Regulation

(EU) 2020/1816, Annex

N/A (Utilization of the

Phase-In provision)

ESRS E1-9

Disaggregation of monetary

amounts by acute and chronic

physical risk paragraph 66 (a)

ESRS E1-9

Location of significant assets at

material physical risk

paragraph 66 (c).

Article 449a Regulation

(EU) No 575/2013;

Commission Implementing

Regulation (EU) 2022/2453

paragraphs 46 and 47;

Template 5: Banking book -

Climate change physical

risk: Exposures subject to

physical risk.

N/A (Utilization of the

Phase-In provision)

ESRS E1-9 Breakdown of the

carrying value of its real estate

assets by energy-efficiency

classes paragraph 67 (c).

Article 449a Regulation

(EU) No 575/2013;

Commission Implementing

Regulation (EU) 2022/2453

paragraph 34; Template

2:Banking book -Climate

change transition risk:

Loans collateralized by

immovable property -

Energy efficiency of the

collateral

[E1-9] Anticipated

financial effects from

material physical and

transition risks and

potential climate-

related opportunities

ESRS E1-9

Degree of exposure of the

portfolio to climate- related

opportunities paragraph 69

Delegated Regulation

(EU) 2020/1818, Annex

N/A (Utilization of the

Phase-In provision)

ESRS E2-4

Amount of each pollutant listed

in Annex II of the E-PRTR

Regulation (European Pollutant

Release and Transfer Register)

emitted to air, water and soil,

paragraph 28

Indicator number 8

Table #1 of Annex 1

Indicator number 2

Table #2 of Annex 1

Indicator number 1

Table #2 of Annex 1

Indicator number 3

Table #2 of Annex 1

Not material

ESRS E3-1

Water and marine resources

paragraph 9

Indicator number 7

Table #2 of Annex 1

Not material

ESRS E3-1

Dedicated policy paragraph 13

Indicator number 8

Table 2 of Annex 1

Not material

ESRS E3-1

Sustainable oceans and seas

paragraph 14

Indicator number 12

Table #2 of Annex 1

Not material

ESRS E3-4

Total water recycled and

reused paragraph 28 (c)

Indicator number 6.2

Table #2 of Annex 1

Not material

ESRS E3-4

Total water consumption in

per net revenue on own

operations paragraph 29

Indicator number 6.1

Table #2 of Annex 1

Not material

ESRS 2- SBM-3 - E4 paragraph

16 (a) i

Indicator number 7

Table #1 of Annex 1

[SBM-3] Material

impacts, risks and

BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2024

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Disclosure Requirement and

related datapoint

SFDR Reference

Pillar 3 Reference

Benchmark Regulation

reference

EU Climate Law

Reference

Location in the

sustainability

statement/ Not

Material

opportunities and their

interaction with strategy

and business model

ESRS 2- SBM-3 - E4 paragraph

16 (b)

Indicator number 10

Table #2 of Annex 1

[SBM-3] Material

impacts, risks and

opportunities and their

interaction with strategy

and business model

ESRS 2- SBM 3 - E4 paragraph

16 (c)

Indicator number 14

Table #2 of Annex 1

[SBM-3] Material

impacts, risks and

opportunities and their

interaction with strategy

and business model

ESRS E4-2

Sustainable land / agriculture

practices or policies paragraph

24 (b)

Indicator number 11

Table #2 of Annex 1

[E4-2] Policies related to

biodiversity and

ecosystems

ESRS E4-2

Sustainable oceans / seas

practices or policies paragraph

24 (c)

Indicator number 12

Table #2 of Annex 1

[E4-2] Policies related to

biodiversity and

ecosystems

ESRS E4-2

Policies to address

deforestation paragraph 24 (d)

Indicator number 15

Table #2 of Annex 1

[E4-2] Policies related to

biodiversity and

ecosystems

ESRS E5-5

Non-recycled waste paragraph

37 (d)

Indicator number 13

Table #2 of Annex 1

Not material

ESRS E5-5

Hazardous waste and

radioactive waste paragraph 39

Indicator number 9

Table #1 of Annex 1

Not material

ESRS 2- SBM-3 - S1

Risk of incidents of forced labor

paragraph 14 (f)

Indicator number 13

Table #3 of Annex I

[SBM-3] Material

impacts, risks and

opportunities and their

interaction with strategy

and business model

ESRS 2- SBM-3 - S1

Risk of incidents of child labor

paragraph 14 (g)

Indicator number 12

Table #3 of Annex I

[SBM-3] Material

impacts, risks and

opportunities and their

interaction with strategy

and business model

ESRS S1-1

Human rights policy

commitments paragraph 20

Indicator number 9

Table #3 and Indicator

number 11 Table #1 of

Annex I

[S1-1] Policies related to

own workforce

ESRS S1-1

Due diligence policies on issues

addressed by the fundamental

International Labor

Organisation Conventions 1 to

8, paragraph 21

Delegated Regulation

(EU) 2020/1816, Annex

[S1-1] Policies related to

own workforce

ESRS S1-1

processes and measures for

preventing trafficking in human

beings paragraph 22

Indicator number 11

Table #3 of Annex I

[S1-1] Policies related to

own workforce

ESRS S1-1

workplace accident prevention

policy or management system

paragraph 23

Indicator number 1

Table #3 of Annex I

Not material

ESRS S1-3

grievance/complaints handling

mechanisms paragraph 32 (c)

Indicator number 5

Table #3 of Annex I

[S1-3] Processes to

remediate negative

impacts and channels

for own workforce to

raise concerns

ESRS S1-14

Number of fatalities and

number and rate of work-

related accidents paragraph 88

(b) and (c)

Indicator number 2

Table #3 of Annex I

Delegated Regulation

(EU) 2020/1816, Annex

Not material

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Disclosure Requirement and

related datapoint

SFDR Reference

Pillar 3 Reference

Benchmark Regulation

reference

EU Climate Law

Reference

Location in the

sustainability

statement/ Not

Material

ESRS S1-14

Number of days lost to injuries,

accidents, fatalities or illness

paragraph 88 (e)

Indicator number 3

Table #3 of Annex I

Not material

ESRS S1-16

Unadjusted gender pay gap

paragraph 97 (a)

Indicator number 12

Table #1 of Annex I

Delegated Regulation

(EU) 2020/1816, Annex

Not material

ESRS S1-16

Excessive CEO pay ratio

paragraph 97 (b)

Indicator number 8

Table #3 of Annex I

Not material

ESRS S1-17

Incidents of discrimination

paragraph 103 (a)

Indicator number 7

Table #3 of Annex I

[S1-17] Incidents,

complaints and severe

human rights impacts

ESRS S1-17 Non-respect of

UNGPs on Business and Human

Rights and OECD Guidelines

paragraph 104 (a)

Indicator number 10

Table #1 and Indicator n.

14 Table #3 of Annex I

Delegated Regulation

(EU) 2020/1816, Annex

II Delegated Regulation

(EU) 2020/1818 Art 12

(1)

[S1-17] Incidents,

complaints and severe

human rights impacts

ESRS 2- SBM-3 – S2

Significant risk of child labor or

forced labor in the value chain

paragraph 11 (b)

Indicators number 12

and n. 13 Table #3 of

Annex I

Not material

ESRS S2-1

Human rights policy

commitments paragraph 17

Indicator number 9

Table #3 and Indicator

n. 11 Table #1 of Annex

Not material

ESRS S2-1 Policies related to

value chain workers paragraph

Indicator number 11 and

n. 4 Table #3 of Annex 1

Not material

ESRS S2-1 Policies related to

value chain workers paragraph

Indicator number 11 and

n. 4 Table #3 of Annex 1

Not material

ESRS S2-1 Non-respect of

UNGPs on Business and Human

Rights principles and OECD

guidelines paragraph 19

Indicator number 10

Table #1 of Annex 1

Delegated Regulation

(EU) 2020/1816,

Annex II Delegated

Regulation

(EU) 2020/1818, Art 12

(1)

Not material

ESRS S2-1

Due diligence policies on issues

addressed by the fundamental

International Labor

Organisation Conventions 1 to

8, paragraph 19

Delegated Regulation

(EU) 2020/1816,

Annex II

Not material

ESRS S2-4

Human rights issues and

incidents connected to its

upstream and downstream

value chain paragraph 36

Indicator number 14

Table #3 of Annex 1

Not material

ESRS S3-1

Human rights policy

commitments paragraph 16

Indicator number 9

Table #3 of Annex 1 and

Indicator number 11

Table #1 of Annex 1

Not material

ESRS S3-1

non-respect of UNGPs on

Business and Human Rights,

ILO principles or OECD

guidelines paragraph 17

Indicator number 10

Table #1 Annex 1

Delegated Regulation

(EU) 2020/1816,

Annex II Delegated

Regulation

(EU) 2020/1818, Art 12

(1)

Not material

ESRS S3-4

Human rights issues and

incidents paragraph 36

Indicator number 14

Table #3 of Annex 1

Not material

ESRS S4-1 Policies related to

consumers and end-users

paragraph 16

Indicator number 9

Table #3 and Indicator

number 11 Table #1 of

Annex 1

[S4-1] Policies related to

consumers and end-

users

ESRS S4-1

Non-respect of UNGPs on

Business and Human Rights

and OECD guidelines paragraph

Indicator number 10

Table #1 of Annex 1

Delegated Regulation

(EU) 2020/1816, Annex

II Delegated Regulation

(EU) 2020/1818, Art 12

(1)

[S4-1] Policies related to

consumers and end-

users

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Disclosure Requirement and

related datapoint

SFDR Reference

Pillar 3 Reference

Benchmark Regulation

reference

EU Climate Law

Reference

Location in the

sustainability

statement/ Not

Material

ESRS S4-4

Human rights issues and

incidents paragraph 35

Indicator number 14

Table #3 of Annex 1

[S4-4] Taking action on

material impacts on

consumers and end-

users, and approaches

to managing material

risks and pursuing

material opportunities

related to consumers

and end-users, and

effectiveness of those

actions

ESRS G1-1

United Nations Convention

against Corruption paragraph

10 (b)

Indicator number 15

Table #3 of Annex 1

[G1-1] Business conduct

policies and corporate

culture

ESRS G1-1

Protection of whistle- blowers

paragraph 10 (d)

Indicator number 6

Table #3 of Annex 1

[G1-1] Business conduct

policies and corporate

culture

ESRS G1-4

Fines for violation of anti-

corruption and anti-bribery

laws paragraph 24 (a)

Indicator number 17

Table #3 of Annex 1

Delegated Regulation

(EU) 2020/1816, Annex

II)

[G1-4] Incidents of

corruption or bribery

ESRS G1-4

Standards of anti- corruption

and anti- bribery paragraph 24

(b)

Indicator number 16

Table #3 of Annex 1

[G1-4] Incidents of

corruption or bribery

The list of ESRS Disclosure Requirements complied with in preparing sustainability statement following the outcome of the double materiality

assessment can be found under [IRO-2] Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement.

ENVIRONMENTAL INFORMATION

Disclosures pursuant to Article 8 of Regulation 2020/852 (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.

According to the Regulation (EU) 2020/852 (EU Taxonomy), the term “eligible” is used for economic activities included in the abovementioned

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.

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Additionally, the Commission adopted Delegated Regulation (EU) 2021/2178 of 6 July 2021 ("Disclosures Delegated Act"), which

supplements Article 8 of the EU Taxonomy Regulation and outlines the required content and format for information disclosure

by companies under Articles 19a or 29a of Directive 2013/34/EU. It also details the methodology for fulfilling the disclosure

requirements related to environmentally sustainable economic activities.

On July 15, 2022, a Complementary Climate Delegated Act (EU) 2022/1214 was published in the Official Journal of the EU,

expanding the Taxonomy framework to include specific nuclear and gas energy activities under strict conditions

(“Complementary Climate Delegated Act”).

TABLE 31 SUMMARY OF KPIS TO BE DISCLOSED BY CREDIT INSTITUTIONS UNDER ARTICLE 8 TAXONOMY REGULATION

* For credit institutions that do not meet the conditions of Article 94(1) of the CRR or the conditions set out in Article 325a(1) of the CRR

**Fees and commissions income from services other than lending and AuM

Institutions shall disclose forward-looking information for this KPIs, including information in terms of targets, together with relevant explanations on the methodology applied.

*** % of assets covered by the KPI over banks´ total assets

****based on the Turnover KPI of the counterparty

*****based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used

Implementation in business strategy, product design processes and engagement with clients and counterparties

The Group seeks to increase its positive effect on society and the environment, utilizing new business opportunities and generating value for all

stakeholders. Through its SFF, the Group 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.

Approach for Taxonomy eligibility and alignment assessment

The information presented follows the requirements described in Article 7 and Article 10 of the Disclosures Delegated Act. 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

Total

environmentally

sustainable

assets****

Total

environmentally

sustainable

assets*****

KPI****

KPI*****

% coverage

(over total

assets)***

% of assets

excluded

from the

numerator of

the GAR

(Article 7(2)

and (3) and

Section 1.1.2.

of Annex V)

% of assets

excluded from

the

denominator of

the GAR

(Article 7(1)

and Section

1.2.4 of Annex

Main KPI

Green asset

ratio (GAR)

stock

914

1,512

1.7%

2.8%

77.2%

54%

23.8%

Total

environmentally

sustainable

assets****

Total

environmentally

sustainable

assets*****

KPI

% coverage

(over total

assets)

% of assets

excluded

from the

numerator of

the GAR

(Article 7(2)

and (3) and

Section 1.1.2.

of Annex V)

% of assets

excluded from

the

denominator of

the GAR

(Article 7(1)

and Section

1.2.4 of Annex

Additional

KPIs

GAR (flow)

195

463

11.1%

19.6%

Trading book*

N/A

Financial

guarantees

Assets under

management

Fees and

commissions

income**

N/A

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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 sustainability 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.

TheGroup 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.

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 Complementary Climate Delegated Act, 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 second year of alignment reporting, and most of the financial undertakings

have not yet published their 2024 annual reports. Non-financial undertakings have not published taxonomy information yet for 2024, thus the

Taxonomy reporting of alignment for non-financial undertakings is based on data publicly available from 2023. Additionally, information on

taxonomy-eligibility for the four environmental objectives implemented in 2024 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.

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 CSRD

requirements and the continuous amendments on Taxonomy regulation, the 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.

ESRS E1 CLIMATE CHANGE

[E1-1] Transition plan for climate change mitigation

Alpha Services and Holdings Group recognized early the importance of aligning its efforts to supporting the transition to a sustainable

economy. Since 2022 it has incorporated sustainable criteria in its lending processes through the issuing of a SFF, applied at Group level. The

SFF incorporates environmental and social credentials in lending activities and stipulates the decision and classification process that the Group

implements to classify its financial products and services as sustainable.

Alpha Services and Holdings acknowledges the importance of the effective integration of its sustainable finance strategy throughout the Group

activities and operations. Thus, the Group has built a wide-range SFF governance model which is based on a dynamic structure and aims to

ensure an effective decision-making and execution process regarding sustainable financing.

Alpha Bank joined in 2023 the UN-convened Net Zero Banking Alliance (NZBA), formally committing to net zero greenhouse gas emissions by

2050. This undertaking reflects the Bank’s societal responsibility, as a leading financial institution in Greece, to help mitigate climate change

and drive the transition to a net zero economy.

As part of its commitment to environmental stewardship, the Group has developed a comprehensive strategy to achieve net zero emissions,

focusing on the following key actions:

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• Reducing financed emissions: The Group sets climate targets at the sector level to decarbonize its lending and investment portfolio

to net zero by 2050, effectively steering capital to support meeting the 2030 Paris Agreement goals and accelerating the real

economy transition.

• Reducing operational emissions: The Group implements energy-efficiency measures across all Branches, offices, and data centers to

reduce its carbon footprint. This includes using electricity from renewable energy sources, optimizing energy consumption, and

adopting sustainable practices in day-to-day Group operations.

• Financing sustainable projects: The Group allocates capital to Green and Social investments, in line with its SFF, with emphasis on

renewables, green buildings and clean transportation. Through sustainable financing, the Bank aims to accelerate the transition to an

environmentally sustainable and resilient economy.

• Engaging Customers: The Group supports its Customers transition to a low carbon economy, offering advice and flexible financing

solutions while facilitating access to funding, via tools like the EU Resilience and Recovery Facility and the Hellenic Development

Bank.

• Zero financing: The Group is committed to zero financing to new investments in thermal coal mining, coal-fired electricity generation

and upstream oil exploration - extraction through the exclusion list that determines specific activities, which are not allowed to be

financed.

• Foster partnerships: The Group works with different partners to improve its clients’ awareness and understanding of financing

solutions and provide an effective ecosystem to enable the transition.

• Collaboration and advocacy: The Group actively engages with its stakeholders, aiming to increase awareness and foster sustainable

practices to the entire spectrum of financial and social activity.

As part of the commitment to supporting the transition to a more sustainable economy, the Group decided to set ambitious goals. As such, the

target for sustainable disbursements has been updated and the Group has planned to lend Euro 4.4 billion in sustainable disbursements during

2024-2026.

• The main focus will be in the Power sector (solar, wind, grid upgrading, etc.), buildings (energy efficiency, upgrades, heat insulation,

certification) and transportation (electric vehicles, alternative fuels).

• It is anticipated that sustainability linked loans will be also a key part of the total sustainable lending, providing financial incentives

for companies to meet Sustainability Performance Targets (SPTs) and accelerate their decarbonization.

As shared within the ESRS 2, part of the Group’s strategy for climate change mitigation and adaptation is the publication within 2025 of a

detailed transition plan, setting out planned actions to meet its 2030 emissions targets.

To align with the NZBA overarching principles of setting and disclosing long-term and intermediate targets to support meeting a net zero by

2050 greenhouse gas emissions goal, the Group has announced a first-round of sector targets across its lending and investment portfolios.

The process followed key steps:

1. Establishing an Emissions Baseline: The Group established an emissions baseline by completing a comprehensive measurement of its

financed emissions for 2022, covering investment and lending portfolios, across all financed sectors. The asset class coverage

included on-balance sheet exposures in Listed and Unlisted Equity, Corporate Bonds, Sovereign Bonds, Corporate Loans, Commercial

Real Estate (CRE), Residential Real Estate (RRE), Motor-Vehicle Loans and Project Finance. SMEs were excluded from the initial

perimeter for target setting. The baseline measurement relied on the GHG emissions of its borrowers or investee companies and

followed the Global Greenhouse Gas (GHG) Accounting and Reporting Standard for the Financial Industry developed by the PCAF.

2. Focusing on Carbon-Intensive Sectors: As a second step, the target setting exercise focused on the financed emissions within the

carbon-intensive sectors recommended by the NZBA. The sectors identified by the NZBA: agriculture, cement, coal, commercial and

residential real estate, iron and steel, oil and gas, power generation and transport were mapped to internationally recognized sector

classification codes applied by the Group.

3. Prioritizing Key Sectors for Target Setting: the Group prioritized setting targets for the Power Generation, Oil and Gas, Cement and

Iron and Steel sectors, taking into consideration each sector’s materiality based on the financed emissions measurement,

outstanding exposure, sectoral contribution to Greece’s emissions, the availability of credible sectoral target-setting guidance, data

quality and availability, as well as the market practice.

4. Selecting the Value Chain: For each of the four priority sectors, the Group selected the parts of the sector’s value chain that are most

material to the Group by exposure and financed emissions, and in which the Bank’s clients have the most control over their

emissions. After accounting for the appropriate value chain, these sectors correspond to ~15% and ~54% of Bank’s outstanding

exposure and financed emissions, respectively, of the sectors in scope for the NZBA.

The targets are compatible with limiting global warming to 1.5C degrees because they employ the widely used, science-based International

Energy Agency Net Zero Emissions by 2050 (IEA NZE) scenario as its benchmark pathway.

Alpha Services and Holdings recognizes the important role of financial institutions in mobilizing capital towards environmentally sustainable

activities and in supporting their clients’ transition to a low-carbon economy. The SFF serves as a key enabler to deliver the sustainable finance

strategy of the Group by financing climate mitigation projects.

Loyal to its commitment towards the support of an environmentally sustainable economy and to mitigate climate change, the Group has an

ambitious plan, with the main decarbonization levers being the increase in Sustainable Financings and the reduction of financings that may

have a negative impact on climate and the environment. Additionally, the Group has developed policies and procedures to reduce its

operational environmental footprint with the overarching aim being net-zero emissions and setting targets associated with this objective.

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Alpha Services and Holdings actively participates in the global effort to build a sustainable future for the economy and the planet. The Group’s

strategy is to align all material elements of the loan and (on balance sheet) investment portfolio with a Science-Based 1.5C pathway, based on

the International Energy Agency Net Zero Emissions (IEA NZE) Scenario, adapted to the Bank’s portfolio composition and national

characteristics as they apply. The first set of sectors for which targets have been set are Power Generation, Oil and Gas, Iron and Steel and

Cement. These sectors constitute over ~64%

of the Bank’s outstanding financed emissions, of the sectors in scope for the NZBA. The metrics

selected for targets are Carbon Intensity metrics for all the above sectors, except for Oil and Gas for which absolute emissions have been used.

The remaining material carbon-intensive sectors will be included in a subsequent round of target-setting within 2025 in accordance with the

NZBA guidelines and in line with the goals of the Paris Agreement (containing global temperature rise to 1.5C and no more than 2C), as well as

EU Law, Regulation and Policy (fit-for-55, EU Green Deal). Some sectors may be excluded from target setting due to either methodological

limitations and/or due to their limited materiality to the Bank's portfolio.

The Group underscores its dedication to sustainability through clear and measurable targets, in line with achieving Net-Zero emissions by

2050. This commitment reinforces its role as a leader in driving positive change both within the financial sector and across broader societal

frameworks.

To support the transition to an environmentally sustainable economy and address climate change, the Group has developed an ambitious

strategy. Its primary focus is to increase sustainable financing while reducing financing that could negatively impact the environment.

The Group channels its investments into key areas, including:

• Environmental initiatives (Renewable Energy Sources, Waste Management);

• Other Energy Projects and Distribution Networks;

• Major Infrastructure Projects.

As a financial institution, the Group does not have any significant CapEx / OpEx expenditure on climate purposes, as these expenditures

constitute a small fraction compared to its lending and investing portfolio.

Relevant KPIs for financial institutions as required by Article 8 of the EU Taxonomy Regulation consist of the Green Asset Ratio (GAR) calculated

over the stock and flow of its balance sheet as listed in the table below:

Before exclusions on segments on value chain covered and SMEs

Excluding shipping financed emissions

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As of year-end 2024, Alpha Bank's taxonomy eligibility ratio for CCM and CCA was 17.57% (turnover-based).

GAR calculations include loans, advances, and securities linked to aligned activities, excluding exposures such as central government assets,

trading securities, and non-NFRD entities. Challenges in alignment reporting remain due to data limitations, particularly for off-balance-sheet

exposures and household flows.

The Group is not excluded from the EU Paris Agreement on climate change and the National Net-Zero emissions target for 2050. The majority

of the Bank's counterparties do not yet disclose information on their corresponding revenue split per sector of economic activity. To overcome

this limitation, the NACE code of the counterparty's principal activity has been used to identify exposures towards companies excluded from

EU Paris-aligned Benchmarks. The following NACE codes have been selected for this purpose: 0510, 0520, 0610, 0620, 1920, 3511, 3521, 3522,

3523, 4671, 4730, 1910, 0910, 4950. Regarding NACE sector D35, the exposures towards Renewable Energy Sources haven’t been considered

in PAB exclusions.

Non-performing status for exposures is fully aligned with the new Definition of Default regulatory guidelines and Stage 3 classification

according to the IFRS9 accounting standard. Stage 2 exposures have been defined according to the IFRS9 accounting standard and exclude

POCI loans.

Exposures have been allocated to maturity buckets according to the remaining maturity of the relevant financial instrument. The contractual

maturity has been used for term loans whereas the IFRS9 behavioral maturity has been used for revolving loans, open loans and credit cards. A

perpetual maturity has been applied for equities (set to 21yrs for weighting calculation purposes). Average maturity has been calculated by

weighing the maturity of each exposure by the gross carrying amount of the exposures.

[E1.SBM-3] Material impacts, risks and opportunities related to Climate Change and their interaction with strategy and

business model

Climate related-risks

Regarding climate-related risks, the Group performs materiality assessment separately for Transition and Physical Risks.

In accordance with the scientific literature and regulatory guidance the Group acknowledges that transition risks are the risks of any negative

financial impact on the institution, stemming from the current or prospective impacts of the transition to an environmentally sustainable

economy on its counterparties or invested assets. The following transition risk sub-types are considered for the materiality assessment of

transition risk: policy and legal, market, reputation and technology.

Physical risks are the risks 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 invested assets. They are categorized either as acute - if they arise from particular

extreme events, or chronic - if they arise from progressive shifts in climate and weather patterns or a gradual loss of ecosystem services.

Detailed information on the Group qualitative materiality assessment for transition and physical risk sub-types, is provided under [IRO-1]

Description of the process to identify and assess material impacts, risks and opportunities.

Resilience analysis

Transition Risks

As described under [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model, the Group has

performed an assessment to identify sectors sensitive to transition risk, while for those sectors lying within the transition risk sensitive

perimeter a risk assessment has been performed under different time horizons. The scale of the transition risk is defined by combining the

outcome of the Likelihood (the probability of occurrence within a provided time horizon) and the Impact analysis (the extent to which the

impact, if occurred, would affect the business). In order to estimate the likelihood of the transition risks more recent literature scenarios,

strategic plans and roadmaps were used, to qualitatively estimate the probability of occurrence of each transition risk driver, as explicitly

described under [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities. The analysis covers the

Group’s Non-Financial Corporate portfolio.

Physical Risks

Regarding physical risk, the Group performs an assessment based on IPCC AR5 RCP 8.5 for 2025, 2030 and 2050 horizons.

More specifically, as described under data point [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and

business model, the Bank has laid down a methodology based on sensitivity and exposure analysis to derive vulnerability to physical risk

factors. Vulnerability analysis is performed to identify potential significant hazards per subsector covered by the analysis for Business portfolio,

as well as across the different geographic regions where real estate properties used as collateral extend.

Sensitivity Analysis

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The aim of the sensitivity analysis is to identify which climate hazards are relevant to the specific economic activity, which includes several

types of assets, irrespective of its location. By 2050, most of the sectors are expected to be more resilient due to increased adaptation

measures resulting in lower sensitivity compared to 2025 and 2030.

Exposure Analysis

The aim of the exposure analysis is to identify which hazards are relevant to the asset’s location, irrespective of the asset’s sector or type.

Climate model projections can be used to understand how the level of exposure may change in the future. For the assessment of exposure to

future conditions, climate projections for the hot-house scenario of IPCC AR5 RCP 8.5 with a horizon of 2025, 2030 and 2050 for the business

portfolio on a country level, and horizons of 2030 and 2050 for the RE portfolio on a NUTS3 level, are taken into consideration.

More details regarding the exposure analysis and the scenarios utilized, may be found under [IRO-1] Description of the process to identify and

assess material impacts, risks and opportunities.

ICAAP climate scenarios

In the context of the Internal Capital Adequacy Assessment Process (ICAAP Report) the Group, aligned with International best practices and

has developed climate risk-specific methodologies to estimate the impact of transition on credit risk across different time horizons (medium

and long term) by making use of leading global macroeconomic and sectoral models. Additional characteristics such as buildings’ energy

efficiency, geographic and counterparty level characteristics are also incorporated in the estimation to further account for heterogeneity of

impacts inherent in climate risks. These are examined as stand-alone climate scenarios and used under both the Economic and Normative

perspective. Where applicable these scenarios are also applied on operational risk and business and strategic risks considering the relevant risk

materiality assessment that has been performed.

The resilience analysis has been performed by the Bank, with reference date 31.12.2024.

For financial materiality purposes, the Group has defined the time horizons in alignment with CSRD guidance. More information is provided

under section “Climate-related impacts, risks and opportunities”.

The Group, in order to estimate the anticipated financial effect for transition risk, leverages on the outcome of the materiality assessment

performed that takes into consideration the factors described under [SBM-3] Material impacts, risks and opportunities and their interaction

with strategy and business model and [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

The results of the materiality assessment performed are illustrated in the table below:

TABLE 31 ANTICIPATED FINANCIAL EFFECT FOR TRANSITION RISK (CLIMATE CHANGE MITIGATION)

Anticipated Financial Effect

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Climate change mitigation

Not material

Material

As shown on the above table, the anticipated financial effect is found to be material on an inherent level basis in the medium- and long-term

horizons, considering that the percentage of the Group’s exposures towards sectors sensitive to transition risk over the total Group Assets

exceeds the established materiality threshold. In the short-term horizon, the anticipated financial effect is found to be below the established

materiality threshold and, therefore, considered not material.

Information on materiality thresholds used to characterize transition risk as material can be found under [IRO-1] Description of the process to

identify and assess material impacts, risks and opportunities.

In addition, the Group, in order to estimate the anticipated financial effect for physical risk, leverages on the outcome of the materiality

assessment performed that takes into consideration the vulnerability assessment outcome per sector and region and the Group’s exposures

towards sectors and regions with High, Medium and Low vulnerability assessment outcomes. The vulnerability assessment outcome is

considered as a proxy for the likelihood of occurrence.

The results of the resilience analysis performed are illustrated in the table below:

TABLE 32 ANTICIPATED FINANCIAL EFFECT FOR PHYSICAL RISK (CLIMATE CHANGE ADAPTATION)

Anticipated Financial Effect

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Climate change adaptation

Not material

Material

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As shown on the table above, in the short-term horizon, the anticipated financial effect is found to be below the established materiality

threshold and, therefore, it is considered not material. In the medium- and long-term horizons the anticipated financial effect is found to be

material on an inherent level basis, considering that for some physical risk factors (e.g., wildfire in case of the regional analysis and floods in

case of sectoral analysis) the anticipated occurrence is relatively high.

Information on materiality thresholds used to characterize physical risk as material can be found under [IRO-1] Description of the process to

identify and assess material impacts, risks and opportunities.

Alpha Services and Holdings Group actively participates in the global effort to build a sustainable future for the economy and the planet. In this

context, the Bank joined the UN-convened Net Zero Banking Alliance (NZBA), committing to net zero greenhouse gas emissions by 2050. This

reflects the Group’s societal responsibility, as a leading financial institution in Greece, to help mitigate climate change and drive the transition

to a Net-Zero economy. As part of its commitment to environmental stewardship, the Group focuses on reducing operational emissions,

supporting its Retail and Wholesale Customers transition to a low carbon economy, increasing awareness and foster sustainable practices to

the entire spectrum of financial and social activity.

Further, the Group continues to implement the ESG Workplan, additional details which may be found under [SBM-3] Material impacts, risk and

opportunities and their interaction with strategy and business model.

This has resulted in increased portfolio of green loans and investments, supporting projects that contribute to renewable energy and

sustainable economy. In line with the SFF, the Group allocates capital to Green and Social investments, with emphasis on the power

generation sector, buildings and transportation. Through sustainable financing, the Group aims to support the development of low-carbon

infrastructure and accelerate Greece’s transition to an environmentally sustainable and resilient economy.

Taking the above into account, along with the lack of any significant risk impacting access to funding in the bond markets, the Group reflects

the trust of its counterparties, borrowers, and investors in its ability to adapt its strategy and business model to address climate change over

the short, medium, and long term.

[E1-2] Policies related to climate change mitigation and adaptation

The Group adopts a proactive approach to the management of ESG risks, with particular emphasis placed on risks arising from climate and

environmental change, which is already a key component of its Risk Management. More specifically, it aims to:

• Support Customers’ decarbonization and the alignment of their portfolio emissions with the objectives set in the Paris Agreement.

• Invest in activities dealing with climate change and reduction of environmental effects from the Group’s operation.

• Support the development of sustainable solutions for cities and communities.

Environmental Risk Management Policy on Legal Entities Lending

The Group is committed to sustainable finance, including the effective management of the Environmental dimension of its lending activities.

To this direction, during the credit approval process, supplementary to the credit risk assessment, the strict compliance of the principles of an

environmentally and socially responsible credit facility are also examined, as those are defined in the “Group Environmental and Social Risk

Management Policy on Legal Entities Lending” which is in place since 2016. The main purpose of the E and S Risk Management Policy is to

provide the appropriate guidance, roles, perimeter, conditions, credit rules and tools in order to identify, manage, avoid, minimize, offset the

risks arising from the business operations of the clients-Legal Entities that may be connected with a damage to the environment, or with any

direct threat of such a damage, having as a result a negative impact on the business operations and financial results of the Group as a whole.

Key principles and requirements:

• Definition of critical sectors that are connected with potential climate and ESG risks. In particular, definition of the Industry specific

Exclusion List, i.e., a list of activities that the Group does not finance, and the Climate Policy Relevant Sectors’ List, which is a

classification of economic activities in terms of transition risk assessment.

• The applicable national and international laws and regulations on climate, environment, society and governance and relevant

standards established with the Policy.

• The definition and implementation of climate and ESG risks assessment and monitoring procedures including ESG assessment at

obligor, transaction and overall level in accordance with the provisions of the relevant Credit Policy Manuals, the due diligence

conduction, the guidelines on the performance standards of the European Bank for Reconstruction and Development (EBRD), the

screening guidelines of the performance standards as well as the national and EU laws and regulations.

• Monitor and Control of the ESG Obligor’s/ Project’s performance.

• Managing Obligor’s/ Project’s Non-Compliance with the Policy Rules and Standards.

• Annual Reporting to stakeholders (EBRD).

Among the main responsibilities of the Credit Risk Policy and Control Business Area are to:

• Developing and updating the Policy in collaboration with the competent Units, taking into account the regulatory framework, the

international best practices and any current developments.

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• Monitoring the implementation of the Policy, conducting credit controls and notification of the Credit Risk Committee which is

responsible for its approval, the General Manager – Chief Risk Officer (CRO), the Chief Risk Control Officer and Senior Management

on the significant arising issues.

•

ESG in Loan Origination

In 2024, the Group enhanced its credit assessment process according to the "Climate related, Environmental, Social and Governance Risk

Management Policy on Group’s Business Lending", “Retail Banking Credit Policy Small Businesses” and “Wholesale Banking Credit Policy”,

incorporating additional dimensions of climate related and governance risks. The main amendments concern ESG assessment, which is more

holistic and is carried out at obligor, transaction and overall level per transaction. More specifically:

• ESG assessment at obligor level is based on specific inter-banking client ESG questionnaires sectoral or cross sectoral,.,

completed by the Clients. The answered questionnaires are scored via internal rating models and the outcome of the

assessment may be Low, Medium or High ESG risk. The Bank has rolled out a bottom-up process, at the obligor level, which is

used to evaluate the performance of each obligor around ESG topics and better inform the credit origination processes in place.

This process embeds a materiality assessment, through which the Bank concluded environmental and social topics for several

economic sectors in its portfolio. Through the questionnaires climate-related information is captured (e.g., emissions data,

energy consumption data etc.).

• 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 rated and classified as Low, Medium, or High ESG risk. 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 (i.e.

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.

• ESG overall assessment which 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.

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. This effort aims to ensure obligors' compliance with the Group's Environmental and Social (E and S)

requirements. The Group aims to finance its counterparties’ green/sustainable transition both in the short-and in the long-term. In this respect

the Group collaborates with High-Risk Obligors to develop an action plan outlining a timeframe and appropriate mitigation measures, while in

the case of new lending investment nature Medium and High-Risk transactions an on-site visit is conducted by specialists. Also, with the aim to

mitigate reputational risks, the Group has designed a robust process that involves identifying and assessing the potential participation of its

Obligors in controversial activities. Additionally, as a mitigating action to physical risk impact, the mandatory property insurance securing new

financing that is provided to the Bank also includes the risk of flooding.

Reputational Risk Policy

The Group has developed the Reputational Risk Policy to effectively manage its reputational risk exposures, including reputational risk

exposures stemming from ESG factors. In this context, the processes that may arise are presented below: By financing Obligors who are

involved in Controversial Activities. This reputational risk exposure is assessed and is taken into account in the Credit Approval process. By

initiating new activities, such as Bond Issuing, Investment Banking activities, Public Offerings, Outsourcing Arrangements, new Suppliers, new

partners or step-ins, new investors or new services / fees charges to the Bank’s clientele. From existing activities, such as Obligors (regular

review), existing Outsourcing Activities (annual review), existing Suppliers, etc.

Sustainable Finance Framework

The Sustainable Finance Framework (“SFF” or “the framework”) which is in place since 2023 can be defined as a guide that sets out a series of

approaches and procedures required for classifying financing as sustainable. Specifically, the framework stipulates the decision and

classification process, that the Group implements, to categorize its financial products or services as sustainable (i.e., green, or social). The main

purpose of the framework is to enable the identification and categorization of sustainable activities and to lay out the criteria to characterize

specific loans as sustainable. The SFF is published on the Group’s website.

Remuneration Policy for the Members of the Board of Directors

The Group integrates ESG-related considerations into its Remuneration Policy, reflecting its commitment to environmental stewardship and

sustainability. Additionally, variable remuneration incorporates criteria linked with climate-related and environmental goals, in alignment with

the actions and initiatives that the Group is developing, including: Financial objectives on Sustainable Finance lending volumes C&E Risk

management framework implementation Objectives aiming to improvement the availability of client ESG data ESG (including C&E) Risk

Training objectives Sustainable Finance Training objectives. The 2024 Remuneration Policy can be accessed on the Group’s website and will be

in the 2024 Remuneration report.

Exclusion list

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As part of the abovementioned policies, the Group applies, maintains, and updates an exclusion list that determines specific activities, which

are not allowed to be financed. This is applicable to all business lending obligors across all geographies and industry sectors. The criteria for

exclusion span across various environmental and social matters. Specifically, the Group does not finance the following activities:

• The production of or trade in any product or activity deemed illegal under host country (i.e. national) laws or regulations or

international conventions and agreements or subject to international phase out or bans, such as PCBs, ozone depleting substances,

trade in wildlife etc.

• Production or trade in weapons and munitions.

• Production or trade in alcoholic beverages (excluding beer and wine).

• Production or trade in Tobacco, Gambling, Casinos and equivalent enterprises. The funding of these activities is permissible on a

combined basis up to 5% of the total loan portfolio.

• Production or trade in radioactive materials. This does not apply to the purchase of medical equipment, quality control

(measurement) equipment and any equipment where the radioactive source is considered to be trivial and/or adequately shielded in

accordance with international practices.

• Forced evictions.

• New investments in thermal coal mining or coal-fired electricity generation capacity.

• Upstream oil exploration - extraction and production.

• Upstream oil development projects, except in rare and exceptional circumstances where the proceeds of the project exclusively

target the reduction of GHG emissions or flaring from existing producing fields.

• Activities involving force-feeding of ducks and geese.

• The keeping of animals for the primary purpose of fur production or any activities involving fur production.

• The manufacture, placing on the market and use of asbestos fibers and of articles and mixtures containing these fibers added

intentionally. This does not apply to purchase and use of bonded asbestos cement sheeting where the asbestos content is less than

20%.

• The export of mercury and mercury compounds and the manufacture, export and import of a large range of mercury-added

products.

• Activities prohibited by host country legislation or international conventions relating to the protection of biodiversity resources or

cultural heritage.

• Drift net fishing in the marine environment using nets in excess of 2.5 km in length.

• Shipment of oil or other hazardous substances in vessels, which do not comply with International Maritime Organization (ΙΜΟ)

requirements.

• Trade in goods without required export or import licenses or other evidence of authorization of transit from the relevant countries of

export, import and, if applicable, transit.

• Conversion of natural forests into plantation.

• Wholesale and retail trade of thermal coal.

• Construction of new nuclear power plants. The Group will continue to consider funding for safety improvements of operating plants

as well as for radioactive waste management and decommissioning of nuclear facilities.

• Any activity involving degradation, conversion or destruction of the UNESCO World Heritage Sites.

• Any activity involving significant degradation, conversion or destruction of the sites included in the Natura map.

• Health technology activities relevant to human cloning for research or therapeutic purposes and genetically modified

organisms/food.

• Customers who are involved in violations of human rights, according to the United Nations’ “Universal Declaration of Human Rights”.

As of January 1, 2024, the Group has expanded its Exclusion List to encompass additional activities with environmental 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.

Monitoring Process

The BoD supervises and approves the ESG objectives and commitments of the abovementioned policies, and it has the oversight of the Group

risk management framework. Within this context, the BoD reviews the risk management strategy, delegates authorities to Committees and

Senior Management for implementing the risk management strategy, reviews the overall risks assumed under the delegated authorities,

provides guidelines, and ratifies the Group’s risk appetite.

One of those committees is the Group Sustainability Committee (GSC) which was established in November 2021 to approve and oversee the

sustainability strategy and to steer all related initiatives. The Committee takes cognizance of and decides upon Sustainability and ESG-related

matters to ensure an internal governance framework that allows the Group to manage ESG risks and consider all sustainability topics. GSC

membership includes six General Managers as permanent members and 8 additional members at the General Manager or senior executive

level. During 2024, the committee met 8 times, highlighting Management’s commitment to enhancing the Group’s sustainability position. The

Group Sustainability Committee’s agenda covered a range of topics, including progress of the Group’s ESG Action Plan, risk identification and

materiality assessment of Climate Risk, the SFF operationalization, updated Policy documents, as well as key disclosures and regulatory

submissions. The role of the Group ESG Coordinator was also established, to lead sustainability initiatives and steer operational teams on

implementation.

Implementation of climate-related policies

In the context of ESG and Climate Risk Governance, Alpha Services and Holdings Group has implemented a comprehensive structure,

addressing relevant decision making and implementation at all levels, from the BoD down to the operational level.

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The BoD approves and oversees the implementation of the Group’s strategic objectives, risk strategy, ESG strategy and internal governance.

The overall Organizational Structure for supervising and managing the implementation of the climate-related objectives, strategy, and policies,

is presented in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities and [SBM-2] Interests and views

of stakeholders.

With reference to the Climate, ESG Risk Policy for Group’s Business Lending, Credit Risk Policy and Control Division is responsible among

others of monitoring the implementation of the Policy, conducting credit controls and notification of the Credit Risk Committee, the General

Manager – Chief Risk Officer (CRO), the Chief Risk Control Officer and Senior Management on the significant arising issues; Informing third

parties/stakeholders (European Bank for Reconstruction and Development - EBRD through the EBRD Office) on issues relevant to the Policy

(financing of projects included in the Referral List) (Appendices 2 and 3); Communicating with the competent Group Units to ensure the proper

comprehension of the principles and rules set out in this Policy.

The Climate, ESG Risk Policy for Group’s Business Lending is established according to the regulatory framework, including but not limited to the

Greek and EU legislation, the guidelines of the European Central Bank (ECB), of the European Banking Authority (EBA), as well as other

international guidelines and best practices.

Stakeholder engagement for policy setting and implementation

Development of the Group’s policies has been largely informed and shaped by the climate-related interests of stakeholders across our entire

value chain, as these were identified an assessed through direct and indirect engagement with a broad range of stakeholders.

Policies with relevance to external stakeholders are publicly available while policies with internal use are available to the Group’s intranet.

As previously mentioned, the Group has adopted policies to manage ESG risks, including climate change-related risks. However, policies are

not particularly dedicated to a specific area, as they are defined in ESRS (i.e. climate change mitigation/adaptation, energy efficiency,

renewable energy deployment).

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[E1-3] Actions and resources in relation to climate change policies

Key actions in relation to climate change

From policies and pledges to action, Alpha Services and Holdings Group supports the decarbonization journey of its Customers across the markets it operates in. The following table presents how its pledged

actions are linked to time horizon, polices, value chain segment of the Group, the geographies, and stakeholders. Most actions have been taken so far at Alpha Bank S.A level, while subsidiaries are expected to

follow in the coming years.

TABLE 33 KEY ACTIONS (EXISTING AND PLANNED) IN RELATION TO CLIMATE CHANGE POLICIES

List of actions

Time horizon

Expected outcome

Relation to policy

objectives / targets

(where relevant)

2024 Progress on

Action

Scope of Action

Current

Planned

Value Chain

Segment

Geographical

boundaries

Affected

Stakeholders

Upgrade lighting to LED lighting

throughout the network of

Branches

Yes

Completi

on year:

2028

Reduce the energy consumption and the relevant emissions by at

least 10% comparing with the existing lighting systems.

The expected reduction of electricity consumption for lighting is

50%, which corresponds to approximately 13% reduction of the

total energy consumption of the relevant Branches.

Energy saving

affecting energy

footprint and

target setting

33 Branches and 6

buildings/warehouses

Own Operations

Greece: office

buildings,

warehouses

and Branches

operated by

Alpha Bank SA

Employees/

Customers

Replace 85% of the Bank’s fleet

with electric and/or plug-in and

hybrid vehicles

Yes

Completi

on year:

2025

Reduce emissions and lower fuel cost

• 2023: Average 110gr/km CO2

• 2024: Average 74gr/km CO2

Also, the required percentage of ¼ of new leases with pollutant

emissions below 50gr Co2 was also covered, as defined by the

new Climate Law.

Energy saving

affecting energy

footprint and

target setting

Vehicles fleet

renewed:

PHEV

218 total:

186- new leases

32- replacements

PETROL 1

HEV

91 (new leases

51, replacements 40)

TOTAL LEASES 311

Own Operations

Greece: Alpha

Bank S.A.

transportation

Employees

Continue to procure Certification

of Origin from renewable energy

systems for all our office buildings,

warehouses and Branches

Yes

Each year

To compensate the 100% of the emissions related to the

operation of our office buildings, warehouses and Branches,

taking advantage of appropriate market solutions.

The Bank receives

guarantees of origin

for 100% of its

electricity

consumption.

Own Operations

Greece: office

buildings,

warehouses

and Branches

operated by

Alpha Bank SA

Employees

Zero financing to new investments

in thermal coal mining, upstream

oil exploration or coal-fire

Yes

Ongoing

No new financing volumes

No new investments

to sectors that may

have a negative

impact on the

environment.

Downstream

Alpha Bank

S.A.

Customers/

Society

The following figures refer to Alpha Bank S.A.

Plug-In Hybrid Electric Vehicle

Electric Vehicle (EV)

Hybrid Electric Vehicle (HEV)

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Fossil Fuel- Limit operational

emissions, enable the supply of

low carbon liquids and gases,

carbon, capture, utilization and

storage technologies

Yes

Completi

on year:

2030

Eliminate the use of fossil fuel for heating purposes

In 2024, 5 oil

burners and 1 gas

burner were

replaced in 6

Branches

due to

the upgrade of the

air - condition

system.

Replacement of oil /

gas burners with heat

pumps

Own Operations

Greece: office

buildings,

warehouses

and Branches

operated by

Alpha Bank SA

Society (local

environment

), Employees

Oil and Gas – Reduction of

financed emissions in the sector.

Yes

Completi

on year:

2030

Achieve a 26% reduction in absolute financed emissions from

2022 to 2030. The Bank’s target exceeds the 23% reduction

required by the IEA NZE, reflecting the ambitious decarbonization

commitments of the Bank’s key clients in the sector.

Achievement of

Bank’s Strategy:

Membership with

NZBA and PRB,

compliance with EU

Green Deal,

alignment with EBA

Guidelines

Monitoring the Oil

and Gas sector new

disbursements in

alignment with the

relevant risk

indicators established

to safeguard the

progress towards

meeting the target.

Downstream

Spanning the

Group’s

geographical

footprint

Customers/

Society/

Shareholders

Power generation - Deployment of

renewable energy technologies

Yes

Completi

on year:

2030

Target for Power sector is 132 kgCO2e/MWh, which represents a

41% reduction in physical intensity from 2022 to 2030. The Bank’s

target is below the IEA NZE in 2030, reflecting the lower starting

point relative to the industry average – driven by the high share of

renewables in the Bank’s portfolio – and the ambitious

decarbonization commitments of the Bank’s key clients.

Achievement of

Bank’s Strategy:

Membership with

NZBA and PRB,

compliance with EU

Green Deal,

alignment with EBA

Guidelines

Increase in

Sustainable

Financings based on

Alpha Bank’s

Sustainable Finance

Framework

Downstream

Spanning the

Group’s

geographical

footprint

Customers/

Society/

Shareholders

Cement - Employ green financing

included in the Bank's Sustainable

Finance Framework and use

regular engagement with key

sector clients on decarbonization

opportunities

Yes

Completi

on year:

2030

584 kgCO2e/t Cementitious product, which represents a 15%

reduction in physical intensity from 2022 to 2030. The Bank’s

target for 2030 is above the IEA NZE pathway, reflecting the fact

that Cement is a hard-to-abate sector, with limited cost-effective

opportunities to decarbonize to 2030 and much of the abatement

expected to occur after 2030. The Bank will continue to engage

with its key clients in the sector to support their decarbonization

efforts.

Achievement of

Bank’s Strategy:

Membership with

NZBA and PRB,

compliance with EU

Green Deal,

alignment with EBA

Guidelines

Application of Alpha

Bank’s Sustainable

Finance Framework

to support clients’

decarbonization

efforts and targets

Downstream

Spanning the

Group’s

geographical

footprint

Customers/

Society/

Shareholders

Iron and Steel - Employ green

financing included in the Bank's

Sustainable Finance Framework

and use regular engagement with

key sector clients on

decarbonization opportunities

Yes

Completi

on year:

2030

The Bank’s starting position in the Iron and Steel sector is well

below the IEA NZE pathway, with a portfolio intensity of

540kgCO2e/t Steel in 2022, compared to the IEA level of 1,737

kgCO2e/t Steel. This is because the Bank’s exposure in the sector

is primarily to secondary steel producers. In this context, the Bank

is not setting a quantitative target for its Iron and Steel portfolio.

The Bank remains committed to support its clients in the sector

decarbonize and will aim for its emissions intensity to remain

below the IEA NZE pathway to 2030.

Achievement of

Bank’s Strategy:

Membership with

NZBA and PRB,

compliance with EU

Green Deal,

alignment with EBA

Guidelines.

Application of Alpha

Bank’s Sustainable

Finance Framework

to support clients’

decarbonization

efforts and targets

Downstream

Spanning the

Group’s

geographical

footprint

Customers/

Society/

Shareholders

This refers exclusively to Alpha Bank S.A. Subject of internal approval.

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ESG Academy

In 2024, Alpha Bank’s strategic commitment to sustainable growth extended, focusing strongly on empowering its People to unleash their

potential. Central to the Group’s Learning and Development capabilities is Alpha Bank’s learning ecosystem ACE #together we grow which was

enriched with the design and launch of specialized Academies (Digital, ESG). Through the ESG Academy, the Bank aims to provide awareness

and training to its Employees on ESG and climate risks, aiming also to add the power of its brand name to the wider sustainability transition

effort. The ESG Academy aims to cover the following thematic areas:

TABLE 34 THEMATIC AREAS ADDRESSED THROUGH ESG ACADEMY

Horizontal Awareness

Technical capabilities for ESG

o Understanding of the ESG components and their

impact on the Banking Sector while inspiring

behavioral change inside and outside of work

o Fundamentals towards ESG integration

o ESG Governance and Operating Model

o Risk Management Framework

o Sustainable Finance Framework

o Business and Strategic Planning around ESG

o Health and Safety Awareness

o Sustainable Finance Framework Operationalization

o Loan Origination Process (Integrating ESG criteria in

lending and the transaction assessment process)

o ESG scoring and modeling

o Data Governance and Processes

During 2024, 79% of workforce of Alpha Bank Greece participated in training organized by the ESG Academy, while over 80% of retail and

wholesale banking business Employees followed dedicated ESG lessons specializing on the understanding of the ESG landscape, the SFF the

Bank has developed and the necessity of the ESG assessment. Employees across the Bank benefited from introductory eLearning courses on

ESG fundamentals and the ESG Risks and Opportunities. A dedicated training was carried out on “ESG Risk Management for Risk Professionals”

with participation of all Employees in risk management. Additionally, the Bank collaborated with the Hellenic Banking Association for the

provision of an open-registration webinar on ESG and Sustainable Finance. Information about additional Academies which run over 2024 can

be found on S1- Own Workforce section of the Sustainability Statement. Provision of remedy for those harmed by actual material impacts is

not relevant for the Group given the exclusion list Policy.

Decarbonization levers for the reduction of GHG emissions

The cornerstone of the Group’s Sustainable Finance Strategy is the design of financial products to enable its clients transition to low-carbon

business models, the provision of “green” retail loans with preferential interest rate to cover Customers’ needs and offering financing

opportunities through EU and state-funded programs covering green and sustainability-related categories as well as dedicated green solutions

for small and medium size businesses.

TABLE 35 SUSTAINABLE FINANCING STRATEGY DELIVERY MECHANISM

Initiative

Description

Project Finance

Through its specialized Project Finance Unit the Bank supports green/low carbon investments:

- Providing financing for new investments in wind farms and solar parks.

- Providing financing for Commercial Real Estate (CRE) projects certified under an internationally

or nationally recognized green building certification scheme.

Co-Funding Programs

Utilize the Bank’s significant expertise in deploying co-funding initiatives, to support decarbonization:

- Leveraging the EU Recovery and Resilience Facility (RRF) Green transition pillar to accelerate green

investments.

- Enabling small businesses to improve their environmental footprint and reduce their energy use, via

the Hellenic Development Bank programs.

Green and Home Energy Solutions

Enhancement with new services and financial incentives in the context of the Green Loan Portfolio to encourage

consumer sustainability journey via:

- Home improvement or equipment loans (thermal insulation, solar panels, heat pumps, energy-

efficient electrical appliances).

- New Green mobility financing solutions to support electrification of transport (plug-in electric

vehicles, electric vehicles, scooters, public transport).

- Incorporation of sustainability criteria into mortgage and real estate lending policies, including

financing terms and pricing.

- Provision of other incentives to existing clients to accelerate the adoption of energy efficiency

standards.

Sustainable Investment Products

- Enriching the offering of mutual funds that promote sustainable investment characteristics.

- Endorsing labelled Green and Social Bonds and promote impact investment-linked structured notes

that incorporate environmental and social characteristics.

- Engaging in training initiatives and dialogue with clients on sustainability themes.

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Decarbonization lever: Reduction of operating footprint

Upgrade lighting to LED lighting throughout the network

is a planned action that will be completed by 2028 and is expected to achieve

carbon reduction of 117 tCO2e per annum. Replacement of the Bank’s fleet with electric and/or plug-in and hybrid vehicles has already

achieved 70% fleet replacement and is aiming to achieve replacement of the entire fleet within the next few years, achieving 33% CO2

reduction. Limit operational emissions, enable the supply of low carbon liquids and gases, carbon, capture, utilization and storage technologies

has achieved carbon reduction of 74 tCO2e compared against 2022.

Decarbonization lever: Transition to renewable energy

Procuring renewable electricity for all our buildings and branches has already been achieved at a 100% rate and will continue. Power

generation and deployment of renewable energy technologies is an action that is expected be completed by 2030 and has already achieved

reduction of 132 kgCO2e / MWh.

Decarbonization lever: Decarbonization of the portfolio

Providing zero finance to new investments in thermal coal mining, upstream oil exploration or coal-fire is an existing and continuing

commitment for Alpha Bank. Alpha Bank has committed to employ green financing included in the Bank's Sustainable Finance Framework and

use regular engagement with key sector clients on decarbonization opportunities. This commitment is spanning across different sectors: (a)

with regard to power generation, Alpha Bank’s target is 132 kgCO2e/MWh, which represents a 41% reduction in physical intensity from 2022

to 2030, (b) in the oil and gas sector, Alpha Bank is aiming to achieve 26% reduction in absolute financed emissions from 2022 to 2030, (c) in

the cement sector, the target is 584 kgCO2e/t Cementitious product, which represents a 15% reduction in physical intensity from 2022 to

2030, (d) in the iron and steel sector, Alpha Bank is not setting a quantitative target for its portfolio; it remains committed to support its clients

in the sector to decarbonize and will aim for its emissions intensity to remain below the IEA NZE pathway to 2030.

Resources for implementation of actions

The ability to implement the actions depends on the availability and allocation of resources.

Due to the nature of the Group’s business activities (i.e. related to the financial services and products), the Group does not require any

significant operational OpEx and/or capital expenditures CapEx that relate to the implementation of its actions towards the achievement of

policy objectives and targets. New requirements are routinely addressed in the broader context of its ongoing operational enhancements and

are in any case considered material, determined in line with relevant due diligence standards. Sectoral exposure amounts of the Group

disclosed in Pillar 3 are the most significant financial indicators, that relate to the Group material impacts through its portfolio.

To implement the decarbonization targets set for key carbon intensive sectors the Bank is leveraging on its ability to regularly measure,

monitor and assess its financed emissions and analyze them in comparison to the target baseline and the IEA NZE pathway to 2030. In

addition, the Bank continuously engages with key clients on their level of progress and decarbonization commitments.

The portfolio decarbonization lever and progress to net zero will also depend on external factors outside the Bank’s control, such as the policy

landscape, the scale and pace of technological developments, and economic and geopolitical factors. Moreover, climate data, scenarios and

methodologies continue to evolve, which may require changes in our methodology and target-setting approach over time.

[E1-4] Targets related to climate change mitigation and adaptation

The Group has established a set of KPIs for each of the environmental priority impact areas of its Strategy (Climate), to enable the

measurement of the overall performance and make the necessary corrective actions to achieve the strategic commitments and management

of its impacts, risks and opportunities related to climate change. One of the top commitments for the Group is to support Customers’

decarbonization and align their portfolio emissions with the Paris Agreement. In addition, the Group commits to accelerating portfolio

alignment with the Objectives set in the Paris Agreement, through setting targets for sustainable lending. As part of this commitment the

Group has set the target to lend Euro 4.4 billion in sustainable disbursements during 2024-2026. The main focus is in the Power sector (solar,

wind, grid upgrading, etc.), buildings (energy efficiency, upgrades, heat insulation, certification) and transportation (electric vehicles,

alternative fuels).

The average annual electricity reduction per Branch due to the lighting replacement has been estimated to be around 7.070MWh

. The conversion factor for

emissions is 0.4996 tCO

2eq

/MWh

. The estimated value corresponds to 33 Branches of Alpha Bank S.A.

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TABLE 36 TARGETS RELATED TO DOWNSTREAM ACTIVITIES

Target description

Target level

Absolute /

Relative

Baseline

value

Baseline

Year

Target

Year

Scope

Progress in 2024

KPIs

4.4 billion to new

Sustainable

Financings

increasing target by

Euro 1.4 billion

compared to 2023 -

2025 target

announcement

Euro 4.4

billion

Absolute

N/A

2024

2026

Banking sector

activity,

Downstream,

Alpha Bank

S.A.(Greece)

Euro 1.809 billion

(incl. Euro 1.742

billion from

wholesale)

New financing

volumes

(in Euro

million)

Within the total

Sustainable

Financings,

achieve at least

Euro

2.6 billion to

Renewable

Energy Systems by

2026,

increasing target by

Euro

1.6 billion

compared

to 2023- 2025

target

announcement

Euro 2.6

billion

Absolute

N/A

2024

2026

Banking sector

activity,

Downstream,

Alpha Bank

S.A.(Greece)

Euro 356 million

New financing

volumes

(in Euro

million)

Zero financing to

new investments in

thermal coal

mining, upstream

oil

exploration or coal-

fired electricity

generation

0 million

Absolute

Euro 0

million

2023

Ongoing

Banking sector

activity,

Downstream,

Alpha Bank

S.A.(Greece)

Euro 0 million

New financing

volumes (in

Euro million)

Financed emissions

targets: Power

Generation

132 kgCO2e

/ MWh

Relative

223 kgCO2e

/ MWh

2022

2030

Banking sector

activity,

Downstream,

Alpha Bank

S.A.(Greece)

147 kgCO2e /

MWh

(-34.1%

compared to

baseline value)

physical

intensity metric

(kgCO2e /

MWh)

Financed emissions

targets: Oil and Gas

74 Indexed

tCO2e of

2022 = 100

tCO2e

Absolute

100 Indexed

tCO2e of

2022 = 100

tCO2e

2022

2030

Banking sector

activity,

Downstream,

Alpha Bank

S.A.(Greece)

83.3 Indexed

tCO2e of 2022 =

100 tCO2e

(-16.7%

compared to

baseline value)

absolute

emissions

metric

( Indexed

tCO2e of 2022

= 100)

Financed emissions

targets: Cement

584 kgCO2e

/ t

Cementitiou

s product -

intensity

Relative

687 kgCO2e

/ t

Cementitiou

s product -

intensity

2022

2030

Banking sector

activity,

Downstream,

Alpha Bank

S.A.(Greece)

684 kgCO2e / t

Cementitious

product –

intensity

(-0.4% compared

to baseline

value)

physical

intensity metric

( kgCO2e / t

Cementitious

product –

intensity)

Financed emissions

targets: Iron and

Steel

Intensity of

portfolio to

remain

below the

reference

pathway

Relative

540 kgCO2e

/ t Steel -

intensity of

portfolio

2022

2030

Banking sector

activity,

Downstream,

Alpha Bank

S.A.(Greece)

520 kgCO2e / t

Steel - intensity

of portfolio

(-3.7% compared

to baseline

value)

physical

intensity metric

( kgCO2e / t

Steel - intensity

of portfolio)

The Group has not set GHG emission reduction targets for the year 2030 regarding its own operations. However, the Bank is a member of

NZBA and therefore is currently in the process of developing targets regarding Scope 1,2 for the mid-term (2026-2030) and long-term time

horizon (>2030). Additionally, the Bank has set though GHG emission reduction targets for 2025 as disclosed in the table below:

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TABLE 37 GHG EMISSION REDUCTION TARGETS RELATED TO OWN OPERATIONS

Target description

Target level

Absolute /

Relative

Baseline

value

Baseline

Year

Target

Year

Scope

Progress in 2024

KPIs

Reduction of Scope

1 and 2 GHG

emissions by 20%

until 2025,

comparing to 2022

N/A

Absolute

1,473

2022

2025

Own operations

Alpha Bank

S.A.(Greece)

1,776

Scope 1 GHG

Emissions

(tn CO2eq.)

N/A

Absolute

18,419

2022

2025

2,353

Scope 2 GHG

Emissions

Location-based

(tn CO2eq.)

15,914

Absolute

19,892

2022

2025

4,129

(-79% compared

to baseline

value)

Scope 1 and 2

Target setting process

Financed Emissions Targets are aligned with the Paris agreement and the UN Sustainable Development Goals and are based on

conclusive scientific evidence. More specifically, with reference to the selected, material-relevant NZBA carbon-intensive sectors

the Group has deployed science-based International Energy Agency Net Zero Emissions by 2050 (IEA NZE) scenario as its benchmark pathway.

Worth mentioning that the baseline measurement relied on the GHG emissions of its borrowers or investee companies and followed the

Global Greenhouse Gas (GHG) Accounting and Reporting Standard for the Financial Industry developed by the PCAF. It is noted that the GHG

emission targets have not been externally assured.

As highlighted in [SBM-2] Interests and views of stakeholders, multiple stakeholder input has been taken into consideration in shaping each of

Targets set by the Group. In response to these expectations, Alpha Services and Holdings Group has taken concrete steps to deliver on its

climate ambitions. As the first Greek bank to join the UN-convened Net-Zero Banking Alliance (NZBA), it is committed to achieving net-zero

emissions across the portfolios by 2050.

It is noted that there are no changes in targets and corresponding metrics to report.

Specific target in relation to the management of risks

The Group has already incorporated in its Risk Appetite Framework (RAF) a set of quantitative indicators and qualitative commitments

regarding climate risks. In terms of quantitative indicators, the Group has defined several C&E indicators designed to improve the sustainability

of the portfolio and mitigate potential exposure to risk and are incorporated in Risk Appetite Framework as supporting elements. Additionally,

limits have been established in part of the existing C&E indicators. The indicators cover the area of business planning and green financing,

collateral vulnerability to physical and transition risk, financial activity vulnerability to physical risk and sustainable investing. In 2024, the

Group updated its Risk Inventory to provide a comprehensive overview of the enhancements and progress achieved in climate-related risks in

the Bank's Risk Registry, by incorporating additional limits. More specifically, the following Key Risk indicators with thresholds were introduced

into the Risk Appetite Framework (‘RAF’), taking into consideration the materiality assessment outcome and its target setting exercise and

commitments in specific sectors.

TABLE 38 THE RISK APPETITE FRAMEWORK (RAF) INDICATORS

Risk Category

Perimeter

RAF Indicator

Transition Risk

Credit Risk

Alpha Bank S.A.

Exposures to sectors considered more sensitive to transition risk

Credit Risk

Alpha Bank S.A.

New originations to sectors considered more sensitive to transition risk

Credit Risk

Alpha Bank S.A.

Exposures of Mortgage Portfolio with EPC label >= D

Credit Risk

Alpha Bank S.A.

New Originations in Mortgage Portfolio with EPC

label <= D

Physical Risk

Credit Risk

Alpha Bank S.A.

Exposures sensitive to impact from climate change physical events, specific sectors

Credit Risk

Alpha Bank S.A.

Real Estate Exposures sensitive to impact from climate change physical events

Transition Risk

Business and Strategic

Alpha Bank S.A.

Net interest income from sectors considered more sensitive to transition risk

Transition Risk

Market Risk

Alpha Bank S.A.

Bank's ESG-related investment assets (such as Green Bonds) (in Euro million). /

Total Face Value of Bonds in AC, FVOCI and FVPL (non-TRD) portfolios classified as

Sustainable according to Bloomberg data

Physical Risk,

Social Risk,

Governance Risk

Operational Risk

Alpha Bank Services

and Holdings S.A.

Group

ESG Risk Losses

Environmental Risk,

Social Risk,

Governance Risk

Reputational Risk

Alpha Bank Services

and Holdings S.A.

Group

ESG Rating

Transition Risk

Business and Strategic

Alpha Bank S.A.

Physical intensity of new and existing clients in the Power sector, kgCO2e/MWh

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Transition Risk

Business and Strategic

Alpha Bank S.A.

Physical intensity of new and existing clients in the Cement sector, kgCO2e/t

cement

Transition Risk

Business and Strategic

Alpha Bank S.A.

Physical intensity of new and existing clients in the Iron and Steel sector, kgCO2e/t

steel

Transition Risk

Business and Strategic

Alpha Bank S.A.

Oil and Gas refining drawn exposure, EUR million

Transition Risk

Business and Strategic

Alpha Bank S.A.

Change in % of exposure with 1.5ºC aligned climate targets for each priority sector

Total reduction target for Scope 3 emissions has not been disclosed as a cumulative figure, as financed emission targets have only been set for

the specific four sectors listed on Table 37.

To define the first wave of sector portfolio decarbonization targets the Bank performed a comprehensive measurement of its financed

emissions covering investment and lending portfolios, across all financed sectors. The measurement relied on the GHG emissions of our

borrowers or investee companies and followed the Global Greenhouse Gas (GHG) Accounting and Reporting Standard for the Financial

Industry developed by the PCAF. Asset classes covered included on-balance sheet exposures in listed and unlisted equity, corporate bonds,

sovereign bonds, corporate loans, commercial real estate (CRE), residential real estate (RRE), motor vehicle loans and project finance. SMEs

were excluded from the initial perimeter for target setting. The final decision on sector prioritization considered each sector’s materiality

based on the financed emissions measurement, outstanding exposure, sectoral contribution to Greece’s emissions, the availability of credible

sectoral target-setting guidance, data quality and availability, as well as the market practice. The GHG emission reduction targets represent

gross targets, meaning that GHG removals, carbon credits or avoided emissions are not taken into account as a means of achieving the GHG

emission reduction targets.

Due to the level of data availability, GHG emission in 2022 were set as baseline, regarding the Bank’s portfolio related emissions. Another

reason was that the Bank improved in 2022 the coverage and data quality of its financed emissions.

The Group employs the widely used, science-based IEA NZE 2050 scenario as its benchmark pathway. The IEA NZE 2050 charts a pathway for

the global energy sector to reach net zero CO2 emissions by 2050, consistent with holding the increase in the global average temperature to

1.5°C above pre-industrial levels. The Group uses the 2023 vintage of the IEA NZE 2050 scenario, which reflects the latest developments in

technologies, markets, policies and investment vis-à-vis the net zero transition. Additional information on the climate analysis is provided in

[IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

[E1-5] Energy consumption and mix

The Group recognizes that energy consumption for own operations is generating emissions that are directly contributing to climate change,

and therefore need to be mitigated. It is also recognized that achieving the net zero target means that the Group will need to minimize

operational emissions and treat any residual emissions through carbon removals or other techniques. In 2023 Alpha Bank started developing

the Energy Management System according to the ISO 50001:2018 requirements, while the certification process was completed in 2024. The

Group is using the following consumption metrics to track and assess effectiveness towards reducing operational emissions.

Table 39 Energy Consumption and mix

Energy consumption and mix

2024

(1)

Fuel consumption from coal and coal products (MWh)

(2)

Fuel consumption from crude oil and petroleum products (MWh)

5,442

(3)

Fuel consumption from natural gas (MWh)

5,448

(4)

Fuel consumption from other fossil sources (MWh)

2.78

(5)

Consumption of purchased or acquired electricity, heat, steam, and cooling from

fossil sources (MWh)

11,328

(6)

Total fossil energy consumption (MWh) (calculated as the sum of lines 1 to 5)

22,220

Share of fossil sources in total energy consumption (%)

33.0%

(7)

Consumption from nuclear sources (MWh)

2,194

Share of consumption from nuclear sources in total energy consumption (%)

3.3%

(8)

Fuel consumption from renewable sources, including biomass (also comprising

industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.)

(MWh)

(9)

Consumption of purchased or acquired electricity, heat, steam, and cooling from

renewable sources (MWh)

42,903

(10)

The consumption of self-generated non-fuel renewable energy (MWh)

(11)

Total renewable energy consumption (MWh) (calculated as the sum of lines 8 to 10)

42,907

Share of renewable sources in total energy consumption (%)

63.7%

Total energy consumption (MWh) (calculated as the sum of lines 6, 7 and 11)

67,321

Group (Alpha Bank) installed a pilot, small scale flat roof PV in one Branch, in Athens, Greece. The new system was installed in 2024 and is

expected to be connected to the grid in early 2025. The system has a nominal power of approximately 10kWp, while it is expected to produce

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annual more than 14.5MWh. The Group will identify the possibility to increase the installed power of PV systems, focusing on reducing the final

emissions balance and the operational cost.

Energy related calculations and methodologies

Almost all data collected for Alpha Services and Holdings Group refer to the actual period January to September/October 2024. Consumption

for 12-month period was derived for all data as following :

- The annual electricity consumption was derived from the actual bills received. For the period that no actual was available, data from

previous corresponding period were used.

- For Alpha Bank London Ltd, primary data was found for the entire building and it is divided by 5 because Alpha Bank London Ltd

occupies 1 of the 5 building floors.

Alpha Bank S.A. has annual contract for purchasing electricity for its own operating premises (e.g. Branches, office buildings, warehouses,

ATMs) and hence has purchased Guarantees of Origin for the total electricity consumption. This affects also subsidiaries operating to these

premises – buildings.

Energy intensity

The energy intensity associated with activities in high climate impact sectors is 0.00164 MWh/Euro net revenue.

The high climate impact sector used to calculate the intensity figure above is L68 (Real Estate activities). The cumulative energy consumption

from the aforementioned entities is 29,939 MWh.

The net revenue associated with real estate operations is Euro 18.3 million and is included in the Group’s financial statements by referring to

the following lines: Interest and similar income, Fee and commission income, Dividend income, Gains less losses on derecognition of financial

assets measured at amortized cost, Gains less losses on financial transactions, Other income. For the total Group net revenue please refer to

[E1-6] Table 45. The above metrics have not been validated by an external body.

[E1-6] Gross Scopes 1, 2, 3 and Total GHG emissions

The measurement, continuous monitoring, and effective reporting of the carbon emissions is a key priority for the Group and constitute a

critical and objective means for assessing its performance and effectiveness against its climate commitments. By the time of reporting, 2024

Gross Scopes 1, 2, 3 and Total GHG emissions have not been validated by an external body.

Table 40 Gross Scopes 1, 2, 3 and Total GHG emissions

Gross Emissions

2024

Scope 1

Gross Scope 1 GHG emissions (in metric tons of CO2eq)

3,252

Share of Scope 1 GHG emissions from regulated emission trading schemes (%)

No emissions from regulated

emission trading schemes

Scope 2

Gross Scope 2 GHG location-based emissions (in metric tons of CO2eq)

27,963

Gross Scope 2 GHG market-based emissions (in metric tons of CO2eq)

19,702

Share of market-based Scope 2 GHG emissions linked to purchased electricity

bundled with instruments such as Guarantee of Origins or Renewable Energy

Certificates (%)

84.6%

Share of contractual instruments used for sale and purchase of energy bundled

with attributes about energy generation in relation to Scope 2 GHG emissions (%)

Only certifications of Origins are

foreseen

Share of contractual instruments used for sale and purchase of unbundled

energy attribute claims in relation to Scope 2 GHG emissions (%)

Only certifications of Origins are

foreseen

Scope 3

Gross Scope 3 GHG emissions for each significant category (in metric tons of

CO2eq)- (Investments)

26,464,149

Share of emissions calculated using primary data obtained from suppliers or

other value chain partners (i.e. obligors) (%)

32.9%

Totals

Total GHG emissions with location-based Scope 2 (in metric tons of CO2eq)

26,560,666

Total GHG emissions with market-based Scope 2 (in metric tons of CO2eq)

26,552,405

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Table 41 Gross GHG Emissions

Emissions category

Gross emissions (tCO2e)

2024

Scope 1 emissions

3,252

Stationary combustion (in metric tonnes of CO2eq)

1,307

Mobile combustion (in metric tonnes of CO2eq)

1,342

Fugitive emissions (in metric tonnes of CO2eq)

604

Scope 2 emissions location-based

27,963

Scope 2 emissions market-based

19,702

Total Scope 1 + 2 emissions (Scope 2 location-based)

31,215

Total Scope 1 + 2 emissions (Scope 2 market-based)

22,954

Scope 3 emissions (excluding category 15)

65,302

Purchased goods and services

9,453

Capital goods

Fuels and energy related activities

2,097

Upstream transportation and distribution

343

Downstream transportation and distribution

Waste generation

Business travel

542

Employee commuting

3,338

Downstream leased assets

49,486

Investments

26,464,149

Scope 1, Scope 2 (location-based) and Scope 3 (excl. category 15) emissions

96,543

Scope 3 emissions (including category 15)

26,529,451

As shown, in the table above, the most significant category of Scope 3 GHG emissions (accounting for 99.7% of total Scope 3 emissions), based

on the Magnitude of the estimated GHG emissions are Investments (Financed emissions).

It is noted that the figure for financed emissions in 2024, was calculated taking into account the restated data of an obligor with a significantly

large carbon footprint, that affected in 2023 the calculation of financed emissions. The Group 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 may be materially affected in the coming years as well.

GHG emissions calculation and methodologies used

There are no significant changes compared to the previous year regarding the definition of what is considered upstream and downstream

value chain. However, changes in the reported Scope 1, 2 GHG emissions compared to previous year (compared to “2023 Sustainability

Report”, are attributed to the fact that certain subsidiaries were sold in 2024 (please refer to the Section: Assets Held for sale of the Financial

Statements).

Scope 1, 2 GHG emissions calculation and methodologies used

The GHG emissions of 2024 have been estimated with the following assumptions:

• Electricity consumptions, period: 1 calendar year, as given from bills issued from Feb 2024 – Jan 2025.

• Water consumption: 1 calendar year, as given from bills issued from Nov 2023 – Oct 2024.

• Conversion coefficients (kWh to tCO

2eq

): Both for location and market-based calculation the values of 2023 were used.

• Refrigerants: emissions are attributed to the refrigerants’ losses of 2023.

Scope 3 GHG emissions calculation and methodologies used

Two specific approaches were used to calculate direct and indirect emissions:

i) Activity-Data Based Approach: Emissions were calculated using the activity data related to the service or product (e.g.

quantities, transport work, energy consumption), and

ii) Spend-Based Approach: Emissions were derived from the economic value of the service or product, correlating with the costs

incurred by the entity. This uses Input-Output tables for (EU-27), allocating national GHG emissions to economic sectors based

on economic flows.

iii)

List of GHG emissions included in the inventory and exclusions and reporting boundaries

The Group is currently at advanced state of a more detailed measurement of its Scope 3 financed emissions across asset classes and sectors,

following the Global Greenhouse Gas (GHG) Accounting and Reporting Standard for the Financial Industry developed by the PCAF. The PCAF

builds upon the GHG protocol guidance to calculate Scope 3, category 15 (see Table 15 Scope 3 Categories), emissions to provide asset class

specific calculation approaches with guidance on financial or operational control approaches, attribution factors, emissions factors and data

sourcing hierarchies.

For the following categories of Scope 3, an explanation of calculation methods for estimating the GHG emissions is provided:

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Category 1: Purchased goods and services. The methodology used for the emissions calculation is based on spend-based method. Purchased

goods include the following sub-categories: furniture, paper, toner, water and electronic equipment, and others. Τhe upstream emissions in this

case are calculated by multiplying the activity data (quantities and/or expenditures) by emission factors from various sources such as: a)

Environmentally- Extended Input Output (EEIO) models that provide sector-level data on emissions per turnover for Greece. Total emissions

from services are estimated on the basis of procurement costs per type of service and emission factors derived from Environmentally-Extended

Input Output (EEIO) models for Greece.

Category 2: Capital goods.

This category is not relevant for the Group. In 2024, the Group did not purchase significant capital goods (such as buildings or machinery) which

could be incorporated into this category of Scope 3 emissions. The emissions associated with the purchase of other products, goods and

services, which could be classified under this category, have been included under Category 1 Purchased goods and services.

Category 3: Fuel-and-energy-related activities (not included in Scope 1 or 2).

The methodology used for the emissions calculation is based on the average-data method. This category of scope 3 emissions comprises the

GHG emissions associated with: (i) the extraction, production, and transportation of fuels consumed by the reporting Group; (ii) the extraction,

production, and transportation of fuels consumed in the generation of electricity consumed by the reporting Group; and (iii) the transmission

and distribution losses corresponding to the electricity consumed by the reporting Group.

The upstream emissions of the fuels consumed in the reporting Group (subcategory i) are calculated by multiplying the activity data (quantities

of fuel) with the emission factors provided DEFRA 2023 (WTT fuels). The upstream emissions of the fuels consumed for generating the

electricity consumed by the reporting Alpha Bank S.A. (subcategory ii) are estimated as follows: Given that a significant part of the electricity

consumed is covered by guarantees of origin, the upstream emissions of this part of electricity was estimated by multiplying the corresponding

electricity consumption with the European average wind farm generation factor according to the study "CoM Default Emission Factors for the

Member States of the European Union" (2017). For the subcategory "TD losses", which corresponds to emissions from losses in the electricity

transmission and distribution network, the emission factor used was based on data from Carbon Footprint Ltd. For the subcategory “WTT

losses” that corresponds to electricity production, the emission factor used was based on data from Carbon Footprint Ltd. It is noted that for

companies which have an active contract with an electricity provider, taking provision for providing Gurantees of Origins from renewable

energy sources, “WTT losses” has not been calculated.

Fuels and electricity quantities used to calculate emissions are provided through bills or invoices.

Category 4: Upstream transportation and distribution.

The methodology used for the emissions calculation is based on spend-based method. This category includes emissions from transportation

services provided from companies distributing materials to Group’s warehouses, as well as companies collecting and transporting materials and

equipment between the various infrastructures of the Bank (e.g., due to the merge of units and branches). Relevant emissions are estimated

based on the amount of money spent for this type of transportation activities and appropriate EEIO emission factors for land transport services

sector. Expenses used to calculate emissions are provided through invoices issued by each transportation Alpha Bank S.A.

Category 5: Waste generated in operations.

The methodology used for the emissions calculation is based on spend-based method and average-data method. Scope 3 emissions from waste

generated in operations include solid wastes produced by Employees and sent to landfill, as well as recycled materials. Activity data for solid

wastes produced in Group’s premises are calculated based on specific assumptions (e.g. by using the indicator of solid wastes produced per

employee in the tertiary sector provided by Eurostat and taking into account the number of Employees who were exempted from teleworking.

Furthermore, for the recycled materials the expenses made for their transportation have been used as activity data, which has been derived

from invoices. DEFRA emission factors per type of material wasted and treated are also used to calculate a weighted emission factor for solid

wastes on the basis of a typical composition of the produced mixture (based on an EPA’s study).

Category 6: Business Travel.

The methodology used for the emissions calculation is based on actual data. Scope 3 emissions are derived from business travel comprises air,

sea, and land transportation of Employees for business-related activities, as well as accommodation in hotels during these trips. All relevant

information is provided by the collaborating travel agencies. Defra 2023 emission factors have been applied.

Category 7: Employee commuting.

The methodology used for the emissions calculation is based on the average-data method. Expert judgment taking into account the experience

of other big companies in Greece is used to reflect the commuting habits of Employees concerning typical travel modes, the type of fuel used,

annual working days for the reference year, as well as commuting distances to work per employee. Within this context, a total transport work

by travel mode on an annual basis is calculated and multiplied by DEFRA’s conversion factors for all means of transport except for public means

where national emission factors have been applied, also taking into account the avoided transport work due to the implementation of

teleworking among the Employees of the Group.

Category 8: Upstream leased assets.

This category does not apply to Alpha Bank because emissions from the operation of leased office buildings are included under scopes 1 and 2.

Category 9: Downstream transportation and distribution.

GHG emissions from this category are considered relevant to the Bank. However, according to the data obtained, Group’s GHG emissions from

this category are relevant low compared to other categories.

Category 10: Processing of sold products.

The Group, as a financial service provider, does not sell products, only services that do not need processing. As a result, emissions in this

category are not relevant.

Category 11: Use of sold products.

THe Group offers only services to its clients and does not sell products that lead to emissions when used. Since we are a service, the use of our

sold products does not have an impact and does not represent position in our carbon footprint.

Category 12: End of life treatment of sold products.

The Group offers only services to its clients and does not sell products that lead to emissions when disposed. Since we are a service, the end-of-

life treatment of sold products does not represent a significant position in our carbon footprint.

Category 13: Downstream leased assets.

GHG emissions from this category are considered relevant to the Group. Alpha Leasing S.A. has a significant amount of emissions in this

category due to its operation.

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Category 14: Franchises.

This category is not relevant as the Group has no Franchises.

Category 15: Investments (Financed Emissions)

In order to align its portfolio with the Paris Agreement climate objectives, the Group is carrying out a full measurement of its financed

emissions, covering investment and lending products of its corporate portfolio across all the sectors it finances, based on the GHG emissions of

its borrowers or investee companies. To measure its financed emissions, the Bank follows the Global Greenhouse Gas Accounting and

Reporting Standard for the Financial Industry developed by the PCAF (version Nov. 2021). PCAF builds upon the GHG Protocol Corporate Value

Chain (Scope 3) emissions – Investments (Category 15), to provide asset class specific calculation approaches. In this context, the asset class

coverage includes Listed and Unlisted Equity, Corporate Bonds, Corporate Loans, Commercial Real Estate (CRE) and Project Finance. The Group

is in the process to complete the exercise, including all asset classes (Mortgages, etc.,). Measuring FEs of all asset classes will be able to provide

the weighted data quality score. For the purposes of the financed emissions measurement, the counterparty NACE sector allocation was

identified and GHG financed emissions calculated for Scope 1, Scope 2 and Scope 3 emissions (in tons of CO2 equivalent), depending on

availability of information. Financed emissions have been measured by using primary data (e.g., reported emissions) for the 32.9% of the

portfolio (in terms of outstanding amount), whereas for the remainder of the portfolio (i.e., 67.1%), financed emissions have been estimated by

using proxy data (e.g., EEIO). To the extent GHG emissions, activity or financial data were not available on behalf of the counterparties for 2023,

the measurement for the financed emissions was based on data for 2022. Bank exposure to each counterparty corresponded to end of 2023

balances. Future disclosure of emissions by Customers will improve data quality but may also cause changes in financed emissions figures.

GHG emissions intensity

Table 42 GHG emissions intensity (total GHG emissions per net revenue)

2024 GHG emissions intensity (total GHG emissions per net revenue (tn CO

e/Euro net revenue).

Location -based

Market-based

2024

0.012

Table 43 Net Revenue Amounts for GHG intensity (in Euro)

2024 Net Revenue Amounts (in Euro)

Net revenue used to calculate GHG intensity (in Euro)*

2,222,000,000

* Total Income from banking operations as in the financial statements

[E1-9] Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Anticipated Financial Effect – Physical risk

As already mentioned above, the Group performs a vulnerability assessment (at both sectoral and regional level) to identify potential

significant hazards per sector covered by the analysis for Business portfolio, as well as across the different geographic regions where real

estate properties used as collateral are located.

Details on the materiality assessment conducted by the Group may be found under [IRO-1] Description of the process to identify and assess

material impacts, risks and opportunities.

TABLE 44 THE SUM OF COLLATERALIZED LOANS COMMERCIAL IMMOVABLE PROPERTY AND OF RESIDENTIAL IMMOVABLE PROPERTY,

ACTUAL EPC, GROUP PERIMETER

Level of energy efficiency (EPC label of

collateral)

Total gross carrying amount (in Euro million)

270.00

158.86

309.54

232.39

116.06

52.43

83.80

Note 1: Source: Pillar III Disclosures

Note 2: Perimeter: Sum of collateralized loans commercial immovable property and of residential immovable property, Actual EPC, Group

Perimeter

Anticipated Financial Effect - Transition risk

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As already mentioned above, the Group performs a materiality assessment for transition risk in order to identify sectors sensitive to transition

risk and climate-related transition risks that materially affect each sector lying within the transition risk sensitive perimeter under different

time horizons.

Details on the materiality assessment conducted by the Group and the time horizons utilized may be found under [IRO-1] Description of the

process to identify and assess material impacts, risks and opportunities.

Table 45 The sum of collateralized loans of commercial immovable property and of residential immovable property, Estimated

and Actual Energy Efficiency Consumption, Group Perimeter

Level of energy efficiency (EP score in

kWh/m²)

Total gross carrying amount (in Euro million)

0; <= 100

782,07

> 100; <= 200

4.236,70

> 200; <= 300

2.386,32

> 300; <= 400

2.160,43

> 400; <= 500

407,15

> 500

1.114,06

Note 1: Source: Pillar III Disclosures

ESRS E4 – BIODIVERSITY AND ECOSYSTEMS

[E4-1] Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Resilience Analysis

The Group has performed a resilience analysis to assess biodiversity and ecosystem risks within its portfolio, as described under [SBM-3]

Material impacts, risks and opportunities and their interaction with strategy and business model and [IRO-1] Description of the process to

identify and assess material impacts, risks and opportunities.

The time horizons for financial materiality purposes can be found in detail in the relevant section under [IRO-1] Description of the process to

identify and assess material impacts, risks and opportunities.

The results of the above-mentioned analysis reveal that biodiversity and ecosystems risk is considered material on an inherent basis over the

long-term horizon.

TABLE 46 ANTICIPATED FINANCIAL EFFECT – RISKS (BIODIVERSITY AND ECOSYSTEM)

Anticipated Financial Effect - Risks

Short-Term (2025)

Medium-Term (2026-2030)

Long-Term (>2030)

Biodiversity and Ecosystem

Not material

Material

Stakeholder Involvement

Alpha Services and Holdings Group proactively engages with all stakeholders to address biodiversity and ecosystem preservation, aligning its

approach with supervisory expectations, regulatory requirements, and evolving best practices, including the development of metrics, targets,

and goals. Guided by the European Banking Authority (EBA) guidelines and the European Central Bank (ECB) expectations, the organization

integrates biodiversity considerations into its sustainability framework. Although specific feedback from shareholders regarding biodiversity

considerations has not yet been received, the organization’s efforts in this area are primarily driven by legal and regulatory frameworks,

reflecting its commitment to compliance and broader responsibility to environmental stewardship.

In addition, for the purposes of the Double Materiality Analysis the Group leveraged its existing stakeholder engagement output (i.e. existing

employee surveys, investor and client and market feedback, etc.) to identify potentially additional priority topics coming from its stakeholders.

For further information around the Group’s overall stakeholder engagement process and involvement please refer to [SBM-2] Interests and

views of stakeholders.

[E4.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

The Bank has not identified any actual and potential impacts on biodiversity and ecosystems either on their own operational sites or sites

under their operational control, nor they have specified any activities negatively affecting biodiversity sensitive areas and affect threatened

species. Specifically, there are no material negative impacts regarding land degradation, desertification or soil sealing and their portfolios of

investment activities have all the required environmental terms and conditions. However, biodiversity has been defined as material only in

relation to the Bank’s downstream value chain and the overall portfolio of investments.

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[E4-2] Policies related to biodiversity and ecosystems

Key Environmental and Biodiversity Policies

The Group adopts a proactive approach to the management of ESG risks, with particular emphasis placed on risks arising from climate and

environmental change, which is already a key component of its Risk Management. Thus, it has set a series of key policies to manage material

sustainability matters such as the Environmental Risk Management Policy on Legal Entities Lending and the ESG in Loan Origination. For

further details about these policies as well as the monitoring process please refer to [E1-2] Policies related to climate change mitigation and

adaptation.

To further mitigate its impact on biodiversity, the Group maintains an exclusion list to determine which activities are prohibited from being

financed. Specifically, the Bank prohibits financing towards:

• Activities prohibited by host country legislation or international conventions relating to the protection of biodiversity resources or

cultural heritage.

• Drift net fishing in the marine environment using nets in excess of 2.5 km in length.

• Conversion of natural forests into plantation.

• Wholesale and retail trade of thermal coal.

• Any activity involving significant degradation, conversion or destruction of the sites included in the Natura map

As of January 1, 2024, the Group has expanded its Exclusion List to encompass additional activities with environmental impact, such as the

conversion of natural forests into plantation.

The Group’s exclusion policy to allocate zero financing to targeted activities harming species diversity, habitats and waterbodies pertains to

the downstream scope of its value chain. The established commitments apply to all the Group’s operations, in every country where it

operates.

Implementation of biodiversity-related policies

In the context of ESG and Climate Risk Governance, Alpha Services and Holdings Group has implemented a comprehensive structure,

addressing relevant decision making and implementation at all levels. Further to that in E1 includes all third-party standards or initiatives the

Group commits to regarding the policy implementation. More details for this structure please refer to [E1-2] Policies related to climate change

mitigation and adaptation.

Stakeholder engagement for policy setting and implementation

Stakeholders' engagement plays an important role in introducing new policies. Thus, the feedback from Investors the Sustainable lending

strategy, Sustainable Finance Framework, the Group introduced in order to reduce Bank’s overall environmental impact. In response to

Regulators’ expectations, the Group implemented Climate Risk Management, ESG criteria in all lending and investment decisions, and Risk and

Capital Strategy incorporating ESG criteria. Customer feedback also influenced the development of the Sustainable Finance Framework,

Transition plans for clients, and ESG-related products and services.

Therefore, there are relevant policies that are available on the ESG and Sustainability section of the Alpha Services and Holdings website in

both Greek and English languages to address the different stakeholder groups:

• Environmental Management System

• Sustainable Finance Framework and External Review

These policies are actively shared with affected stakeholders through direct communications and employee ESG awareness programs.

Specifically, all Employees have access to the policies through ABiD on Intranet – internal Services and Holdings website. For stakeholders

implementing policies, including investors, the Groupensures access through regular updates, sustainability reporting, and dedicated investor

engagements. These methods include participation in conferences, briefings, and the publication of detailed frameworks, such as the SFF and

the Climate-Related, Environmental, Social, and Governance Risk Management Policy, which outline the bank's commitments and operational

integration of ESG standards.

Relation of Policies with Biodiversity and Ecosystems matters

The Group acknowledges that its current biodiversity and ecosystems-related policies are still under development to fully address the specific

subject matters outlined in the DP. However, it is committed to progressively integrating these aspects into its operational and financing

frameworks. Below is the current status and alignment of policies with the subject matters.

a) Contribution to direct impact drivers on biodiversity loss:

i. Climate Change: The Group’s policies address climate change indirectly through its focus on decarbonization and support for

renewable energy and energy-efficient projects, but these measures do not currently target biodiversity impacts directly.

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ii. Land-Use Change: While land-use assessments are part of the ESG risk review for projects, the policies do not comprehensively

address land artificialization, freshwater-use change, or sea-use change impacts. These gaps are recognized and planned for future

iterations of the policies.

iii. Direct Exploitation: The Group’s exclusion list explicitly prohibits financing activities such as deforestation and overfishing, but

further integration of biodiversity-specific exploitation metrics into the due diligence process is still under development.

iv. Invasive Alien Species: This is not explicitly addressed in current policies but could be included in future updates as part of the

Group’s evolving biodiversity strategy.

v. Pollution: Policies currently address pollution risks, particularly in industrial projects, through ESG due diligence, but direct links to

biodiversity impacts are not yet systematically incorporated.

b) Impacts on the State of Species:

The Group does not currently have detailed mechanisms to assess impacts on species population sizes or extinction risks. Biodiversity

considerations are indirectly addressed by excluding funding for activities in protected areas, but further development of species-specific

impact monitoring is required.

c) Impacts on the Extent and Condition of Ecosystems:

Ecosystem impacts, including land degradation and soil sealing, are partially addressed through ESG risk reviews and exclusion of certain

activities. However, a comprehensive ecosystem health monitoring framework is not yet in place.

d) Impacts and Dependencies on Ecosystem Services:

Dependencies on ecosystem services, such as carbon sequestration and water provision, are considered in project evaluations where relevant,

but these are not yet systematically linked to biodiversity impacts across the portfolio.

The Group applies, maintains and updates the exclusion list to determine specific activities, which are not allowed to be financed. The criteria

for exclusion span across various environmental and social matters. The Group's exclusion list is in compliance with the EBRD Environmental

and Social Exclusion List as well as with the EBRD Referral List. The exclusion list is part of the Climate related, Environmental, Social and

Governance Risk Management Policy on Group’s Business Lending which incorporates activities related to biodiversity and ecosystems. Please

refer to [E4-2] Policies related to biodiversity and ecosystems for more information on the exclusion list.

In addition, following the ESG risk categorization at the obligor/project/lending transaction level and depending on the outcome (described in

detail in the relevant Credit Policy Manuals), an ESG Due Diligence is carried out based on specific evaluation criteria, defined as “Performance

Standards”, which reflect those of EBRD. One of the ESG evaluation criteria describes potential risks and impacts on biodiversity conservation

and sustainable management of living natural resources. All obligors/projects of the Group are required to manage the ESG performance

stemming from their business activity to this domain. When the outcome of the ESG assessment is non-sustainable Medium or High Risk

financing and the request under consideration concerns a dedicated purpose investment nature new financing e.g. project finance

(infrastructure, energy, etc.), construction / expansion / purchase of real estate including industrial premises, hotel and tourism units, a due

diligence is carried out on the basis of which, if required, a corrective action plan is compiled which should be implemented in a specific

timeframe by the client.

In addition to all the policies described above, the Group has established an Environmental Management Policy since April 2019 that sets the

framework for the Group’s Environmental Management, aiming at improving its environmental performance, its compliance with the

institutional and regulatory framework on environmental issues and ensuring the effective use of natural resources. According to the Policy, an

Environmental Management System (EMS)- certified with ISO14001- is developed according to international standards, setting the framework

for the monitoring, management and improvement of the environmental impact of its activities. The EMS monitors the Bank's environmental

performance related to its operations and assesses financed projects on the basis of environmental and social risks.

Alpha Bank, through its Environmental Management System (EMS), indirectly addresses the impacts related to biodiversity and ecosystems,

recognizing their importance for its business operation and model. Although there is no specific reference on biodiversity and ecosystems as

separate entities, the EMS incorporates procedures for assessing and managing environmental and social risks that touch upon natural

systems and the challenges they face.

Material Dependencies: The Group recognizes its dependence on material resources derived from ecosystems. Through the EMS, it identifies

and assesses the environmental aspects of its activities that interact with natural ecosystems, such as energy and water use, emissions, and

resource management. The emphasis on efficient resource use directly correlates the recognition that the sustainability of business activities is

inextricably linked to the health of natural systems.

Physical Risks: The EMS includes the assessment of environmental impacts and risks arising from extreme weather events or other natural

disasters (physical risks). The Group examines the impact of these phenomena on its operations and business model and takes measures to

minimize them.

Transition Risks: By integrating non-financial criteria into its credit assessments, the Groupproactively addresses the risks of transitioning to a

more sustainable economy. By evaluating financed projects based on environmental and social standards, the Group reduces its exposure to

businesses or sectors that may be negatively affected by regulatory changes, reputational issues, or economic challenges related to

biodiversity loss or ecosystem degradation.

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Opportunities: The Group recognizes the opportunities arising from promoting sustainability. It encourages green financing and offers

products that help its Customers improve their environmental performance. In this way, The Group seeks to seeks to contribute to the growth

of sustainable investments and services, while also contributing to ecosystem protection.

Sustainable Land and Agriculture Practices

In agriculture involving animals, Group prohibits financing activities such as force-feeding ducks and geese, fur factory farming, and any other

activities deemed illegal under national or international laws or subject to phase-out bans. To mitigate specific sectoral risks—such as

managed grazing, prevention of overgrazing, large-scale livestock farming, wastewater management, waste management, air emissions,

animal feed, disease control, responsible use of antibiotics, and ensuring animal welfare—the Group conducts Environmental and Social risk

due diligence through qualified personnel in accordance with required legislation. As of December 2024, agriculture represents only a small

portion of the Group’s current loan portfolio.

Sustainable Sea and Ocean Practices

Furthermore, the Group prohibits financing drift net fishing activities using nets longer than 2.5 km to mitigate risks in fisheries and

aquaculture. To address other sector-specific risks—including fish types, bycatch, organic waste management, petroleum management,

wastewater and effluents, air emissions, solid waste management, plant-based feeds from sustainable agriculture, cultivation of native species

in bag nets or closed-wall sea-pens, cultivation of non-native species in land-based tanks, risk prevention for local wild populations, stocking

densities to minimize disease outbreaks, net loss prevention in fish protein yield, water management, discharges and effluents, soil erosion

and sedimentation, and the use of fertilizers and chemicals—the Bank conducts Environmental and Social due diligence through technically

qualified personnel in accordance with required legislation.

Deforestation Practices

Finally, to prevent environmental and social risks associated with forestry projects, the Group Credit Policy prohibits financing commercial

logging operations in primary tropical moist forests, and the production or trade of wood or other forestry products unless sourced from

sustainably managed forests.

To address sector-specific risks such as water management, responsible use of fertilizers and pesticides, alternatives to chemical inputs,

hazardous materials management, soil erosion, fire management, reforestation with native species, and promoting multi-age and multi-

species forests over monocultures, the Group conducts environmental and social risk due diligence through qualified personnel in accordance

with required legislation. As of December 2024, forestry constitutes only a small portion of it’s loan portfolio.

[E4-3] Actions and resources related to biodiversity and ecosystems

Biodiversity and Ecosystem related Actions

To remain compliant with its exclusion policy, the Group retains a commitment to allocate zero finance to targeted activities harming species’

diversity, habitats and waterbodies. This action was achieved for the reporting year as no new financing volumes were allocated to any

exclusionary categories. This expects to remain unchanged as the Bank commits to its target in the future and is expected to continue over the

short-, medium, and long-term horizons.

The Group’s aim of zero financing towards targeted activities harming species diversity, habitats and waterbodies, pertains to its downstream

value chain. The established commitment applies to all Group’s operations, in every country where it operates and affects individuals,

corporates and SMEs. This commitment took effect in FY23 and the target has been achieved for FY23 and FY24.

Additionally, the implementation of this commitment contributes directly to Group’sbroader sustainability objectives, particularly aligning with

SDG 15 “Life on Land.” It supports the Group’s strategy to minimize its environmental footprint and safeguard biodiversity by financing only

those activities that meet strict environmental criteria as outlined in its Climate-Related and ESG Risk Management policies.

Regarding geographies and stakeholder groups, this commitment applies comprehensively across all countries of operation, primarily affecting

individuals, SMEs, and corporates in the Group’s downstream value chain. While the commitment has been implemented globally, a significant

focus remains on the Greek market, given the regional impact of activities on local biodiversity and ecosystems.

Further to that, starting in 2021 and continuing through 2026, the Bank has also set an additional action to collaborate with Reforest Action

and subsequent promotion of impact investing to private banking Customers. Since 2021 as part of the 'Reforest Action' initiative, more than

60,786 trees have been financed for planting and specifically in 2024, nearly 4,648 trees have been financed for planting. The reforestation

projects have been implemented in critical areas across Greece, including the Arona forest in Katerini, Thessaloniki forest, Pierian Mountains

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forest, and Kastanolongos forest in Southern Evia. This effort has resulted in the storage of 697.2 thousand tons of CO2 and the creation of

14,052 natural shelters for wild animals according to the certificates the Group has received for the completion of each initiative.

Regarding the operational and upstream value chain segments, the Group has not identified any material impacts related to biodiversity and

ecosystems.

The Group confirms that its own operational model, primarily centered on financial services, does not inherently or directly generate issues

requiring remediation actions.

However, in cases where harm has occurred due to external circumstances, such as natural disasters, Alpha Services and Holdings Group has

historically supported affected communities through financial assistance and social programs.

In response to the floods in Thessaly in 2023, Alpha Bank immediately implemented a comprehensive support plan for affected individuals and

businesses. This included the suspension of loan repayments for impacted Customers, providing immediate financial relief to those who faced

significant losses. Additionally, the Group allocated funds to support the restoration of essential infrastructure and collaborated with local

authorities to address urgent community needs. These efforts directly contributed to the recovery of thousands of individuals and businesses

in the region.

Similarly, during the wildfires that struck the island of Rhodes in 2023, the Group distributed financial aid to local residents and businesses to

help address urgent needs, such as rebuilding damaged properties and restoring livelihoods. Moreover, the Group supplied essential

equipment and resources to emergency responders and participated in reforestation efforts to mitigate the long-term environmental and

biodiversity impact of the fires.

As such, while the nature of the Group’s services minimizes direct instances of material harm necessitating remedy, its frameworks and

initiatives ensure that any identified impacts are effectively addressed in alignment with best practices and stakeholder expectations.

Resources for implementation of actions

It is important to mention that for the implementation of Bank’s action plan does not require significant operational expenditures (OpEx)

and/or capital expenditures (CapEx). Thus, the Bank has not set any significant current or future financial and other resources allocated to the

implementation of the action plan.

Worth noting that no biodiversity offsets have been used in the actions.

[E4-4] Targets related to biodiversity and ecosystems

The Alpha Services and Holdings Group has identified through its Materiality Analysis the potential negative impacts on biodiversity and

ecosystems through its financial products/services. In order to promote the local habitats and species the Group is committed and has set the

target to zero financing to targeted activities harming species diversity, habitats and waterbodies. This represents an ongoing target that

serves to mitigate any material impacts the Group has on biodiversity and ecosystems through the provision of its financial products and

services. The Group ensures it will not finance transactions that impose environmental or social threat, through the incorporation of the

“Climate related, Environmental, Social and Governance Risk Management Policy on Group’s Business Lending” in the existing Credit Risk

Management Framework and the Group’s Credit Policy.

This target was implemented in 2023, is absolute, with no permissible thresholds, and continues to be in effect from fiscal year 2023 onwards.

Since the target took effect in FY23, it has been achieved in the fiscal years since as no new financing volumes have been allocated to such

activities. Progress and compliance are tracked through regular monitoring of financing activities and the established credit risk management

processes, along with the exclusion of harmful activities as per the Group’s expanded Exclusion List.

The Group ’s target relating to biodiversity and ecosystems serves to mitigate its downstream material impacts and is applicable everywhere

(i.e., in each country) the Group has its operations. The initial focus for the Group’s sustainable lending targets is its largest entity, Alpha Bank

S.A., with the targets having been expanded across the Group for 2024.

Moreover, this commitment aligns with the Group’s broader sustainability objectives under the SSF, which prioritizes financing that supports

renewable energy, energy efficiency, and biodiversity preservation while systematically excluding harmful environmental practices. These

actions reflect the Group’s alignment with the UN Sustainable Development Goals and its commitment as a member of the Net Zero Banking

Alliance to mitigate biodiversity loss and achieve net-zero greenhouse gas emissions by 2050.

The Group's commitment to maintaining zero financing is an ongoing objective, evaluated annually. Consequently, the baseline value is

anticipated to consistently remain at zero each year.

Target setting process

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The Group set its sustainable lending targets for the purpose of aligning its portfolio with the Paris Agreement objectives and is in the process

to develop more targets on material sustainability matters by actively leveraging its Materiality Analysis and SFF to identify areas of priority

and impact. The finalization will consider both local and international sustainability contexts.

To ensure the robustness of its existing target of Zero financing, Alpha Services and Holdings utilizes methodologies and frameworks provided

by the organizations and initiatives it participates in or supports. As a signatory of the Net-Zero Banking Alliance (NZBA), the Group is aligning

its long-term objectives with the net-zero pathways, using science-based scenarios to measure and track emissions reductions. Through the

UN Principles for Responsible Banking (PRB), the Group has integrated the SDGs and Paris Agreement objectives into its business model.

Further, the Group adheres to the Green Bond Principles (2021) and Green Loan Principles (2021) to classify and track sustainable financing

activities, ensuring that these meet globally recognized sustainability standards. As part of its membership in the UN Environment Program

Finance Initiative (UNEP FI), the Group applies best practices to assess risks and opportunities in its financing activities, particularly related to

climate and biodiversity impacts.

To enhance transparency and align with international policy goals, the Group incorporates guidance from the TCFD in its reporting and

integrates climate-related risks into its decision-making processes. Furthermore, through its participation in the United Nations Global

Compact (UNGC), the Group ensures its sustainability targets address broader social and environmental considerations.

The targets under development also align with Greece’s Recovery and Resilience Plan and other relevant EU and national policies. The

methodologies incorporate both quantitative metrics (e.g., emissions reductions, biodiversity impacts) and qualitative indicators (e.g.,

governance improvements), ensuring progress is measurable, traceable, and aligned with the Bank's commitment to sustainable development.

While more targets are included, Alpha Bank remains committed to maintaining transparency through regular updates in its Sustainability

Report and other disclosures.

Stakeholder Involvement in Target Setting

Targets engagement to diverse stakeholders, including regulators, Customers, and community representatives takes place through structured

dialogue and collaborative platforms, with the most recent example of the materiality assessment. By actively participating in initiatives like

the UNEP FI, the bank ensures that its goals reflect broad societal priorities and address key sustainability challenges. For more details on the

overall stakeholder engagement process please refer to [SBM-2] Interests and views of stakeholders.

Target Progress

The Group’s zero financing target for activities with an adverse impact on species diversity, habitats and waterbodies is an absolute target

which is measured through two KPIs: 1) new financing volumes in Euro million (Zero volume) and 2) Operational sites owned, leased, managed

in or adjacent to protected areas and areas of high biodiversity value outside protected areas. The target was achieved for FY23 and FY24 with

no new financing volumes announced for either metric category.

Target thresholds

Alpha Services and Holdings Group has not identified nor used a specific methodology to identify any ecological thresholds and allocations of

impacts for their target as this is described in the abovementioned paragraphs.

The Group ensures compliance with the target of absolute zero financing on all activities included in Group’s exclusion list, through its robust

credit risk management processes, which monitor all lending activities against the established criteria. As disclosed, this target is absolute,

with no permissible thresholds.

It is worth mentioning that Alpha Services and Holdings has laid the groundwork for integrating biodiversity considerations into its broader

sustainability strategy through existing frameworks such as the SFF. Last but not least, existing governance structures, including the Corporate

Governance, Sustainability, and Nominations Committee, ensure that biodiversity-related considerations remain integral to the Group’s

sustainability agenda.

Target Alignment with international and national policies and legislations

Alpha Services and Holdings Group leverages the European Recovery and Resilience Facility (EU RRF). Specifically, under the framework of

Greece’s National Recovery and Resilience Plan (NRRP), the the Bank supports projects classified under the green transition pillar, which

allocate significant resources to biodiversity protection. Through the RRF, the Group finances projects aimed at urban regeneration,

protection of biodiversity, and enhancements in environmental infrastructure, including investments in Civil Protection Centers. These

activities contribute to the preservation and sustainable management of ecosystems while fostering the Group's broader sustainability

objectives. The RRF’s mandates for climate and biodiversity are fully integrated into the Group’s SFF, ensuring that biodiversity-related

financings align with EU Taxonomy criteria and other relevant environmental standards.

Targets reflected in Value Chain

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The Group recognizes the critical importance of biodiversity in its downstream value chain. Through its downstream value chain assessment,

the Group has identified key biodiversity-related risks and opportunities, including dependencies on ecosystem services and the impacts of

financed projects on habitats and ecosystems. The Group’s activities in sectors such as real estate, tourism, and infrastructure are analyzed

using tools like UNEP FI's Portfolio Impact Analysis to identify and manage biodiversity impacts.

The Group’s target relating to biodiversity and ecosystems serves to mitigate its downstream material impacts and is applicable everywhere

(i.e. in each country) the Bank has its operations. The initial focus for the Group’s sustainable lending targets is its largest entity, Alpha Bank

S.A., with the targets having been expanded across the Group for 2024.

Finally, the Group has not used biodiversity offsets as part of its target-setting and their target pertains to avoidance on the mitigation

hierarchy.

Target effectiveness, ambitions and progress

Alpha Services and Holdings Group tracks the effectiveness of its policies and targets in relation to material sustainability-related impacts,

risks, and opportunities. This is implemented through:

1. structured approach:

• governance frameworks as SFF and External Framework Review by ISS Corporate Solutions

• periodic assessments as Self-Assessment and annual report for Principles for Responsible Banking

• qualitative and quantitative indicators that are aligned with international standards such as the EU Taxonomy, the UNEP FI Principles

for Responsible Banking, and Alpha Services and Holdings Group’s SFF.

2. mechanisms, not limited to:

• Policy Effectiveness Tracking: Regular reviews of environmental, social, and governance (ESG) risks and integration into credit

assessment processes to ensure that clients meet sustainability thresholds.

• Defined Levels of Ambition: Commitment to achieving net-zero greenhouse gas emissions by 2050, operationalized through interim

science-based reductions and sustainable financing expectations.

• Qualitative and Quantitative Indicators: Metrics such as exposure to transition-sensitive sectors, greenhouse gas emissions metrics

and biodiversity impacts indicators to evaluate progress and manage risks.

• Baseline Assessments: Reference points for progress measurement, such as emissions intensity benchmarks and sectoral

sustainability profiles.

The Group implements a process of ESG risk categorization and due diligence during credit approvals. The governance structure, including the

Corporate Governance, Sustainability, and Nominations Committee, ensures oversight and accountability at all levels. The Group’s strategic

focus areas—such as fostering a sustainable economy, achieving net-zero targets, and improving financial inclusion—are integrated into

operational policies and stakeholder engagement efforts.

For transparency, these efforts are disclosed annually in Alpha Services and Holdings’ Annual Sustainability Report and other related

disclosures, which are externally assured.

[E4-6] Anticipated financial effects from material biodiversity and ecosystem-related risks and opportunities

Anticipated Financial effect of material biodiversity and ecosystems-related risks

Information regarding the assessment performed to identify material biodiversity and ecosystems-related risks is provided under [IRO-1]

Description of the process to identify and assess material impacts, risks and opportunities.

Dependency Analysis

Information regarding the dependency analysis performed by the Group is provided under [IRO-1] Description of the process to identify and

assess material impacts, risks and opportunities.

Anticipated Financial effect of material biodiversity and ecosystems-related opportunities

Information regarding the assessment performed to identify material biodiversity and ecosystems-related opportunities is provided under

[IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

ESRS E5 - RESOURCE USE AND CIRCULAR ECONOMY

[Ε5-1] Policies related to resource use and circular economy

Key Environmental and resource Use Policies

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The Alpha Services and Holdings Group adopts a proactive approach to the management of ESG risks, with particular emphasis placed on risks

arising from climate and environmental change, which is already a key component of its Risk Management. Thus, the Group has set a series of

key policies to manage material sustainability matters such as the Climate related, Environmental, Social and Governance Risk Management

Policy on Group’s Business Lending and the ESG in Loan Origination. For further details about these policies as well as the monitoring process

please refer to [E1-2] Policies related to climate change mitigation and adaptation.

The Group’s exclusion policy pertains to the downstream scope of its value chain. The established commitments apply to all the Group’s

operations, in every country where it operates.

Implementation of resource use-related Policies

In the context of ESG and Climate Risk Governance, Alpha Services and Holdings Group has implemented a comprehensive structure,

addressing relevant decision making and implementation at all levels. For more details on this structure, you may refer to [E1-2] Policies

related to climate change mitigation and adaptation.

All third-party standards or initiatives the Group commits to regarding the policy implementation are listed also in E1 as referred above.

Stakeholder Involvement in Policies

In accordance with the Group’s Environmental Policy, it maintains ongoing communication with its shareholders, clients, partners, and

government entities concerning sustainability matters. It consistently publishes reports detailing the outcomes of its environmental

initiatives.

After gathering feedback from Investors, the Group introduced the Sustainable lending strategy, SFF, and Reduction of the Group’s

environmental impact. For more information on relevant stakeholder involvement in policies and how the aforementioned policies are made

available to stakeholders, please refer to [E4-2] Policies related to biodiversity and ecosystems.

In its financing activities, the Group actively promotes circular economy practices among its clients by integrating environmental and social

criteria into credit assessments. Projects focusing on recycling, waste reduction, and the use of recycled materials are prioritized in the Group's

SFF, which aligns with the EU Taxonomy for environmentally sustainable activities. The Group's exposure to circularity-related projects for the

full FY 2024 amounted to Euro 1.83 million.

Additionally, through the financial services, the Group encourages clients to transition away from reliance on virgin resources by adopting

circular economy principles as ESG criteria are embedded throughout the financing process to ensure alignment with sustainability objectives

at every stage of the credit lifecycle.

To strengthen these efforts, the Group has established robust monitoring mechanisms, overseen by the Corporate Governance, Sustainability,

and Nominations Committee, to assess and track the environmental impact of financed projects.

The Group’s approach to sustainable sourcing and the use of renewable resources is firmly integrated into its business practices and aligned

with international sustainability standards, including the EU Taxonomy for environmentally sustainable activities and its ISO 14001-certified

Environmental Management System (EMS).

In its financing activities and broader economic contributions, the Group prioritizes funding for projects and businesses that advance the use of

renewable resources and sustainable practices. Financing is directed towards industries such as renewable energy, green buildings, and

sustainable agriculture according to the SFF.

[Ε5-2] Actions and resources related to resource use and circular economy

Resource Use and Circular Economy key actions

The Group has a negative impact to Resource Security (which affects the development of a Circular Economy) through the Group’s

products/services and business relationships.

As a result, the Group has developed a list of green and social activities that are eligible for sustainable financing which has been implemented

for FY24 and will continue to be applied in the future. These activities include five distinct themes: Energy Efficiency, Renewable Energy,

Sustainable Transport, Resource Efficiency and Pollution Control, and Green Buildings. Thus, the Group has committed to (re)finance:

• Processes and infrastructure that facilitate recycling. Examples: waste management companies which incorporate recycling and

sustainable waste management practices.

• New technology to facilitate maximum use of waste. Examples: separation of materials or energy efficient recycling technology.

• Treatment of bio-waste through anaerobic digestion in dedicated plants with the resulting production and utilization of biogas and

digestate.

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• Treatment of bio-waste through composting (aerobic digestion) in dedicated facilities with the resulting production and utilization of

compost.

• Companies/projects that substitute virgin raw materials with secondary (recycled) materials originating from materials and resources

recovery.

• Companies/projects that increase the capacity utilization of a product or asset during its useful life through sharing business models.

Sharing is circular when it optimizes the utilization of the product or asset.

• Repair activities and activities that facilitate reduction in material use. Examples: renting electric appliances instead of buying or

community-based equipment sharing, etc.

Alpha Services and Holdings Group is implementing sustainability into its operations and financing activities according to its SFF and in

alignment with global sustainability goals, including the Paris Agreement, the EU Green Deal, and the United Nations Sustainable Development

Goals (SDGs).

The Group provides funding for projects that promote recycling, composting, and innovative waste-to-energy solutions, including the

production of biogas and secondary materials with an established goal of achieving EUR 4.4 billion in sustainable financing disbursements by

2026.

Regarding geographies and stakeholder groups, actions applicability please refer to the relevant section in [E4-3] Actions and resources related

to biodiversity and ecosystems.

To support remediation for communities impacted by material environmental harms, the Group has financed projects aimed at improving

waste management infrastructure in regions with historically inadequate waste processing systems. The Epirus Region and Peloponnese

Region PPP projects exemplify this commitment, directly reducing pollution, minimizing harmful environmental impacts, and improving public

health outcomes. These efforts address the systemic harm caused by improper waste management, ensuring compliance with international

environmental standards while benefiting local communities.

The Epirus plant, operational since 2019, ensures at least 17,000 tonnes of recyclable materials are recovered annually, contributing to

national recycling targets. The plant generates 10,800 kilowatt-hours of green energy every year, enough to power 3,000 households, while

preventing the release of 12,000 tons of carbon dioxide into the atmosphere. Additionally, it produces 25,000 tonnes of compost annually,

supporting sustainable agricultural practices and reducing reliance on chemical fertilizers.

The Peloponnese plant, which is expected for completion in 2025, will prevent regional landfill waste, at least 65% of biodegradable materials

will be utilized, 50,000 tons of liquid waste will be diverted from landfills, and green energy will be generated to serve the needs of 6,000

households, while avoiding release of 24,000 tons of carbon dioxide into the atmosphere.

Resources for implementation of actions

Alpha Services and Holdings Group acknowledges the importance of allocating appropriate financial and other resources to effectively

implement its action plans. As a financial institution, the Group’s action towards circular economy as disclosed within this section in the

abovementioned paragraphs involve lending – financing activity. Consequently, traditional classifications of operational expenditures (OpEx)

and capital expenditures (CapEx) do not directly apply. Regarding the capital allocation for the implementation of Bank’s action plan please

refer to the relevant section in [E4-3] Actions and resources related to biodiversity and ecosystems.

[Ε5-3] Targets related to resource use and circular economy

Resource Use and Circularity Targets

The Group has identified through its Materiality Analysis the potential negative impacts on circularity (resources and waste) through its

financial products/services. In order to promote the reduction of waste generation and promotion of the principles of the circular economy in

alignment with SDG 12 “Responsible Consumption and Production” the Group monitors the financing provided in alignment with the Bank’s

SFF Green pillar - Resource efficiency and pollution control theme which targets loans for recycling and reuse and circular economy.

The Bank sets an overall target for new sustainable financings of EUR 4.4 billion for 2024-2026 which includes dedicated purpose financing to

Companies/projects that substitute virgin raw materials with secondary (recycled) materials originating from materials and resources recovery,

Companies/projects that increase the capacity utilization of a product or asset during its useful life through sharing business models and

Repair activities and activities that facilitate reduction in material use.

In addition, the Bank measures and monitors the financing eligible and aligned to the EU Taxonomy objective for the transition to a circular

economy, in accordance with Article 8 of the EU Taxonomy.

The Group’s target applies to its downstream value chain and is applicable everywhere (i.e., in each country) that there areoperations. The

initial focus for the Group’s sustainable lending targets is its largest entity, Alpha Bank S.A., with the targets having been expanded across the

Group for 2024.

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TABLE 47 TARGET - CIRCULARITY-RELATED SUSTAINABLE FINANCING

Target description

Target

level

Absolute/

Relative

Baseline

value

Baseline

year

Target

Year

Scope

Progress in 2024

KPIs

Allocate Euro 4.4

billion to new

Sustainable

Financings by 2026

(SFF aligned loans

and bonds)

Euro 4.4

billion

Absolute

N/A

2024

2026

Banking sector,

Downstream

Alpha Bank S.A.

• Euro 1.809 billion

overall target

Euro

1.831

million

Recycling

and

Reuse

New financing

volumes

(in Euro

million)

Targets Assumptions, Methodologies, Scenarios, Data Collection and Alignment with International Policies

The Bank is in the process to develop more targets on material sustainability matters for the organization and is actively leveraging its

Materiality Analysis and SFF to identify areas of priority and impact. The finalization will consider both local and international sustainability

contexts.

To ensure the robustness of its existing target of Euro 4.4 billion towards new Sustainable Financings including circularity-focused projects by

2026, Alpha Bank utilizes methodologies and frameworks provided by the organizations and initiatives it participates in or supports. As a

signatory of the Net-Zero Banking Alliance (NZBA), the Bank is aligning its long-term objectives with the net-zero pathways, using science-

based scenarios to measure and track emissions reductions. Through the UN Principles for Responsible Banking (PRB), Alpha Bank has

integrated the SDGs and Paris Agreement objectives into its business model.

Further, Alpha Bank adheres to the Green Bond Principles (2021) and Green Loan Principles (2021) to classify and track sustainable financing

activities, ensuring that these meet globally recognized sustainability standards. As part of its membership in the UN Environment Program

Finance Initiative (UNEP FI), the Bank applies best practices to assess risks and opportunities in its financing activities, particularly related to

circular economy and resource (re)use.

To enhance transparency and align with international policy goals, the Group incorporates guidance from the TCFD in its reporting and

integrates climate-related risks into its decision-making processes. Furthermore, through its participation in the United Nations Global

Compact (UNGC), the Group ensures its sustainability targets address broader social and environmental considerations.

The targets under development will also align with Greece’s Recovery and Resilience Plan and other relevant EU and national policies. The

methodologies will incorporate both quantitative metrics (e.g., total amount allocated to sustainable financing, total financing specifically to

renewable energy projects, percentage reduction in financing activities that negatively impact the environment) and qualitative indicators

(e.g., governance improvements, programs initiated to educate stakeholders, awards and recognitions received), ensuring progress is

measurable, traceable, and aligned with the Group's commitment to sustainable development.

Further engagement to diverse stakeholders, including regulators, Customers, and community representatives takes place through structured

dialogues and collaborative platforms, with the most recent example of materiality assessment. More details on the stakeholders engagement

process please refer to the relevant section in [SBM-2] Interests and views of stakeholders. By actively participating in initiatives like the UNEP-

FI, the Group ensures that its goals reflect broad societal priorities and address key sustainability challenges.

While more targets are included, Group remains committed to maintaining transparency through regular updates in its Sustainability Report

and other disclosures.

Progress against targets

Since the existing commitment of 4.4 billion EUR towards new Sustainable Financings including circularity-focused projects by 2026 took effect

in FY23, an additional KPI metric has been introduced to measure progress more effectively. The metric is an absolute number, EUR 1,831

million and no significant assumptions behind it are taken. The methodology used for this metric is based on the activities incorporating

circular economy principles in alignment with the SFF and SDG 12.

The first disclosure year was FY23 when the commitment took effect. Although no trend analysis the target is currently in line as initially

planned for FY24 and ongoing until 2026.

The Group has established voluntary targets, such as reaching a 4.4 billion sustainable disbursement goal for 2024–2026 and achieving net-

zero emissions by 2050 under Net-Zero Banking Alliance, reflect the bank’s ambition to exceed compliance standards and align with global best

practices.

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The European Recovery and Resilience Facility (EU RRF) plays a critical role in Alpha Bank’s sustainability strategy. RRF loans are aligned with

Greece’s Recovery and Resilience Plan, financing projects that enhance resource efficiency, promote circular economy principles, and

accelerate the green energy transition. While compliance with RRF requirements is mandatory, Alpha Bank voluntarily extends these principles

to its broader lending portfolio, further supporting the green transition of SMEs and other key sectors.

The Group’s broader sustainability strategy integrates the Paris Agreement and the European Circular Economy Action Plan.

Targets Applicability

The Group acknowledges the importance of improving disclosures for its subsidiaries and entities in other countries. As disclosed in the 2023

Sustainability Report, the Group aims to standardize its materiality assessments and enhance transparency across all regions of operation.

Therefore, for entities or subsidiaries not explicitly covered in the present Sustainability Statement, the Group confirms that efforts are

underway to extend these frameworks and assessments. Reasons for this stem from varying stages of implementation of standardized

materiality assessments and data collection processes across regions such as local regulatory requirements, operational structures, and

resource availability

[Ε5-6] Anticipated financial effects from material resource use and circular economy-related risks and opportunities

Anticipated Financial effect of circular economy-related risks

Please refer to [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities.

Anticipated Financial effect of circular economy-related opportunities

In order to assess the anticipated financial effect, the Group has evaluated if any material circular economy related opportunities (EU

Taxonomy aligned and other sustainable financings according to the Group SFF) are anticipated in the short-, medium- and long-term.

Please consult [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities for information on

opportunities related to circular economy across the three time horizons evaluated.

SOCIAL INFORMATION

ESRS S1 - OWN WORKFORCE

[S1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

The Group's workforce includes only Employees who can be materially impacted by its operations in the scope of its disclosure. The

comprehensive approach to sustainability ensures that all material impacts on the Group’s workforce are considered and disclosed in

accordance with ESRS 2.

The workforce comprises full-time and part-time Employees, both on permanent and fixed-term contracts. Additionally, the Group engages

self-employed individuals and people provided by third-party undertakings primarily engaged in employment activities. These third-party

workers include contractors and service providers, who support the Group's operations in areas such as maintenance, cleaning, and security,

but data is not available for non-Employees.

The Group ensures that there are no material negative impacts in the areas of its operation. The Group's operations are primarily within the

EU, where stringent regulations and oversight mechanisms are in place to prevent issues such as child labor, forced labor, or/and compulsory

labor. Additionally, the Group has robust policies and procedures (as referenced in the section [S1-1] Policies related to own workforce, and

[S1-2] Processes for remediate negative impacts and channels for own workforce to raise concerns) to address and mitigate individual

incidents, ensuring prompt and effective responses to minimize any adverse effects.

Activities of the Group that result in material positive impacts on its own workforce include various initiatives aimed at improving the work

environment and employee well-being. These activities positively affect all Employees, including full-time and part-time Employees. The Group

runs several projects to ensure the well-being of its workforce as part of its strategy focuses on creating a safe, inclusive, and supportive work

environment for all. Some of the key topics we have identified as per the Double Materiality Assessment include:

Secure Employment: Implementing policies to ensure job security, offering long-term contracts, and minimizing layoffs through strategic

workforce planning. The above affects all Employees, particularly those in roles susceptible to automation or restructuring.

Social Dialogue: Establishing regular communication channels between management and Employees, creating forums for discussion, and

involving Employees in decision-making processes (e.g., talk to us, establishment of the Alpha Way Communities of Change Workshop etc.).

The above actions benefit all Employees, since it provides them with a “voice” in the organization.

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Freedom of Association: Supporting the formation of employee unions, ensuring the right to collective bargaining, and respecting workers'

rights to unionize.

Diversity: Implementing diversity and inclusion programs, promoting gender equality, supporting underrepresented groups, and ensuring

equal opportunities for all Employees, are some of the activities the Group promotes to help create a more supportive and inclusive work

environment that enhances employee satisfaction and overall organizational performance.

Training and Skills Development: Offering continuous learning opportunities, providing access to professional development courses, and

supporting career advancement through mentorship programs and through learning and development tools for all Employees, equally (e.g.,

Udemy). As a result, Employees are enabled to seamlessly adapt to modern work practices and evolving job roles. For the purposes of the

Financial Materiality Assessment the Group leveraged the RCSA inherent risk assessment outcome which identified Training and Skills

Development as a material inherent risk. This is due to Group's dependency on human capital, the ever evolving regulatory and technological

advancements, and therefore an increased need for continuous training of a large number of the Group Employees.

However, no material opportunities with current and anticipated financial effects on the Group have been identified.

It is noted that no operations at significant risk of incidents of forced labor or compulsory labor, either in terms of type of operations or in

terms of countries or geographic areas with operations considered at risk, are in place. Furthermore, there are no operations at significant risk

of incidents of child labor, as there are no countries or geographic areas with operations considered at significant risk of child labor incidents.

Importantly, there are no risks of harm for the Group’s own workforce, as the Group has not identified any groups of Employees with

particular characteristics, those working in particular contexts, or those undertaking particular activities who may be at greater risk of harm.

This assessment ensures that the Group's own workforce remains safe and well-supported in their roles.

Finally, no material risks or opportunities arising from impacts and dependencies on specific groups of people in the Group’s own workforce

have been identified through the double materiality assessment. The Group’s entire own workforce, and especially women, young

professionals and migrants, groups that usually face greater struggles in the workplace, remain safe and well-supported in their roles, with no

specific Employee groups being at greater risk of harm or benefiting disproportionately from the Group's initiatives.

Transitioning to greener operations may lead to changes in certain roles, with some becoming less relevant as the company adapts. To support

the Employees through this shift, the Group is committed to offering reskilling and upskilling programs, helping individuals develop new skills,

aligned to sustainable finance and green technologies.

The introduction of new technologies for greener operations, may necessitate updated health and safety protocols, including additional

training and respective equipment. Transition plans will also include policies that promote remote work and flexible hours to reduce

commuting-related carbon emissions. This aims at improving work-life balance, but may also require relevant adjustments.

By addressing these key areas, the Group aims to ensure a smooth transition, that minimizes negative impacts and maximizes positive

outcomes for all Employees.

[S1-1] Policies related to own workforce

The Group is committed to maintaining a responsible and inclusive work environment. To manage potential material impacts that may occur,

the following policies have been adopted:

Corporate Responsibility Policy

The Policy follows internationally acclaimed directives, principles, and initiatives to protect human rights, such as the Core Labor Conventions

of the International Labor Organization (ILO) and the Universal Declaration of Human Rights (UDHR). With reference to own workforce, the

Policy addresses the respect to human rights and renounces any form of child, forced or compulsory labor. At the same time, it recognizes the

right to form trade unions and the right of collective bargaining, which are established under national and international regulations. It also

promotes the respect towards the diversity of its workforce, fair renumeration and ensures the continuous training and education of the

Employees, and lastly, promotes health and safety of Employees at the workplace, and work life balance. The aforementioned principles are

endorsed across the Group, while the current policy refers to the Group’s subsidiaries in Greece and abroad where it holds a presence. The

monitoring of the Policy is operated by the Marketing and Public Relations Business Area and there are considerations for updating it in the

short-term time horizon.

Code of Conduct and Ethics

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Alpha Services and Holdings Group has introduced a Code of Conduct and Ethics policy, which has been approved by the BoD through the

Corporate Governance Sustainability and Nominations Committee. It describes the Group commitments and practices regarding its activities,

its management and the rules of conduct that apply to its Executives and Employees in their interactions not only with each other, but also

with transacting parties and Shareholders. The Group attaches great importance to matters of ethics and transparency and has in place clear

rules and regulations, established through the Personnel Regulations and the Acts of the General Management, regarding matters such as the

protection of personal data, the prohibition for Executives and Employees to accept gifts in the context of performing their official duties, as

well as potential cases of conflict of interest while conducting transactions.

The overall objectives of the policy are to uphold ethical business conduct, regulatory compliance, and corporate transparency across all

operations of Alpha Services and Holdings Group. The Code of Conduct and Ethics establishes the foundation for integrity, accountability, and

responsible corporate governance, ensuring alignment with the Group’s values and regulatory obligations.

This policy is directly linked to the material impacts, risks, and opportunities identified through the Group’s double materiality assessment,

such as ensuring ethical conduct, fair treatment, secure employment, social dialogue, and non-discrimination within Alpha Services and

Holdings Group. The Code supports a corporate culture, where employees are protected, empowered, and encouraged to uphold ethical

standards.

The process for monitoring adherence to this policy includes structured compliance frameworks, periodic internal audits, oversight by the

Corporate Governance Sustainability and Nominations Committee, and dedicated training programs. Additionally, whistleblowing mechanisms

and grievance procedures enable employees to report unethical behavior or violations.

The Alpha Services and Holdings Group respects and promotes human rights through the business policies it applies, its responsible supply

chain operation and its relationships with the Customers. More details about the Code are provided under [G1-1] Business conduct policies

and corporate culture.

Diversity and Inclusion

The Policy applies to the selection procedure for BoD Members and is also taken into consideration for the appointment of Alpha Bank S.A.’s

Senior Management and Employees.

The objectives of the Policy are to:

• Support and promote diversity on the BoD and Employees.

• Engage a broad set of qualities and competences when recruiting Members of the BoD and Employees, to achieve a variety of views

and experiences and to facilitate independent opinions and sound decision-making within the BoD.

• Aim at an appropriate representation of all genders within the BoD.

• Ensure that the equal opportunities principle is respected, when selecting Members of the BoD.

• Ensure equal treatment and opportunities for Employees of different genders.

When setting diversity objectives, the Alpha Bank S.A. should consider diversity benchmarking results published by competent

authorities, the EBA or other relevant international bodies or organizations.

The monitoring process for the Diversity and Inclusion Policy is ensured through continuous oversight and evaluation by the Corporate

Governance, Sustainability and Nominations Committee (CGSNC). This committee is responsible for assessing the implementation of the

policy, reviewing gender representation and overall diversity at the Board of Directors, Senior Management, and Employee levels within Alpha

Bank S.A.

As part of the annual evaluation of the Board’s effectiveness, the committee analyzes its composition, taking into account diversity in skills,

experience, and representation. If diversity objectives are not met, the committee investigates the underlying reasons and recommends

corrective actions to ensure compliance with the principles of equal opportunity and inclusion. Additionally, the policy is periodically

reassessed against diversity benchmarking results published by competent authorities such as the EBA or other relevant international

organizations, ensuring its alignment with regulatory requirements and industry best practices.

In accordance with corporate governance standards, the policy is reviewed every two years, with any necessary amendments submitted for

approval to the BoD, ensuring its continuous adaptation to the evolving needs of Alpha Bank and the broader diversity and inclusion

landscape. While the existing policy was initially established in 2021, it is expected to be updated in the short-term time horizon.

Violence and Harassment Prevention

The Group has a zero-tolerance approach to any form of harassment, including sexual harassment and domestic violence that could potentially

affect the workplace environment.

The violence and harassment policy, established in 2022, sets the framework for preventing and addressing workplace discrimination,

violence, and harassment, ensuring a respectful and dignified environment. The policy applies to:

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• all Employees

• contractors

• interns

• all related stakeholders

It establishes clear mechanisms for reporting, investigating, and taking appropriate actions to and resolve incidents confidentially and

impartially. Reports of workplace violence, harassment, or discrimination are assessed through a structured process that ensures fairness,

objectivity, and protection of all parties involved. The Evaluation Committee for Reports and Complaints is responsible for reviewing all

submitted cases and determining appropriate actions, with strict adherence to confidentiality principles and non-retaliation safeguards.

Support and protection for victims are prioritized, and the Group commits to raising awareness through training and resources to prevent

future occurrences. Any form of retaliation or malicious reporting is strictly prohibited, ensuring a safe reporting system and compliance with

legal obligations. The policy against violence and harassment at the workplace, in accordance with Law 4808/2021, explicitly covers

discrimination based on gender, race, color, ethnic or social origin, genetic characteristics, language, religion or beliefs, political opinions,

disability or health status, age, or sexual orientation.

The monitoring process for the Violence and Harassment Prevention Policy is structured in such a way so as to ensure its continuous

implementation and effectiveness. The Corporate Governance, Sustainability, and Nominations Committee (CGSNC) is responsible for

overseeing the enforcement of the policy, ensuring that incidents are managed in a manner consistent with legal and regulatory requirements.

Additionally, awareness and training programs are regularly conducted to reinforce the Group’s zero-tolerance approach and to educate

employees, contractors, and stakeholders on identifying and preventing workplace violence and harassment. Periodic internal reviews and

audits ensure compliance with the policy, while benchmarking against industry best practices and legal standards provides a framework for

continuous improvement.

The policy undergoes a formal review process every two years, during which its effectiveness is reassessed, and updates are proposed to the

Board of Directors as necessary. Any corrective actions required due to identified policy breaches or gaps are implemented to enhance

workplace safety and maintain a respectful and inclusive environment.

For further information, please refer to [S1-13] Training and skills development metrics below.

Career Framework

Alpha Services and Holdings Group is committed to providing structured growth opportunities, enhancing organizational effectiveness, and

establishing itself as a preferred employer.

To support these objectives, the Career Framework Policy establishes a comprehensive structure to define, evaluate, and manage roles within

the Group, ensuring clarity, fairness, and alignment with strategic objectives. The policy categorizes roles based on job titles, career levels, and

job families, creating a consistent framework for role assessment and career development.

The policy integrates seamlessly with core human resources systems, including talent management, compensation, and workforce planning. It

supports dual career paths, enabling Employees to advance either through managerial roles or as individual contributors, based on their

expertise and aspirations. Role evaluations are conducted objectively, focusing on responsibilities, required competencies, and their impact on

the organization, ensuring a transparent and equitable approach.

Periodic reviews ensure the framework remains aligned with market standards and organizational needs. The Policy applies to all Employees of

the Bank and the Group Companies, except for any specific requirements and adjustments to individual issues. These exceptions must be

approved by the Executive Committee, adhere to the local, supervisory, and legislative provisions of the countries where the Group operates.

Remuneration Policy for employees

The Remuneration Policy of Alpha Bank establishes a structured framework for employee compensation, ensuring compliance with Greek

laws, European Banking Authority (EBA) guidelines, and financial best practices. The policy aims to attract and retain skilled Employees,

encourage long-term sustainable performance, and align compensation with the bank’s strategic objectives and risk management framework.

It balances fixed and variable remuneration, where fixed pay includes base salary and mandatory benefits, while variable pay consists of

performance-based bonuses, stock options, and deferred incentives. The policy ensures gender neutrality, equal pay, and diversity and

inclusion.

The governance of the policy is overseen by the BoD and the Remuneration Committee. Risk management mechanisms, such as malus

(reduction) and clawback (recovery) clauses, prevent excessive risk-taking and ensure accountability. Performance evaluation is based on a mix

of financial, non-financial, and risk-adjusted criteria, ensuring that compensation decisions support long-term corporate stability. The policy

undergoes annual reviews to align with regulatory changes and market trends. Within this structured and comprehensive remuneration policy,

Alpha Bank ensures sustainable growth while safeguarding the interests of its Employees, shareholders and stakeholders.

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An updated Remuneration policy for the Members of Alpha Bank S.A.’s BoD was published in 2024 incorporating criteria linked with climate-

related and environmental goals. More information on the policy is provided in [E1-2] Policies related to climate change mitigation and

adaptation.

The policies adhere to the principles of the United Nations Global Compact (UNGC) and the International Labor Organization (ILO) standards;

comply with national labor laws and the European Union's directives on fair pay; align with the United Nations Guiding Principles on Business

and Human Rights and the OECD Guidelines for Multinational Enterprises.

Implementation of policies related to own workforce

Depending on the focus of each policy, the HR Strategy, Rewards and Organizational Effectiveness area has developed and contributed to

policies through consultation with employee representatives, diversity and inclusion experts, feedback from employee surveys; consultation

with labor unions, employee representatives, and financial experts; and by receiving input from human rights organizations, employee

representatives, and legal advisors.

Those policies are communicated to all Employees through the Group’s Intranet, Employee handbooks, and training sessions.

Oversight of policies related to own workforce

The Group has designed and implemented several policies to mitigate potential negative impacts on its own workforce, due to material

sustainability matters. The scope of the relevant policies includes the entirety of its workforce, so that equality and fairness are promoted at

the same time. Employees at the highest managerial level are also subject to these policies and thus, can benefit from their implementation.

The most senior level in the organization accountable for the implementation of these policies varies depending on the specific policy. For the

Corporate Responsibility Policy, the Chief Executive Officer (CEO) holds ultimate accountability, ensuring that the Group's sustainability

commitments and ethical responsibilities are upheld. The Code of Conduct and Ethics is overseen by the Chief Compliance Officer (CCO),

ensuring adherence to ethical standards and regulatory requirements. The Diversity and Inclusion Policy falls under the responsibility of the

Chief Human Resources Officer (CHRO), who ensures the promotion of equal opportunities and diversity across all levels of the Group.

The Violence and Harassment Prevention Policy is monitored and enforced by the Chief Human Resources Officer (CHRO) in coordination with

the CGSNC, which ensures the policy's alignment with legal and ethical standards. The Career Framework Policy is under the responsibility of

the Chief Human Resources Officer (CHRO), who oversees career development, employee progression, and fair employment practices. Τhe

Remuneration Policy is supervised by the Chief Financial Officer (CFO) and the Remuneration Committee, ensuring alignment with regulatory

frameworks and market standards while promoting equitable and sustainable compensation structures.

These senior executives ensure that the policies are effectively implemented, reviewed, and updated, in accordance with evolving regulatory

requirements, internal objectives, and sustainability commitments.

Scope of policies

Policies and Processes regarding diversity, inclusion, fair renumeration and human rights apply to all Group Employees, across all levels and

departments, as well as to Employees that are primarily employed outside of Greece. This way the Group ensures that all Employees receive

the same treatment, and no discriminations or favorable treatment are present.

Specific groups of Employees, such as women or young professionals, are covered by the scope of those policies and remain protected in all

aspects of their work life. For example, specific provisions are in place to ensure that women Employees are not negatively impacted in case of

pregnancies. Also, young professionals, in the first steps of their career, are protected from exploitation, since the Group is complying with

national law requirements on minimum wage and working hours, as well as with the banking sector collective agreement of OTOE, while also

has adopted internal policies that ensure fair renumeration and career advancements based on performance and merit.

In 2024, review and adjustment of compensation structures were also in place, to ensure fairness in renumeration, as well as to ensure that

the renumeration reflects the new roles and responsibilities associated with greener operations. The implementation of the “Remote

Working” policy, as well as flexible working arrangements, have become part of the Group’s culture and are targeted at reducing unnecessary

employee transportations.

Moreover, the Group has implemented strict anti-discrimination policies and provided training to prevent harassment and promote a

respectful workplace. By adopting these policies and practices, the Group can manage the material impacts, risks, and opportunities related to

their workforce, ensuring a smooth transition to more sustainable operations.

As described in [G1-1] Business conduct policies and corporate culture in which the Code of Conduct and Ethics is described in more detail, the

policy and the relevant trainings were updated within the reporting period.

Additionally, there are no changes in job creation and upskilling opportunities for the workforce specifically in Group’s policies, and they are

part of the Group's overall strategy, and the organization implements several programs regarding this matter.

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Several programs and initiatives have been launched already and are part of the Group’s broader strategy.

For example, the Alpha Bank S.A. provided a digital certification program for 1,500 network Employees as part of the upskilling efforts.

Additionally, the Group launched the 'Leading for Impact' program, which focuses on upskilling and mentoring the senior leadership team.

These initiatives were not part of a specific policy, but aligned with the Group’s overall strategic goals.

The Group is committed to upholding human rights and ensuring fair treatment for all Employees. These commitments are reflected in the

detailed description of Group's Code of Conduct and Ethics and policy against violence and harassment at the workplace as presented in

section [S1-1] Policies related to own workforce.

The Group's approach is always guided by the principles outlined in the Group’s Code of Conduct and Ethics and the Personnel Organization, in

which employee rights are well documented and protected. The Code includes provisions regarding the Group’s commitment to:

a. maintaining a culture of inclusion and acceptance for all Employees,

b. recognizing that the organizations’ sustainable development is linked to its workplace and based on the health and well-being of its

workforce and providing related benefits designed to ensure a secure workplace,

c. promoting a working environment free from any kind of discrimination and violence, especially through the Policy on “Preventing

and Combating Discrimination, Violence and Harassment at Work and the Management of Reports - Complaints on Incidents of

Discrimination, Violence and Harassment" that has been adopted.

The Code of Conduct and Ethics is in place to ensure that various labor rights, such as equal pay for equal work, right to freedom of association

etc., are not only part of national law but also a standard the Group wants to uphold and honor as an organization, since they align with its

values.

The Group is deeply committed to fostering an environment where every voice is valued, and feedback is both encouraged and acted upon.

Hence, it has several mechanisms in place to monitor compliance with the UN Guiding Principles on Business and Human Rights, ILO

Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises, including trainings that align

with the aforementioned and grievance mechanisms which are referenced in detail in the Grievance or Complaints Handling Mechanisms

Related to Employee Matters section of the S1- Own workforce.

Employee Engagement Survey

Since 2021, a Group-wide Employee Engagement Survey is conducted biannually, underscoring the dedication to continuous improvement and

dialogue. This survey is viewed as more than just a feedback tool—it is a vital mechanism for strengthening trust, enhancing communication,

and driving meaningful change within the organization.

The most recent survey, held in June/July 2024, achieved an impressive 85% response rate, with 5,267 Employees participating across the

Group. This high participation rate reflects the strong engagement and commitment of the Group’s own workforce. Furthermore, Employees

submitted over 3,080 comments, demonstrating their trust in the survey, as a meaningful platform to share their thoughts and concerns.

The survey findings are presented to the organization’s top management, with a detailed report outlining key insights and areas for

improvement. In addition, managers are tasked with discussing the feedback with their teams, ensuring Employees’ input is acknowledged and

specific opportunities for improvement are addressed.

To maintain transparency, the overall survey results are shared with the entire workforce through an Intranet announcement, ensuring that all

Employees are informed about the outcomes and the steps being taken to address them.

An action plan is developed collaboratively, engaging senior leadership to provide solutions and ideas that address the key areas for

improvement identified in the survey, ensuring that the actions taken are comprehensive, effective, and aligned with both employee

expectations and leadership support.

The Group has implemented several measures to provide and enable remedies for human rights impacts and ensures top-quality working

conditions and opportunities for advancement, based on merit and equitable treatment. It offers fair remuneration, in line with national labor

market standards, and ensures compliance with regulations on minimum wage, working hours, and leave.

The Group has established a competitive remuneration framework to attract, engage, and retain its Employees, promoting gender neutrality

and equal pay for equal work. Please refer to [S1-1] Policies related to own workforce for information on the Group's Code of Conduct and

Ethics and rest of the Own Workforce-related Policies. These, do not explicitly address trafficking of human beings, forced labor or compulsory

labor and child labor and there is not a public commitment/ endorsement to the UN Guiding Principles on Business and Human Rights. As the

Group operates in countries with strict employment regulations, it commits to safeguarding human rights through adherence to all applicable

national laws, and those set out by the EU and other regulatory bodies. The Group is also committed to safeguarding the rights of Employees

as established under national and EU law and the ILO conventions..

Information on employee associations may be found under [SBM-2] Interests and views of stakeholders.

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Diversity, Equity and Inclusion Strategy

Since 2022, the Alpha Services and Holdings Group has adopted the most modern framework against violence and harassment at the

workplace, while since 2023, the Bank developed its DE&I Strategy, consisting of five DE&I focus pillars:

• Gender Diversity

• Generational Diversity

• Health Equity

• Financial Inclusion

• LGBTQ+ inclusion

Gender Diversity

In this context, a framework of interventions has been developed in the past three years, with respect to providing equal opportunities for

professional development, equal performance evaluation and rewards, with special emphasis on personal development for women. A key part

of these interventions has been the practice of mentoring, placing women in the drivers’ seat, through the role of mentor for new joiners and

young colleagues, both male and female.

Examples of the empowerment initiatives are the Group’s mentoring and educational programs, namely:

- “Trading Alpha Brains” (TAB)

- “SheForHe”

- “Bankers and Daughters”

- “A.W.A.R.E. (Alpha Women, Authentic, Resilient, Empowered)”

These programs are addressed not only to the Group Employees and their families, but also to women who have left the Bank. In 2024 the

Group launched a new initiative dedicated to women’s empowerment and designed to inspire positive thinking, cultivate strong support

networks, and nurture a culture of collaboration. The "Leadership Academy for Women Leaders", provides leadership empowerment training

for women and is addressed to executives of the Bank's branch network. In the program participate 110 senior women leaders, including

Managers, Experts and Branch Managers.

Generational Diversity

In terms of Generational Diversity, indicative initiatives include providing the opportunity to students to obtain experience through short or

long-term internship programs, young professionals to work full-time in various functional areas through fixed-term contracts.

In 2024 alone, 171 such contracts were executed, with 153 involving individuals under 30. Additionally, the Group continued its two Accelerator

Programs in Retail and Wholesale areas, benefiting over 200 young professionals. The Young Enthusiasts Society (YES) employee community

also actively fosters engagement, skill-building, and cross-functional collaboration for younger Employees. For further information, kindly visit

[S1-1] Policies related to own workforce and [S1-4] Taking action on material impacts on own workforce, and approaches to mitigating material

risks and pursuing material opportunities related to own workforce, and effectiveness of those actions below.

Health Equity

Health Equity was supported through the provision of disability-related extra days of leave, reduced working time and provision of 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. Moreover, all Employees are supported by two physicians with fully equipped dispensaries.

To promote overall well-being, the Wellbeing employee Community also designs and implements initiatives targeting mental health, work-life

balance, financial wellness, and physical health. For further information, kindly visit [S1-1] Policies related to own workforce and [S1-4] Taking

action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own

workforce, and effectiveness of those actions below.

Financial Inclusion

To activate the Financial inclusion pillar in relation to our Employees, the Alpha Bank S.A. designed and implemented in 2024 a Financial

Literacy program for 200 female participants (100 Employees of Alpha Bank and 100 women outside of Alpha Bank), 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 will continue with a second phase of Financial Coaching in 2025, where 20

of the participants (10 women from the Alpha Services and Holdings Group and 10 from outside the Group) will implement 4 personal

coaching sessions, focused on their own areas of interest regarding their personal financials. For further information, please refer to [S1-4]

Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related

to own workforce, and effectiveness of those actions below.

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LGBTQ+ inclusion

Embracing the values of DE&I, the Group is proud to underline its commitment to creating a welcoming and supportive environment for

everyone. Recognizing the importance of LGBTQ+ inclusion, Alpha Bank 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 launched for all

people managers to raise awareness of and help prevent all forms of Unconscious Bias.

The described policies apply to all Employees including people from groups at particular risk of vulnerability in its own workforce and underpin

the commitments of HR to:

• Enhance people’s financial health through inclusive access to financing

Provide an inclusive and safe work environment

The policies underpin the commitments of HR towards:

• Diversity and Inclusion through Diversity and Inclusion Policy: The Group is committed to respecting and defending the diversity of

its employees, including age, gender, ethnic origin, religion, disability, and sexual orientation.

• Fair Remuneration through Remuneration Policy: Offering fair remuneration based on contracts that comply with national labor

market regulations, including minimum pay, working hours, and leave entitlements, is always a priority for the Group.

• Human Rights through Corporate Responsibility Policy: The Group proudly defends human rights, recognizes the right to union

membership and collective bargaining, and opposes all forms of child, forced, or compulsory labor.

In order to increase Employees engagement, productivity and of, multiple initiatives have been launched in the last few years. The priority was

to safeguard that employee issues and concerns will be timely communicated and addressed.

As a means to promote collaboration and networking, employee groups with common interests or characteristics, the “Communities of

Change”, were inaugurated in 2021 and further developed year on year, aiming 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

• Nurturing cross-functional alliances for Employees from different areas and promote collaboration

• Establishing Alpha Bank as an employer of choice and introducing practices that enhance our employee value proposition

These communities offer safe and supportive spaces for Employees to connect, share experiences, and inspire one another, while fostering

professional growth and cultural awareness.

Alpha Ithacans

Formed in July 2021, the Community currently comprises approximately 80 Alpha Services and Holdings Group Employees, who have

repatriated from abroad since 2019. The primary objective of this Community is to facilitate the exchange of knowledge, best practices, and

diverse experiences among its members. By sharing insights from different regions and environments, the community aims to accelerate

change, improve results, and boost effectiveness within the Bank. Additionally, it seeks to encourage more Greeks abroad to consider Alpha

Bank as their employer of choice for repatriation. As part of Alpha Bank’s “Future Ithacans” initiative and following successful networking

events in London and New York last year, Alpha Bank participated in the ReBrain Greece event in Amsterdam and the Career Day in Düsseldorf.

Agile Bankers

The Community was formed in February 2021 and currently counts approximately 170 members. The community’s purpose is to build a

mindset within Alpha Bank: 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 community members participate in monthly meetups and workshops. All

members also participate in the webinars and e-learnings of the Agile Academy (ACE).

Datah0l1cs

The Datah0l1cs Community, established in January 2024 and officially launched in April 2024, aligns with Group’s organizational strategy of

digital transformation by enhancing Employees' data literacy skills. It aims to help basic data users become familiar with the data management

lifecycle while providing experienced data users opportunities to further develop their expertise and skills. This community fosters a culture of

innovation and collaboration, bringing together 150 members from various Business Areas of the Alpha Bank.

As part of the Community the members can:

• Join a knowledge-sharing network where they can freely exchange ideas, queries, best practices, and occasional challenges related to

data use.

• Enhance their knowledge of tools by participating in educational programs.

• Contribute optimization ideas by engaging in workshops and resolving case studies.

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• Leverage their expertise in the data management lifecycle to act as trainers for the broader community, thereby developing their

leadership competencies.

Young Enthusiasts’ Society (YES)

The Young Enthusiasts Society (YES) was launched in March 2024 and currently counts over 120 young Employees below the age of 29 years

old. The purpose of the YES Community is to empower young professionals by creating a positive, enriching, and supportive work

environment. YES offers targeted training, career development pathways, and resources to help young talent thrive in their early career

stages.

Through YES, young professionals find a welcoming space that promotes inclusivity and collaboration. As part of a "Community of Change," YES

members:

• Build meaningful networks, connecting with colleagues across various departments and levels.

• Strengthen relationships and exchange ideas through engaging activities.

• Benefit from continuous learning opportunities through tailored educational programs.

• Discover new career paths within the organization to support their growth.

• Contribute to shaping the organization’s culture and improving its processes.

Wellbeing Community

Launched in November 2024, the Wellbeing Community is dedicated to enhancing the overall wellbeing within the organization. This

Community aims to create a supportive environment where Employees can prioritize self-care, build resilience, and access resources for

personal growth. Through workshops, open discussions, and wellness activities, the community fosters a culture that values emotional

balance, mental health awareness, and a positive approach to life. The community will work to make wellbeing an integral part of the everyday

work experience.

Additional Communities have been designed and will be launched in 2025, centered around the DE&I strategy pillars, such as Health equity

and sexual orientation (LGBTQ+).

The Group is dedicated to preventing, mitigating, and addressing discrimination, violence, and harassment, including gender-based and sexual

harassment, and domestic violence. To achieve this, the Group takes appropriate measures and makes reasonable adjustments to working

conditions to support potentially affected Employees. It informs and sensitizes Employees through various means, including printed and

electronic materials and trainings. This ensures that all Employees are aware of the policies and procedures regarding discrimination and

harassment.

Within 2024 the Group, provided practical guidance to all Employees to prevent any form of discrimination, harassment, or misconduct against

Colleagues, Customers, suppliers, contractors, or any individual who intends to do business with the Group based on the Code of Conduct and

Ethics. It also emphasizes the Group’s commitment to prohibiting all forms of violence and harassment occurring in the course of work,

whether directly related to or resulting from it, including instances within the family environment, gender and sexual violence and harassment.

Employees are encouraged to report incidents of discrimination and harassment, with reports accepted in writing, either signed or

anonymously, via telephone, mail, or email through the Speak Up mechanism. All reports are treated with the utmost confidentiality and

handled with care and discretion. The Alpha Holdings and Services Group has established mechanisms for conducting fair, timely, thorough,

and objective investigations of reported incidents, overseen by the “Assessment Committee for reports/complaints of discrimination, violence

and harassment incidents”. The Group has also the authority to take necessary measures and impose appropriate sanctions on any individual

exhibiting discriminatory or harassing behavior. These procedures ensure that discrimination is effectively prevented, mitigated, and

addressed, while also advancing diversity and inclusion within the organization.

The Group is steadfast in its dedication to fostering an inclusive, equitable, and respectful workplace. As part of this commitment, the Bank

ensures that all Employees are well-informed and equipped to uphold non-discrimination policies and practices. This dedication is reflected in

the Group’s comprehensive training approach, which includes initiatives such as the Unconscious Bias Training program, first introduced to

Managers and Directors.

The Unconscious Bias Training is a cornerstone of Group’s strategy to prevent discrimination and promote diversity. The training helps

Employees recognize and understand unconscious biases that can influence decision-making, and interactions. It equips staff with practical

tools and strategies to mitigate bias and foster an environment of fairness and respect. Additionally, it reinforces understanding of the Group’s

non-discrimination policies, ensuring alignment with organizational values. The training is delivered through interactive workshops, case

studies, and real-life scenarios that engage participants in meaningful dialogue and reflection.

Leadership training also plays a crucial role in supporting the Group’s non-discrimination goals. It equips leaders with the necessary skills to

embody and advocate for inclusivity, ensuring a trickle-down effect across teams. Leaders are trained to recognize bias in workplace dynamics

and decision-making processes, take corrective actions, and create a culture where Employees feel safe to express themselves without fear of

bias or discrimination.

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Non-discrimination policies and practices are an integral part of the People and Culture section of the organization’s Code of Conduct and

Ethics, for which updated training materials have been developed to ensure that all team-members are fully informed and actively engaged in

upholding the Group’s values of equality and fairness.

[S1-2] Processes for engaging with own workers and workers’ representatives about impacts

Workforce Engagement at Group level

The Alpha Services and Holdings Group has established comprehensive processes and implemented multiple initiatives for engaging with its

workforce and workers’ representatives to address actual and potential impacts. These processes are part of the entire Group’s ongoing due

diligence efforts to ensure that Employees’ perspectives and feedback, as key internal stakeholders, inform its decisions and activities

effectively.

Communication and Feedback

Human Resources Outreach: The Human Resources (HR) function is primarily responsible for ensuring that employee engagement occurs and

that the results of this engagement inform the bank’s approach. This responsibility is led by the Chief Human Resources Officer (CHRO), who,

along with other HR directors and managers, plays a pivotal role in this process. The CHRO and the HR leadership team regularly convene to

discuss and address various employee matters and concerns raised, to develop and implement new policies and strategies within the Alpha

Group and generally remain responsive and aligned with the needs and expectations of its workforce. Beyond this, the Group has established

the role of HR Business Partners, who serve as the first point of contact for Employees in various units and branches, supported further by

visits from HR Unit Executives.

Employee Feedback Channels: Alpha Services and Holdings Group maintains open lines of communication with Employees to continuously

gather data and feedback, with particular attention to those from vulnerable groups, helping to identify specific issues and areas for

improvement.

Internal campaigns, tools such as the Speak-Up Line and internal communities, provide Employees with accessible platforms to voice concerns

and share input. Bi-annual employee engagement surveys, frequent feedback sessions, and annual 360◦ performance reviews help monitor

the effectiveness of implemented policies and strategies, making necessary adjustments to them and ensure continuous improvement.

It must be noted that Alpha Services and Holdings Group takes several proactive steps to gain insight into the perspectives of women and

people with disabilities within its workforce. The Group has established Diversity and Inclusion Programs that specifically address the needs

and challenges faced by these groups, ensuring they feel valued and supported. Employee Resource Groups (ERGs) provide a platform to share

their experiences and concerns, fostering a sense of community and enabling the bank to understand their unique perspectives.

Labor Agreements and Employee Representation

The bank respects the right to union membership and collective bargaining, engaging with worker representatives to discuss and negotiate on

matters affecting the workforce.

Special Corporate Collective Labor Agreement: The Top Management team of Alpha Services and Holdings Group Personnel Union jointly

concluded a Special Corporate Collective Labor Agreement, which also further reinforces policies that prevent, address and eliminate violence

and harassment behaviors in the workplace and beyond.

Sectoral Collective Labor Agreements (CLA) cover the entire banking sector, while Corporate Collective Labor Agreements (CCLA) cover all

permanent Employees of the Alpha Services and Holdings Group.

Engagement with Unions: The Alpha Bank Group Employees Association also closely collaborates with HR. More specifically, monthly meeting

discussions are held pertaining to topics of employee welfare, workplace policies, and other relevant issues. This cooperation provides a

structured platform for dialogue and collaboration and ensures that employee voices are heard and considered in decision-making processes.

As a result the above information evidences the general process in place for the Group to engage with its own workforce.

[S1-3] – Processes to remediate negative impacts and channels for own workers to raise concerns

As comprehensively presented in the previous section [S1-2] Processes for engaging with own workers and workers’ representatives about

impacts, Alpha Bank has several specific channels in place providing comprehensive resources, targeted support and assistance for all its

workforce without exception, in order to raise their concerns or needs directly with the organization and have them addressed. Human rights

issues are mainly and initially managed through the Human Resources Business Partners (HRBPs), who serve as the key point of

communication between Employees and the HR function. The HRBPs specialize in understanding the unique needs and challenges of

Employees within their specific areas of work in the Group. To make this process even more accessible, Employees can use the ‘Talk2Us’

application to schedule face-to-face or virtual meetings with their HRBP at their convenience. Additionally, Employees have the option to

report any irregularities, omissions, or offenses through the Bank’s Additionally, Employees have the option to report any irregularities,

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omissions, or offenses through the Bank’s SpeakUp mechanism managed in house by the Human Resources Operations department, and also

through Whistleblowing mechanism, managed in house by the Regulatory Compliance department. More information can be found on [S1-2]

Processes for engaging with own workers and workers’ representatives about impacts. Disputes of a labor relations nature are addressed in

accordance with the provisions of the Personnel Regulation of the Bank.

Grievance or Complaints Handling Mechanisms Related to Employee Matters

Alpha Bank remains committed to maintaining a transparent and effective grievance or complaints handling mechanism to address all

employee concerns promptly and fairly. The currently implemented approach includes multiple channels through which Employees can raise

their grievances, including anonymous reporting options to protect their privacy and encourage openness.

The grievance handling process is designed to be transparent, impartial, and efficient. It involves the following key steps:

1. Submission: Employees can submit their grievances through various channels, including an online portal, email, or dedicated hotline.

2. Acknowledgment: Upon receipt of a grievance, an acknowledgment is sent to the employee, confirming that their concern has been

received and will be addressed.

3. Investigation: A thorough investigation is conducted by a designated team to gather all relevant information and ensure an unbiased

review.

4. Resolution: Based on the findings of the investigation, appropriate actions are taken to resolve the grievance. This may include

mediation, corrective measures, or disciplinary actions if necessary.

5. Feedback: The outcome of the grievance process is communicated to the employee, along with any steps taken to address their

concern.

Alpha Services and Holdings Group also ensures that all Employees are aware of the grievance mechanism and their rights to raise concerns

without fear of retaliation. Regular training sessions and communication campaigns are conducted to promote awareness and understanding

of the grievance process.

Dedicated to ensuring that Employees have access to effective communication channels, the Group has implemented various processes to

support and mandate the availability of these channels, which are crucial for maintaining transparency, addressing concerns, and fostering a

positive work environment. Specifically, the Policy for Violence and Harassment designates the individual responsible for receiving relevant

reports.

Furthermore, through the intranet, every employee can contact the Human Resources Business Area to discuss work-related concerns, as well

as matters related to health, safety, and wellbeing, via specially designed channels (speak up, talk2us, relevant microsite).

Each concern is carefully reviewed, and the employee is kept informed about the status of their request. Regular follow-ups are conducted to

ensure that issues are addressed appropriately.

All policies are uploaded to the intranet, where every employee can easily access them. The intranet serves as a centralized repository for all

policy documents, ensuring that Employees have immediate access to the latest versions of all relevant policies. This includes detailed

guidelines on how to report concerns, the procedures for handling reports, and the support available to Employees. By making these policies

readily accessible, the Bank ensures that Employees are well-informed about the processes in place to address their concerns and needs.

The Bank’s policy for Violence and Harassment explicitly prohibits any form of retaliation against Employees who report concerns. This policy

outlines the procedures for reporting incidents, investigating complaints, and taking appropriate actions to resolve issues. Specifically, the

policy for Violence and Harassment designates a specific individual responsible for receiving all relevant reports. It also includes measures to

support affected Employees and prevent future occurrences.

The Whistleblowing Policy “of Alpha Bank aims to promote transparency and integrity within the organization by encouraging Employees,

Customers, and suppliers to report any incidents of fraud, corruption, coercion, or other violations of the Bank’s policies and procedures. The

policy ensures that reports can be made in good faith and with reasonable belief that an offense has been or may be committed. It also

safeguards the anonymity of whistleblowers and outlines the procedures for investigating and addressing reported incidents.

All the above information evidences the existence of channels for Employees to raise their concerns.

[S1-4] Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing

material opportunities related to own workforce, and effectiveness of those actions

Key actions for own workforce

Alpha Services and Holdings Group invests in continuous training and professional development opportunities for its personnel to ensure that

Employees are equipped with the necessary skills and knowledge to implement the newest processes and systems. The impact and

effectiveness of these programs is evaluated through the assessment of participation rates, performance metrics, feedback questionnaires and

their actual influence on employee performance and career progression.

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Moreover, the Group also drives training and awareness programs to educate all Employees about the importance of diversity and inclusion,

promoting a culture of understanding and support. In collaboration with external organizations that specialize in supporting women and

people with disabilities, Alpha Bank Group is actively leveraging their expertise to better address the needs of all Employees, creating of a

more inclusive and supportive work environment.

Throughout the reporting year, the implementation of key policy objectives was forged by actions that contributed to the Group’s targets with

impactful programs, initiatives and partnerships:

Mentoring programs:

• The “Financial Literacy Lessons” program, a nine-month educational initiative, was exclusively addressed to female Employees of the

Bank mainly in managerial positions. It was conducted in collaboration with the NGO “Women on Top”, aiming to strengthen the

financial resilience and confidence of the participants by familiarizing them with the basic principles of financial literacy and helping

them better manage their financial future.

• The PosiDives program was a key initiative within the Bank's DE&I strategy, exclusively addressed to female Employees. Designed to

empower women in managerial positions, the program fosters positive thinking, strengthens support networks, and cultivates a

collaborative culture. The inaugural 2024 cycle of PosiDives included 110 senior women Managers, Experts, and Branch Managers,

who were actively engaged in professional growth and leadership development for a multiple month-period. Conducted in

collaboration with an external partner, this included training sessions, inspiring talks from influential speakers, and interactive Q&A

sessions to encourage open discussions and shared learning.

Acceleration programs:

- Alpha Bank has integrated "Acceleration Programs" into its Talent Acquisition Strategy to attract young talent across various Lines of

Business (LoBs). These programs are designed for individuals with little to no prior work experience, incorporating transparent and

highly reliable skills assessment methodologies to unlock candidates’ potential. All successful participants begin their journey with a

six-month probation period, which transitions into permanent employment upon consistent performance.

Internships:

- Alpha Bank offers internships to both university graduates and undergraduates, with durations ranging from 1 to 12 months, tailored

to individual needs. These internships often serve as a pathway to future employment, depending on organizational requirements.

Building Connections with Universities:

- The Bank actively supports and participates in career events organized by universities to bridge the gap between the corporate

environment and students’ career development. Additionally, Alpha Bank hosts "Business Days" annually, inviting students and

graduates to engage directly with industry leaders. Alpha Bank’s "Business Days” have welcomed many participants for three

consecutive years (in 2024 alone, around 200 students and graduates took part). These events provide a valuable platform for

participants to meet business leaders, gain insights into banking operations, learn about work methodologies, and explore critical

experiences that can shape their future careers.

All above actions are referring to all Employees in Greece.

The Group has undertaken several key actions to implement its HR policies effectively. These actions include:

• Training and Development: Providing continuous training and development programs to enhance employee skills and career

growth.

• Employee Engagement: Implementing regular employee engagement surveys to gather feedback and improve workplace conditions.

• Diversity Initiatives: Launching programs to increase the representation of diverse groups within the workforce.

• Leadership Development: Establishing programs to cultivate future leaders within the organization.

Other initiatives for Own Workforce

Health and well-being:

Health equity is supported through the provision of disability-related extra days of leave, reduced working time, financial assistance, and the

extension of financial support for child health issues/disabilities. Psychological support sessions and annual health check-ups are also provided.

Finally, all Employees are supported by three physicians with fully equipped dispensaries.

Health and Safety Standards: Maintaining a safe workplace for all is paramount, therefore health and safety audits are conducted on a regular

basis, with any identified issue getting promptly addressed to uphold high safety standards.

Benefits for Employees and their families:

Alpha Bank offers Employees and their family members a series of benefits, coverage, and services that demonstrate the Bank’s concern and

offer additional support and safety. In collaboration with Generali Hellas Insurance Alpha Bank S.A., the Bank provides the following programs

to its permanent Employees and their family members: Health and Life Insurance Plan, Outpatient Insurance Plan. Multiple benefits are

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provided to parents, such as childbirth allowance, reduced working hours, day-care benefits, special cash benefits for the Employees’ children

(e.g., Christmas gift cards or gift cards at the beginning of the school period), and gift cards to Employees for having a third child. Moreover,

the Bank provides special leave days to Employees to meet personal needs such as meeting with their children’s schoolteachers, attending to

their child in cases of hospitalization, undergoing the process of assisted reproduction, or for mourning purposes.

The Bank also provides support to specific groups of Employees through special programs that include annual financial assistance, leave days,

and reduced working hours for Employees with children facing serious health problems, as well as a special monthly welfare benefit for

Employees and pensioners who are blind or have kidney failure. Additional leave days are also provided to Bank Employees attending

undergraduate programs.

Effectiveness of actions for own workforce

The Group employs a comprehensive approach to track and assess the effectiveness of its actions and initiatives in delivering positive

outcomes for its workforce. For this reason, a set of Key Performance Indicators (KPIs) has been established for each of its strategic priority

impact areas, enabling the measurement of overall performance and the implementation of necessary corrective actions.

Employee training and engagement are also prioritized, with extensive training programs covering topics such as compliance, anti-money

laundering, and occupational health and safety.

Employee engagement is measured through regular surveys, and the results are used to improve policies and practices as described below. By

implementing these measures, the Group ensures that its actions and initiatives are effective in delivering positive outcomes for its workforce

and other stakeholders.

Current and planned actions for mitigating material risks and effectiveness of these actions

The Bank implements the following actions for mitigating risk related to training and development skills:

• Continuous learning and development initiatives to enhance employee skills and adaptability in order to make the transition in new

digital era smoother for own workforce.

• Process for identifying and preparing future leaders to ensure business continuity.

• Ensuring a safe working environment and promoting physical and mental health.

• Educating Employees on the importance of diversity and preventing workplace discrimination.

• Offering attractive salaries and benefits to retain top talent and equal pay without any discrimination.

• Aligning employee performance with organizational goals through bonuses and other incentives (By using a platform connected with

APD, specify goals via scorecards).

In order to recognize the positive impacts of the aforementioned actions, the organization utilizes a measurement tool for both qualitative and

quantitative data in the areas where these practices focus, aiming to eliminate all forms of discrimination among Employees. Below are

important KPIs that help identify the effects of the above actions:

• Employee Turnover Rates: Monitoring the rate at which Employees leave the organization to identify retention issues.

• Employee Satisfaction Surveys: Regularly surveying Employees to gauge their satisfaction and engagement levels.

• Training Completion Rates: Tracking the participation and completion rates of training programs.

• Health and Safety Incident Reports: Monitoring the frequency and severity of workplace incidents.

• Workforce Demographics: Analyzing the composition of the workforce to ensure diversity goals are met.

• Inclusion Surveys: Assessing Employees' perceptions of inclusivity within the organization.

• Cost-Benefit Analysis: Evaluating the financial impact of HR initiatives on the organization's bottom line.

By implementing these actions and tracking their effectiveness through various metrics, Alpha Bank can effectively manage risks and

dependencies related to own workforce.

It is noted that no material opportunities have been identified that relate to own workforce.

The Group is fully committed to ensuring that its practices do not cause or contribute to material negative impacts on its workforce, including

those related to procurement, sales, and data use, with particular attention to privacy concerns. Specifically, it ensures that no products or

services are purchased or utilized in ways that collect, process, or use employee data without prior notice, as such practices could create

negative impacts related to privacy issues. To this end, the Group has implemented strict compliance measures with applicable General Data

Protection Regulation (GDPR) and prioritizes ethical and transparent practices in all areas of data handling.

In procurement, the Group works exclusively with suppliers and service providers, who adhere to rigorous standards of data privacy and

protection. Due diligence is conducted to ensure that these third parties respect employee data rights and operate in accordance with the

Group’s organizational values. In sales, practices are designed to be fair and transparent, avoiding any undue pressure or actions that could

exploit employee or customer data. Additionally, robust internal processes govern data use, ensuring that all data collected from Employees is

processed responsibly, securely, and with clear consent.

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When potential tensions arise between mitigating material negative impacts—such as those involving privacy—and other business pressures,

the Group adopts a balanced and principled approach. This includes engaging in thorough risk assessments and prioritizing the protection of

employee data over conflicting business objectives. Stakeholder collaboration is also a core part of the Group’s approach, actively involving

Employees and their representatives to address concerns and develop solutions that uphold workforce well-being.

The commitment to continuous improvement drives Alpha Bank to regularly review and update the policies and practices to ensure alignment

with evolving privacy regulations and best practices. Furthermore, the Group invests in training and awareness initiatives to foster a culture of

responsibility and accountability across the organization, empowering Employees to understand their rights and the measures taken to protect

them.

Transparency and accountability are central to these efforts, and the Group is steadfast in ensuring that its operations do not utilize employee

data in a manner that could cause harm or compromise privacy. Through these measures, the Bank demonstrates its dedication to creating a

secure, fair, and supportive work environment that prioritizes the trust, safety, and well-being of its workforce.

Alpha Bank is committed to effectively managing its material impacts and has allocated substantial resources to ensure that these impacts are

addressed in a structured, efficient, and responsible manner. The management of material impacts is supported by a comprehensive

framework that includes financial investments, dedicated personnel, and continuous training programs to build capacity and expertise across

the organization.

Allocation of Resources

The Bank has established specialized teams and committees responsible for identifying, assessing, and managing material sustainability-

related impacts. These teams are equipped with the necessary tools and resources to monitor performance, implement corrective actions, and

drive improvements. Financial resources are allocated to support initiatives such as sustainability projects, technology investments, and

partnerships with external experts and organizations that enhance our ability to manage impacts effectively.

Training and Capacity Building

Recognizing the critical role of employee awareness and skill development in managing material impacts, ongoing training programs remain an

ongoing priority for the organization. These programs are designed to equip Employees at all levels with the knowledge and competencies

needed to understand and address material impacts. Training topics include environmental stewardship, human rights, ethical business

practices, and compliance with relevant regulations. Additionally, targeted training is provided to Employees in key roles, ensuring they can

apply best practices and innovative solutions in their respective areas of responsibility.

By allocating dedicated resources and fostering a culture of continuous learning and improvement, Alpha Bank ensures that its approach to

managing material impacts is both effective and aligned with the commitment to sustainability, transparency, and stakeholder accountability.

This integrated approach enables the Group to mitigate risks, seize opportunities, and create long-term value for the organization and

stakeholders.

[S1-5] - Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

The following targets are related to the policies referred above and contribute to their objectives.

TABLE 48 TARGETS TIED TO OWN WORKFORCE

Target description

Target

level

Absolute /

Relative

Baseline

value

Baseline

year

Target Year

Scope

Progress in 2024

Maintain >40% of womens'

representation in Managerial

positions

>40%

Relative

40%

2022

2027

Own operations

42%

Increase Youth employment by 20%

20%

Relative

20%

2020

2027

Own operations

51%

The targets are ongoing and the progress against them is reviewed annually. No milestones or interim targets are in place, as the completion

period of the target is annual and will be monitored by 2027. To define the targets no scienced-based evidence related to own workforce has

been defined.

Target setting has been set through the engagement types, and consultation with internal stakeholders, including Employees and employee

representation as per [SBM-2] Interests and views of stakeholders.

The Group acknowledges the importance of addressing material sustainability matters such as Secure Employment, Social Dialogue, Freedom

of Association, Training and Skills Development, and Diversity. However, the Group has not yet established specific targets regarding these

particular sustainability topics, beyond those already disclosed in the MDR table referring to Diversity. While measurable targets have not

been explicitly defined, the Group remains fully committed to promoting and improving practices related to these material sustainability

topics.

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It is noted that Employees or Employees representative were not directly engaged in setting the abovementioned targets. The targets related

to own workforce were set in collaboration of the GSD and HR Department. The tracking of performance against these targets and any

improvements as a result of the current performance are also performed by the abovementioned responsible divisions. However, employee an

employee representatives’ feedback is taken into account in all the above steps in order to achieve positive outcomes and response to the

expectations of the own workforce.

Our organization is committed to ensuring the effectiveness of our policies and actions concerning material sustainability-related impacts,

risks, and opportunities. In alignment with this commitment, we actively track and evaluate our performance, even in the absence of formally

established measurable outcome-oriented targets.

Specifically:

Processes for Tracking Effectiveness:

Alpha Services and Holdings Group has implemented robust processes to monitor and assess the effectiveness of the sustainability initiatives.

These processes include regular internal reviews, stakeholder engagement, and data-driven assessments to ensure that Group’s actions align

with its overarching sustainability objectives.

Defined Level of Ambition:

While measurable targets are in development, the Group has established a clear qualitative level of ambition that serves as a guiding

framework for its efforts. This ambition focuses on fostering positive environmental and social outcomes while mitigating associated risks.

Indicators and Progress Measurement:

To evaluate progress, the Group utilizes a combination of qualitative and quantitative indicators. These indicators are carefully selected to

reflect the specific context and nature of the material sustainability-related impacts the Group addresses. Additionally, a base period is defined

to measure progress consistently, allowing for meaningful comparisons over time.

By adopting these practices, Alpha Group demonstrates its dedication to transparency, accountability, and continuous improvement in

sustainability performance. This approach not only reinforces the commitment to responsible business conduct but also ensures that it

remains adaptive and responsive to emerging sustainability challenges and opportunities.

The Group’s efforts include the ongoing monitoring and evaluation of performance in these areas to ensure alignment with its sustainability

values, the implementation of policies and initiatives aimed at fostering a positive and inclusive workplace culture, and active engagement

with Employees and stakeholders to identify and address opportunities for progress. Alpha Services and Holdings Group is continuously

working to enhance its approach to these matters by developing frameworks, processes, and methodologies that will enable the establishment

of specific and outcome-oriented targets in the future. The aim is to ensure that any targets adopted meaningfully reflect the Group’s

commitment to these critical sustainability topics and drive tangible improvements.

[S1-6] - Characteristics of the undertaking’s Employees

TABLE 49 TOTAL EMPLOYEE HEAD COUNT BY GENDER

Headcount

Female

Male

Total

Reporting Year

2024

Total number of Employees

2,3,4,5

3,470

2,755

6,225

Number permanent Employees

3,370

2,664

6,034

Number of temporary Employees

100

191

Note 1: The data related to Employees refer to the end of the reporting period (31.12.2024). No numbers in averages across the reporting

period of 2024 has been provided for taking into account fluctuations in number of employees.

Note 2: No non-guaranteed hours Employees are in place.

Note 3: Regarding gender of Employees, there are not Employees with other gender or not reported gender.

Note 4: Please note that these metrics are absolute numbers throughout S1-6 and as such, there are no significant assumptions or

methodologies behind them.

Note 5: It is noted that the metrics described have not been assured by an external third party.

TABLE 50 TOTAL EMPLOYEE HEADCOUNT IN COUNTRIES WHERE THE UNDERTAKING HAS AT LEAST 50 EMPLOYEES REPRESENTING AT

LEAST 10% OF ITS TOTAL NUMBER OF EMPLOYEES.

Reporting Year

2024

Country

Number of Employees (Headcount)

1a,b

Greece

5,700

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Note 1a: The data related to Employees refer to the end of the reporting period (31.12.2024). No numbers in averages across the reporting

period of 2024 has been provided for taking into account fluctuations in the number of employees.

Note 1b: Male: 2,515 and Female: 3,185

TABLE 51 NUMBER OF EMPLOYEES WHO LEFT THE GROUP AND TURNOVER RATE

Reporting Year

2024

Number of Employees who left the Group

748

Employee turnover rate (%)

Note 1: The Employee turnover rate (%) has been compiled with data on employees who left the Group voluntarily and non-voluntarily,

including Resignations, the Voluntary Separation Scheme, Fixed Term Terminations and Dismissals, Death, Sabbatical leave and other.

[S1-8] - Collective bargaining coverage and social dialogue

Please note that these metrics are absolute numbers throughout S1-8 and as such, there are no significant assumptions or methodologies

behind them. It is noted that the metrics described have not been assured by an external third party.

TABLE 52 SHARE OF TOTAL EMPLOYEES WHO ARE COVERED BY COLLECTIVE BARGAINING AGREEMENTS

Type of coverage

2024

Percentage of total employees who are covered by collective bargaining agreements

(%)

98%

TABLE 53 SOCIAL DIALOGUE

Social Dialogue

Coverage Rate

Workplace representation (EEA only)

(for countries with >50 empl. representing >10% total

empl.)

Reporting Year

2024

80 – 100 %

100% (Greece)

The Group does not have any agreements in place for representation by the European Works Council (EWC), Societas Europaea (SE) Works

Council, or Societas Cooperativa Europaea (SCE) Works Council. This is because employee representation and dialogue within our organization

are effectively facilitated through the Alpha Bank S.A. Employees' Association. The Group does not have any other agreement in place other

than the one reference per S1-2- Labor Agreements and Employee Representation section.

The Alpha Bank S.A. Employees' Association serves as the primary platform for employee representation, ensuring robust engagement and

communication between the organization and its workforce. This structure enables us to address employee concerns, foster constructive

dialogue, and uphold our commitment to promoting fair and inclusive workplace practices.

By leveraging this established framework, we ensure that employee representation remains both effective and aligned with our organizational

values and regulatory requirements. We remain committed to maintaining open and transparent communication with our Employees, while

continuously improving our approach to workplace representation and dialogue.

[S1-9] - Diversity metrics

TABLE 54 GENDER DISTRIBUTION IN NUMBER AND PERCENTAGE AT TOP MANAGEMENT LEVEL

Gender distribution in number and

percentage at top management level

2024

(#)

2024

(%)

Female

20%

Male

80%

Note 1: The top management level above refers only to Executive and Senior Management.

Please note that these metrics are absolute numbers and as such, there are no significant assumptions or methodologies behind them. It is

noted that the metrics described have not been assured by an external third party.

Senior Leadership Team: those persons who exercise executive functions within an institution and who are responsible and accountable to the

management body for the day-to-day management of the institution.

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The following are considered as Senior Leadership Team:

• CEO

• Chiefs who are members of the Executive Committee

• Chiefs that are part of the senior leadership team who are not members of the Executive Committee

It is noted that in line with the regulatory framework, the Bank considers as Key Function Holders (KFHs), as defined in the joint ESMA and 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, the following Members of the Senior Leadership Team: the Chief Financial Officer, the Chief Risk Officer,

the Chief of the Internal Audit Business Area and the Chief of Compliance. All of the above roles are Members of the Senior Leadership Team.

The Group Internal Auditor is considered as Key Function Holder.

TABLE 55 DISTRIBUTION OF EMPLOYEES BY AGE GROUP

Distribution of Employees by age group

2024

(#)

< 30 years old

479

30 to 50 years old

4,178

> 50 years old

1,568

Please note that these metrics are absolute numbers and as such, there are no significant assumptions or methodologies behind them. It is

noted that the metrics described have not been assured by an external third party.

[S1-11] - Social protection

The Group offers its Employees and their family members a range of benefits, coverages, and services that demonstrate the Group's care and

provide additional support and security. In collaboration with GENERALI Hellas Insurance S.A., the Group provides the following insurance

programs to its permanent Employees and their family members:

• Health and Life Insurance Coverage Program

• Outpatient Insurance Coverage Program

Alpha Group provides comprehensive income protection for employees through its VSS (Voluntary Separation Scheme) and TEA (Pension

Fund) programs, alongside public benefits. The VSS offers paid leave and generous severance packages for voluntary departures, ensuring

financial stability during transitions. The TEA ensures retirement benefits through mandatory contributions, based on salary and service years.

Additionally, the national system provides unemployment and retirement benefits, offering a baseline level of support. Together, these

programs ensure robust financial security for employees facing unemployment or retirement

Additionally, it grants special leaves to Employees to cover personal needs, such as meetings with their children's teachers, caring for their

child in case of hospitalization, undergoing assisted reproduction procedures, or for mourning purposes.

Finally, the Group supports specific groups of Employees through special programs that include:

• Annual financial assistance, days of leave, and reduced working hours for Employees with children facing serious health issues.

• Special monthly welfare allowance for Employees and retirees of the Group who are blind or suffer from renal failure.

• Additional Facilitation Leaves for the Group's Employees who are enrolled in undergraduate programs.

By creating a more strategic role for Human Resources within the Organization, enriching the workforce, and strengthening its structures, the

Group aims to offer Employees improved services throughout their experience within the Group. Health and safety at work are significant

issues for the Group and its Human Resources, as illnesses, injuries, or other health issues can affect the work environment and employee

productivity. Employee safety is of utmost importance in the banking sector, and therefore, the Group takes measures to ensure that the

workplace has the appropriate mindset to eliminate or reduce occupational risks and prevent injuries. In 2024, our commitment to the health

and safety of our Employees was further strengthened, highlighting our dedication to promoting a safe and supportive work environment. A

particularly satisfactory development for the Group was the certification, by an accredited body, of the Occupational Health and Safety

Management System it implements, according to the ISO45001 standard, thus confirming its effectiveness. This recognition affirms the

Group's commitment to implementing best practices, striving for continuous improvement, and adopting the highest standards in workplace

health and safety.

[S1-13] - Training and skills development metrics

Please note that these metrics are absolute numbers throughout S1-13 and as such, there are no significant assumptions or methodologies

behind them. It is noted that the metrics described have not been assured by an external third party.

TABLE 56 PERCENTAGE OF EMPLOYEES THAT PARTICIPATED IN REGULAR PERFORMANCE AND CAREER DEVELOPMENT REVIEW BY GENDER

Gender

Females

Males

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Reporting Year

2024

Percentage of Employees that participated in regular performance and career development reviews (%)

91%

90%

Note 1: The percentage is calculated as the Number of employees that participated in regular performance and career development reviews

divided by the total number of employees.

TABLE 57 AVERAGE NUMBER OF TRAINING HOURS PER EMPLOYEE BY GENDER

Gender

Females

Males

Reporting Year

2024

Average number of training hours per employee (#)

35.2

32.0

Note 1: Average number of training hours per employee by gender has been calculated as the number of training hours per employee and by

gender divided by the total number of employees.

[S1-17] - Incidents, complaints, and severe human rights impacts

Please note that these metrics are absolute numbers throughout S1-17 and as such, there are no significant assumptions or methodologies

behind them. It is noted that the metrics described have not been assured by an external third party.

The Group monitors the effectiveness of its approach to protect human rights by tracking its performance through the following metrics:

TABLE 58 TOTAL NUMBER OF INCIDENTS OF DISCRIMINATION, INCLUDING HARASSMENT REPORTED IN THE REPORTING PERIOD

Reporting Year

2024

Total number of incidents of discrimination, including harassment reported in

the reporting period (#)

During 2024, there was 1 incident of harassment for the Group, regarding Alpha Bank S.A. The incident was recorded via direct communication

with HR, with the individual involved submitting a written account of the incident to the HR representative. No specific methodology or

assumption has been made for compiling the above data.

TABLE 59 NUMBER OF COMPLAINTS FILED THROUGH CHANNELS FOR EMPLOYEES TO RAISE CONCERNS (INCLUDING GRIEVANCE

MECHANISMS) AND NUMBER OF COMPLAINTS FILED TO NATIONAL CONTACT POINTS FOR OECD MULTINATIONAL ENTERPRISES

Reporting Year

2024

Number of complaints filed through channels for Employees to raise concerns

(including grievance mechanisms) (#)

Number of complaints filed to National Contact Points for OECD Multinational

Enterprises (#)

Data related to the abovementioned number of complaints have been compiled through the available channels for Employees described in

[S1-3] Processes to remediate negative impacts and channels for own workers to raise concerns.

TABLE 60 TOTAL AMOUNT OF FINES, PENALTIES, AND COMPENSATION FOR DAMAGES AS A RESULT OF THE INCIDENTS AND COMPLAINTS

DISCLOSED ABOVE, AND A RECONCILIATION OF SUCH MONETARY AMOUNTS DISCLOSED WITH THE MOST RELEVANT AMOUNT PRESENTED

IN THE FINANCIAL STATEMENTS (#)

Reporting Year

2024

Total amount of fines, penalties, and compensation for damages as a result of the

incidents and complaints disclosed above

Due to the nature and geographical location of operations of the organization, there are no Incidents, complaints, and severe human rights

impacts to report- please refer to [S1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

for more information.

ESRS S4 - CONSUMERS AND END-USERS

[S4.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model in relation to

consumers

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In the scope of ESRS 2 disclosures, all consumers and end-users of the Group’s products and services are included.

The types of consumers who are likely to be materially impacted by the Group’s products/services and business relationships are individuals

(i.e. private clients), and corporate and SME Customers. More specifically, individuals are people who use the Group’s products/services for

personal needs, such as in the instance of savings accounts, mortgages and credit cards. Corporate customers are large businesses that have

more complex needs, such as loans for operations, expansion, cash flow management and investments. Further, SME customers are small and

medium-sized enterprises that need banking services to support their operations and growth, including business loans. The positive impacts on

them arise from the offering of products and services contributing to the access to products and services, i.e. Finance and Housing. Moreover,

a broader socio-economic positive impact is created to Customers and broader society/economy through the Group’s products/services and

business relationships, contributing to Healthy Economies.

The Group does not engage in the sale of products and services that are inherently harmful to individuals. Due to the nature of the Group’s

operations, it handles sensitive personal information, therefore there is an inherent risk of data breaches or misuse of personal information.

Furthermore, consumers depend on precise information concerning financial products and services, including loan terms, interest rates, and

fees. The Group offers its services and products to all consumers and end-users, without any form of discrimination and with respect to their

freedom of expression. The Group ensures that all product-related information is transparent and readily accessible to prevent potential

misuse or misunderstanding of its products and services.

Customers may include certain groups that could be particularly susceptible to negative impacts resulting from marketing and sales strategies

or privacy-related incidents, such as young and senior individuals and other financially vulnerable individuals (e.g., low-income borrowers). The

Group ensures that no such material negative impacts to its Customers could occur, through its initiatives, processes and targeted products

and services in place e.g. education loans, targeted credit products to other vulnerable groups, and others.

Activities resulting in positive impacts to Customers

The Group’s activities provide comprehensive and inclusive access to financial services through an extensive variety of high-quality financial

products and services. These span across retail banking, corporate and business banking for medium-sized and large enterprises, financing

services, asset management, insurance products, investment banking, brokerage, and real estate services in Greece, Cyprus, United Kingdom

and Romania. Continuous improvements are made to enhance the Group’s services and products, ensuring ease of access for Customers.

More information about the business sectors, products and services of the Bank is included in the annual report and on its website.

In Greece, Alpha Bank S.A. representing the largest share of the Group’s operations, has a diverse product and service offering for individuals,

corporate and SME clients. These include:

Products and services to Retail Customers that contribute to the access to Housing and Finance

Affordable Housing solutions:

• Alpha Residence: a housing loan allowing Customers to purchase a home with the option to secure the loan against any

property, with a built-in flexibility in adjusting payment terms based on changes in income.

• Alpha First Home: a housing loan targeting first-time buyers between ages 18 to 50, providing financing for up to 90% of

the property’s value.

• Alpha Residence Renovation: a renovation loan available for home improvement projects, which can be secured with or

without a property mortgage.

• “Exoikonomo 2023”: a program funded by the Recovery and Resilience Fund to enhance the energy efficiency of homes by

at least three energy categories, achieving over 30% primary energy savings. The total investment in this project is

expected to result in annual energy savings of at least 213 ktoe and the energy renovation of at least 105,000 homes by

2025. Additionally, the investment includes specific incentives to support low-income and vulnerable households, offering

an increased grant rate and a dedicated budget of Euro 100 million.

• Reward Program for Consistent Mortgage Borrowers: introduced in response to the financial strain on households caused

by consecutive interest rate hikes due to Central Banks' monetary policies. This program, available for 12 months, aims to

support borrowers who consistently meet their repayment obligations by reducing interest rates on variable rate

mortgages and to protect borrowers from potential future increases in benchmark rates.

To further its positive impacts to consumers and end-users, Alpha Bank S.A. is launching two programs within 2025 contributing to Access to

Housing and Finance:

• My Home II which is a co-financed housing loan designed for first-time homebuyers aged 25 to 50. This program aims to

support low-income individuals and those without the financial means to purchase their own primary residence through

low-interest mortgage offerings.

• Upgrade My Home which is a co-financed loan program aiming to provide incentives to individuals for energy

improvements to their existing residences.

Accessibility to Finance:

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• Alpha Cash Collateral: an option to allow Customers to secure a loan without liquidating assets, providing financial

flexibility while maintaining investment portfolios.

• myAlpha Quick Loan: e-banking personal loans of up to Euro 5,000 to cover unexpected costs and routine spending with a

fast and paperless process.

• Alpha “Metron Ariston”: secured and unsecured personal loans with competitive interest rates and flexible repayment

schedules.

• Alpha Green Solutions – Electric Car/Bicycle and Consumer Loan for the home: consumer loans especially designed to

finance the purchase of electric vehicles or the improvement of the energy efficiency of homes, with favorable fixed

interest rates.

• Alpha Education Consumer Loan: loans for educational purposes with favorable fixed interest rates.

• Alpha All in 1: offering consolidation of outstanding credit card and consumer loan balances into a single, simplified loan

program with lower monthly payments.

• Alpha Epipleon – Overdraft Program: providing access to additional funds conveniently and affordably through Customers’

payroll accounts, as needed.

• Car Financing and Consumer Goods Loans: through a wide network of car dealers and retailers, Alpha offers consumer

loans for the purchase of cars, motorcycles and consumer goods, with competitive fixed interest rates.

• myAlpha Benefit: packages aiming to cut down on monthly transaction expenses for individuals. 2 new transaction plans

were launched in 2024, myAlpha Benefit Advanced and myAlpha Benefit Premium. With the addition of these 2 plans, the

suite of 3 package offerings was finalized.

Products and services to corporate and SME Customers that contribute to the access to Housing and Finance, and Healthy

Economies

The Group’s products and services include lending activities, leasing, real estate activities and factoring activities that enhance the accessibility

to finance and the ability of corporate and SME Customers to house their operations, and perform development, construction or renovation

activities.

The Group also supports through its products and services sectors that are inherently positively associated with the access to Housing and

Finance, such as L68 Real estate activities, F41 Construction of buildings and F43 Specialized construction activities, K64 Financial and

insurance activities, K65 Insurance, reinsurance and pension funding, except compulsory social security, N78 Employment activities. Through

Alpha Bank S.A. other initiatives targeting corporate and SME Customers include:

• Financing solutions for Businesses (e.g., InvestEU co-funding program) and Large Corporate Customers including Letters of

Guarantee, Letters of Credit, and lending to the Division’ Customers by the Group Companies in Greece and abroad (excluding

customer lending through the Subsidiaries Alpha Leasing S.A. and ABC Factors S.A.).

• Alpha Bank Gold Business: a service dedicated to delivering top-tier consulting services to its Gold Business Customers. This

commitment extends beyond identifying optimal financial solutions to include the development and implementation of new

business development standards.

• High-value investment projects in the Greek Hospitality Sector through bonds and loans.

• IBAN verification for transfers to other banks within Greece.

• myBusiness Benefit transaction packages with package account management.

• myAlpha Web for Business: Addition of the ability to register/update the associated Alpha Bank S.A. email on myAlpha Web for

Business. Regarding corporate e-Banking, in 2024 the possibility of applying for change of subscription limits and requesting the

acquisition of Web FX and Alpha Online Term Deposit services was added through myAlpha Web for Business only for Wholesale

Customers. From myAlpha Web for Business users can issue certificates showing the average balance of deposit accounts and the

existence of a deposit account.

Specifically targeting SMEs, the Bank offers the following:

• HDB Innovation Guarantee Fund: offers financing under favorable conditions, supported by an 80% guarantee. Additionally, there is

an option to subsidize up to 20% of the capital if the debtor meets specific innovation and ESG (Environmental, Social, and

Governance) criteria within three years of the initial loan disbursement.

• Recovery and Resilience Fund, Greece 2.0: providing comprehensive Banking Advisory services for the co-financing of SMEs, aimed at

implementing investment plans that include sustainability-promoting interventions.

• Training and support program: a strategic training and technical support program, with workshops implemented throughout Greece,

specifically targeting SME Customers, aiming to implement investment projects and transformation plans which enhance

competitiveness and generate new job opportunities.

• Ecosystem of Partnerships: a comprehensive suite of services is offered across all green entrepreneurship sectors, encompassing

sustainable investments, including specialist advisors, suppliers, and photovoltaic station construction contractors.

• Equal support for businesses: collaboration with the Hellenic Development Bank (HDB) and the European Investment Fund (EIF) to

offer favorable financing options for start-ups. Furthermore, the Bank supports female entrepreneurship through its comprehensive

range of financial products. In partnership with the EIF, the Bank has also facilitated microcredit for micro-enterprises, including

numerous women-owned sole proprietorships, via the "Employment and Social Innovation (EaSI) Microfinance Guarantee Facility."

• Alpha Smart Hospitality: a service promoting sustainable development by providing financial resources to support the targeted

growth of Greek entrepreneurship. This approach involves methodical, substantial, and integrated planning within a sustainability

framework, considering available resources, goals, and emerging trends.

Moreover, the Bank offers the program “Bonus Charity” to further enhance the socio-economic impact of the Bank. For the 16th consecutive

year, the Program “Bonus Charity” allowed Alpha Bank Customers to support cooperating non-profit organizations. Through this Program,

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Customers supported their institution of choice in practice, by redeeming Bonus points and sending the corresponding amount to the relevant

institution. This year, 1 new institute was added to the list of cooperating institutions. The Bonus Program subsided the points redeemed by

holders and actively supported the institutions, depositing the amount corresponding to more than double the value of the points. In this way,

the Bonus Program supported people in need and certified environmental organizations. For 2024, 5,840,000 Bonus points were redeemed

through 946 charity transactions, and Euro 29,200 were donated to the 36 charities participating in the Program.

During 2024, the Program was intensely promoted on social media, while the new Bonus app proved to be a very successful communication

channel. The list of institutions participating in the “Bonus Charity” Program is available on the webpage of the Bank

(www.alpha.gr/el/idiotes/bonus/bonus-stin-agapi), with the moto “You can also make a gift of joy by redeeming your Bonus points, choosing

among 36 participating associations, and offer your help to those who need it!”

Digital solutions to enhance the accessibility of products/services to Customers

Innovation and digitalization necessitate a modern Branch Network, advanced digital networks and web-services, providing widespread,

inclusive access to financial services. Key imperatives of the Bank’s digital strategy are the continuous improvement in product and service

quality, a modern and responsible approach to the Customers’ banking needs as well as the Bank’s uninterrupted operation.

Through digital initiatives such as e-banking and digital card wallets, the Group makes it easier and more secure for Customers to access its

services and products. Among others, the solutions offered are:

• The cards enrolled in wallets (Apple Pay, Google Pay, Garmin Pay, Xiaomi Pay) and the tokenized cards on file, which Alpha

Bank was the first to offer to its Customers, maintained in 2024 the positive trend with the number of active digitized cards

(tokens) exceeding 8.4 million. The digital card offering makes it easier and more secure for Customers to use their cards to

make payments.

• The ability to open a current account and obtain business e-Banking credentials through myAlpha Web for individuals was

made available to the general public on 20.11.2024. Individual Customers who have e-banking passwords were given the

opportunity to start their professional cooperation with the Bank, as Sole Proprietorships (including freelancers), through

myAlpha Web Individuals.

• Ability to open a privileged account: private Customers who have e-Banking and wish to open a privileged account to be

served with their daily transactions can obtain it either through myAlpha Web or through myAlpha Mobile without visiting

a branch.

• IRIS payments (QR generator): offering for freelancers and sole proprietorships, and optional 'mobile search' during the

Activation/Modification of the IRIS Payments service.

• The provision of e-Statements: automated information on card transactions, accounts, loans, and POS so that Customers

who have e-Banking receive the relevant information online and through the platform can download the form without

having to receive physical documents by post.

• Online issuance of certificates: offering since 2023 the option to make online requests for the issuance of specific

Certificates for bills and loans without visiting a branch.

• Automation (during 2024) of deposit account balance, average deposit account balance, and account maintenance with

Alpha Bank.

• Addition of myAlpha Rendez-vous service on myAlpha Web for Business – Customers now have the ability to make

appointments digitally.

More specifically, regarding myAlpha Rendez-vous by Alpha Bank S.A., it provides the ability to book an appointment and be serviced either

through a video call, phone call, or physically at a branch. The Remote Customer Collaboration System (RCCS) consists of the myAlpha Rendez-

vous tool offered by the alpha.gr made available to Customers since September 2022 and the Appointment booking widget within the e-

Banking environment that was made available to users since May 2023 and continues to be improved and features are added to it. Since their

start, the total number of appointments registered by both channels is more than 400,000 with more than 80% of them having been

completed and only 20% of them having been cancelled for some reason by the customer himself or the Bank. It is worth noting that

approximately 70,000 appointments have been registered through the Outbound Application tool, which is used by the Bank's Customer

Service Department and the Branches to register the appointments of Customers who are unable to register their appointment themselves or

do not have an email. This feature was added to myAlpha Web for Business in July 2024. All appointments registered through digital channels

with more than 72% of them completed without problem, while only 24% of them have been cancelled, for some reason, by the customer

himself or the bank.

Physical solutions to enhance the accessibility of products/services to Customers

Furthermore, the Group provides accessibility of its financial services to all consumers, including persons with disabilities and vulnerable

groups by modernizing its physical facilities. In more detail these include:

• For Customers with visual and hearing impairment:

1. Branch Services:

o Assistance provided without the need for witnesses.

2. Bank Documents:

o Documents available in Braille, with a processing time of 7 calendar days.

3. ATM Accessibility:

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o Cash withdrawals and balance inquiries available at onsite and offsite ATMs with voice guidance, accessible to Alpha Bank

Customers, as well as those from other Greek banks via the DIAS network.

o All ATMs have embossed elements on the keyboard for accessibility while many ATMs feature sound commands and tactile

indications on keyboards.

o For security, customer information is not displayed on the screen during transactions.

o Specific ATMs are placed at service points of interest in collaboration with associations for the blind (e.g., KEAT).

4. Customer Service:

o Appointments or in-branch assistance available for Customers with hearing impairments.

o Accessible video media with subtitles available on Alpha.gr.

• For senior citizens and people with increased accessibility needs:

o One-to-one educational video sessions provided by the dedicated “e-Banking walkthrough” team.

o Modernized facilities of Branches that are accessible to Customers with mobility disabilities.

The websites are available in both English and Greek, and this bilingual approach extends to its Customer Service Call Centre. Customers

visiting the Branches can also receive assistance in English, and an English-language interface option is available at the Bank’s ATMs. The

Branch Network and ATMs form the cornerstone of traditional banking services, and as such, they have been given heightened attention to

ensure that all Customers can access financial services equitably in all countries and regions that the Group operates.

Through the offering of these products/services, the Group delivers material positive impacts to its Customers.

It is noted that no negative material widespread or systemic impact to consumers and end-users has been identified in contexts where the

Group sells or provides its products or services or related to individual incidents and specific business relationships. Groups of Customers with

particular characteristics, have been identified through the UNEP FI Consumer Banking Identification Module and are incorporated in the

SFF. The SFF targets specific groups of Customers such as socioeconomically disadvantaged population, living in rural areas or isolated islands

with limited or inadequate basic infrastructure, undereducated, long-term unemployed and working population vulnerable to losing their job

due to the energy transition. Additionally, it focuses on elderly, youth, and other vulnerable groups, including persons with disabilities, or

those in need of medical attention. Nο Customers have been identified through the double materiality assessment with particular

characteristics or for particular products or services that may be at greater risk of harm.

Material risks and opportunities related to Customers

Material risks and opportunities for the Group generally derive from impacts, dependencies or other factors, such as exposure to climate

hazards or changes in regulation that address systemic risks. Dependencies arise from a reliance on consumers, such as that relating to

reputational damage. Other factors refer to systemic factors; for instance, regulatory changes in the financial services sector.

From a risk perspective, in the context of the double materiality assessment performed in 2024, the Group concluded that regarding

consumers and end-users, in particular “Privacy”, “Access to (quality) information” and “Responsible marketing practices” risks are considered

material in the short-, medium- and long-term for the Group. These risks arise from issues such as disclosure and data protection issues,

unsuitable promotion practices, fiduciary breaches, product suitability issues or inadequate disclosure of product terms.

The root cause for the risk manifestation lies on the Bank’s own operations (most typically due to potential failures of internal controls

established to prevent such risks), with risks deriving from external factors, including regulatory changes, in case of the Bank’s processes fail to

respond which could potentially result in significant financial losses. Therefore, the risks related to privacy, access to (quality) information, and

responsible marketing practices are not dependent with impacts of any particular group of Customers.

It is noted that through the double materiality assessment process no material opportunities have been identified related to the consumers

and end-users.

[S4-1] Policies related to customers

For managing its material impacts to Access to Finance and Housing, Healthy Economies, as well as its risks related to Privacy and Access to

(Quality) Information, Responsible Marketing Practices, the Group has adopted a comprehensive set of policies, including:

Alpha Bank S.A. Sustainable Finance Framework (SFF)

The SFF lays out of the criteria to characterize specific loans as sustainable, including themes that contribute to the access to Finance and

Healthy Economies, Housing (i.e. Access to credit and financing and Affordable social housing).

The process of monitoring the implementation of the SFF includes a robust SFF governance model and the integration into the Bank’s existing

credit approval process.

The SFF relates to banking and lending activities addressed to individuals, corporate and SME Customers. The scope of the SFF encompasses a

variety of ESG lending solutions in the Bank’s Wholesale and Retail banking portfolios. Additional credit products may be considered by

performing the assessment of certain eligibility criteria.

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The related activities of SFF focus on Dedicated-purpose financing (Green/Social loans), Dedicated purpose financing (RRF loans), General

purpose financing (Business Mix) and General-purpose financing (Sustainability-linked loans) helping inter alia:

- Access to credit and financing and contribution to Healthy Economies targeted to females, rural populations focusing on agricultural

production and agricultural value chains, excluded and/ or marginalized populations, and economically disadvantaged groups

through SME lending in emerging markets and Microfinance lending.

- Affordable social housing focusing on the financing of construction, renovation and maintenance of houses destroyed or damaged by

natural disasters, as well as adequate, safe and affordable housing for women, low-income and underserved population.

For further details on the key objectives of the SFF, the integration of stakeholders’ views in establishing the SFF, and the online availability of

SFF to affected customers and employees for implementing it, please refer to [IRO-1] Description of the process to identify and assess material

impacts, risks and opportunities and [E1-2] Policies related to climate change mitigation and adaptation. It is noted that the SFF is not currently

relevant to any third-party standards or initiatives.

Group Cybersecurity and Information Security Framework

The Group Cybersecurity and Information Security Framework sets out the information security principles, policies, procedures,

methodologies, technical security standards and guidelines for the classification and protection of corporate information, safeguarding

customer and Bank’s data from unauthorized access. The Framework relates to all the Group’s activities, products and services and applies to

all countries where the Group operates and to all Business Areas of the Bank and Group subsidiaries. It is also mentioned that through the

Group Outsourcing Policy, the Bank and Group subsidiaries are also ensuring that third-party service providers comply with the Group

Cybersecurity and Information Security Framework, where applicable, as well as other applicable ICT security standards.

The Framework is reviewed at least annually to meet the increased requirements arising from the relative regulatory framework (such as NIS

Directive, EU Cybersecurity Act, GDPR, EBA Guidelines on Cloud Services, EBA ICT Risk Guidelines, DORA, etc.), the operational and

technological environment as well as the applicable international standards and best practices. The Cybersecurity and Information Security

Business Area operates under Management Systems certified according to ISO standards, including ISO 22301 (Business Continuity), ISO 27001

(Information Security), ISO 27017 (Information Security Controls for Cloud Services) and ISO 27018 (Protection of Personally Identifiable

Information on Public Clouds), ISO 27701 (Privacy Information Management) and follows the guidelines provided under ISO 20000-1 guidance

system (Information technology). The Business Area also leads the SWIFT CSP assessment and PCI DSS recertification processes for the Bank.

Please refer to [SBM-2] Interests and views of stakeholders for details on how consumers’ views are considered in setting the aforementioned

framework. The Group Cybersecurity and Information Security Framework is available on the Group’s Intranet to all Employees.

Group Personal Data Protection Policy

The Group Personal Data Protection Policy aims to define the rules governing the organizational and technical measures for the effective

management and protection of personal data while ensuring the privacy of the data subjects (i.e. Natural Persons and Sole proprietorships).

Moreover, the policy seeks to enhance customer confidence and preserve the Group’s reputation as well as its competitive presence in the

market. The scope of the policy applies to all Group subsidiaries and their respective Business Units, all Employees, and all third parties that in

any way process personal data on behalf of the Group subsidiaries, as data processors. The Group Personal Data Protection Policy is binding

for Group subsidiaries that operate in countries where GDPR is applicable and process personal data. The policy is accessible to all Employees

on the intranet.

The Policy has been developed to be in compliance with the General Data Protection Regulation (GDPR) and as such, has a strict set of

procedures inter alia it adheres to:

1. Privacy by Design and by Default

2. Record of Processing Activities

3. Data Protection Impact Assessment

4. Data Subjects Rights Management

5. Personal Data Breach Management

The "Privacy by Design and by Default" procedure ensures personal data protection throughout the entire lifecycle of a project, product, or

system, from initial development to operation and withdrawal. It applies to all projects involving organizational redesign or IT systems where

personal data is processed, either by the Bank or third parties. This procedure aligns with the Group Cybersecurity and Information Security

Framework and supports the procurement, development, and maintenance of information systems.

The "Record of Processing Activities" procedure documents all personal data processing activities within business units in a central (Record of

Processing Activities) RoPA. Its purpose is to ensure the RoPA is consistently updated with the information required under Article 30 of the

GDPR through regular or ad hoc reviews.

The Data Protection Impact Assessment is conducted when personal data processing may pose a high risk to the rights and freedoms of

individuals. Its purpose is to identify such high-risk activities and manage them by developing action plans with technical and organizational

measures to mitigate the risks. The "Data Subject Rights Management" procedure ensures that data subjects' requests are received, assessed,

and processed effectively within the required timeframe. It relies on the cooperation and coordination of all involved business units and third-

party data processors.

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The "Personal Data Breach Management" procedure ensures compliance with obligations to protect personal data by identifying, managing,

and responding to breaches promptly. It includes notifying the Supervisory Authority and affected individuals, when necessary, in accordance

with applicable legal requirements.

The Group Data Protection Policy is applicable since 2018, as well as other procedures that cover various obligations stemming from GDPR. To

monitor this policy, KPIs are determined and generated on a regular basis and are subject to periodical review to confirm the effectiveness of

the measures implemented and performance of the data protection program.

Group Outsourcing Policy

This Policy sets specific evaluation criteria for Outsourcing third party service providers, aiming to minimize potential risks for the Group and its

Customers.

Its key objective is to establish the framework guiding the outsourcing activities of the Bank, its Group Companies. It delineates the principles

for evaluating outsourceable activities for Outsourcing third party service providers, the criteria for making outsourcing decisions, and the

specific needs and objectives that each outsourcing assignment aims to fulfil, aiming to minimize potential risks for the Group and its

Customers.

The Group Outsourcing Policy applies to Group Companies in Greece and abroad, and relates to activities outsourcing, on the basis of

Executive Committee Act No 178, as issued by the Bank of Greece (Session 178/2.10.2020), and the relevant guidelines of the European

Banking Authority (EBA Guidelines on outsourcing arrangements EBA/GL/2019/02). The policy covers Outsourcing service providers that may

be deployed regarding the offering of services to customers and end-users, but does not apply to all third-party service providers, as per BoG

Act 178/5/2.10.2020. In addition, the Policy addresses Privacy and Access to Products and Services in line Double Materiality Analysis

performed by the Group.

The Outsourcing Committee is responsible for supervising implementation of the Outsourcing Strategy. It ensures that the BoD is duly and

regularly informed on issues related to the overall implementation and monitoring of the Outsourcing Strategy and Policy. All Business Areas

of the Bank as well as management bodies involved in the outsourcing lifecycle must comply with the Outsourcing Policy (of which the

Outsourcing Strategy is an integral part) and the relevant Procedures. The policy is made available internally on the Group’s intranet page. The

Outsourcing Policy does not apply to all third-party service providers, as per BoG Act 178/5/2.10.2020.

The policy is made available internally on the Group’s intranet page.

Other information on policies related to Customers

It is noted that no specific Alpha Bank S.A. policy is in place regarding responsible marketing practices and access to quality information

although Alpha Bank complies fully with all rules and guidelines established by the Communication Control Board, including the Greek Code of

Advertising and Communication.

The reason for this is that the Bank’s existing processes safeguard its customers regarding the responsible marketing practices and access to

quality information and as such, there has been no need for the introduction of any further policies to cover the needs of consumers as

pertains to the aforementioned material sustainability matters. Respective regulations are regularly assessed to ensure the alignment of the

processes in place. The instructions from the Marketing and Public Relations Committee are followed and Risk Committee is placed on the

promotional/advertising material of products/services available to the Bank in order to ensure compliance with a variety of regulatory texts

such as MiFID II, PPTE 2501/2002, PSDII etc., aiming at the full, transparent, timely and non-misleading information of existing and potential

Customers. Explicit and sufficient information, regarding offered services and products, is provided to all Customers regardless of the

distribution channels. These processes evidence that at Alpha Bank, transparency in promoting its services throughout the business

relationship with Customers is of the utmost importance.

In addition, aspects related to these matters, are integrated in the Code of Conduct and Ethics and the Corporate Responsibility Policy.

Particularly, for ensuring adequate controls against the generation of misleading financial information, as well as corruption, antitrust

violations, abusive contractual terms, insider dealing, conflicts of interest, money laundering, bribery and, towards its Customers, the Group

has set a Code of Conduct and Ethics. Regarding Customers, the Group ensures through the Code of Conduct and Ethics:

• The protection of customer information confidentiality.

• The protection of personal data through secure and appropriate management thereof.

• The provision of explicit information regarding offered services and products, regardless of the distribution channels.

• The transparency in promoting its services throughout the relationship.

• The diligent resolution of complaints and measuring of customer satisfaction.

• The protection of the Customers’ legitimate interests.

• The establishment of the appropriate organizational structure, policies and procedures for the avoidance of conflict-of-interest

situations.

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Furthermore, through the Corporate Responsibility Policy, the Bank prioritizes credibility, consistency, and efficiency in its banking services. As

in accordance with the Code of Conduct and Ethics and the principles of Corporate Governance, the Bank adheres to principles of best banking

and business practices. More specifically, the principles of integrity and honesty, impartiality and independence, confidentiality and discretion

with the aim to provide full, accurate, and truthful information to stakeholders.

More information on the Code of Conduct and Ethics is provided in [G1-1] Business conduct policies and corporate culture of the Sustainability

Statement, as well as on the Group’s website. The Corporate Responsibility Policy is described further on [S1-1] Policies related to own

workforce and the Corporate Governance Statement within the Annual Report 2024.

Apart from the above policies, which ensures responsible practices towards Customers, it should be mentioned that there are policies

specifically addressed to the Branch Network Employees which are available through the Group's Intranet.

Through engaging with its key stakeholders, Alpha Bank S.A. has identified 3 areas that their Customers are prioritizing: 1) access to finance, 2)

data privacy, and 3) sustainable financing. Taking into consideration the interests of its Customers, the Bank has responded through setting the

SFF, the Cybersecurity and Information Security Framework, as well as implementing transition plans for its Customers, developing ESG-related

products and services, ecosystem of ESG partners, and internal risks and controls.

Oversight of policies

The BoD and its Committees are responsible for the Group and approves and oversees the implementation of the abovementioned policies.

Organizationally, the process of monitoring the implementation of the SFF includes a robust SFF governance model and the integration into

the Bank’s existing credit approval process. The Group Sustainability Committee oversees the implementation of the SFF and reports to the

BoD. The Head of Cybersecurity and Information Security Division is responsible for managing the day to day operational execution of this

policy and manages the multilayered security infrastructures and mechanisms for the protection of the services provided. Finally, it is

mentioned that the Group’s Cybersecurity and Information Security Strategic Plan is monitored regularly and reported to the Audit

Committee, Risk Management Committee, and Executive Committee which report to the BoD. The Group’s Data Protection Officer as well as

the DPOs in the Group Companies are responsible for the control and continuous monitoring of compliance and proper implementation of this

policy. The Outsourcing Committee is responsible for supervising implementation of the Outsourcing Strategy. It ensures that the BoD is duly

and regularly informed on issues related to the overall implementation and monitoring of the Outsourcing Strategy and Policy. All Business

Areas of the Group as well as management bodies involved in the outsourcing lifecycle must comply with the Outsourcing Policy (of which the

Outsourcing Strategy is an integral part) and the relevant Procedures.

Adhering to principles for the protection of Human rights

The Bank takes into consideration specific groups of Customers in the content of SFF. The SFF targets socioeconomically disadvantaged

population, living in rural areas or isolated islands with limited or inadequate basic infrastructure, undereducated, long-term unemployed and

working population vulnerable at losing their job due to the energy transition, aging population, vulnerable youth, persons with disabilities or

in need of medical attention with the aim to enhance the sustainable activities performed by the Bank.

The Group demonstrates its commitment and its general approach for respecting the human rights of consumers and/or end-users through

adhering to the following principles:

As signatory of the United Nations Global Compact (UNGC), the Bank operates in respect with “Principle 1: Businesses should support and

respect the protection of internationally proclaimed human rights”; and “Principle 2: make sure that they are not complicit in human rights

abuses.”

Through the UNEP FI initiative, the Group commits to the 6 Principles for Responsible Banking (PRB) including “Principle 3: Clients and

Customers: “We will work responsibly with our clients and our Customers to encourage sustainable practices and enable economic activities

that create shared prosperity for current and future generations.”

It is noted that no standalone human rights policy is in place.

General approach for customer engagement and measures to provide or enable remedy for human rights impacts

The Group continuously seeks to engage effectively with its Customers by establishing meaningful, two-way communication, building trust and

creating value. Through customer engagement, the Group identifies and understands its customer needs and expectations, continuously

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improves the offering of products and services as well as updates and enhance its policies, mechanisms and processes to maintain trust and

build long-term relationships with its Customers.

The Group has a general approach for providing and enabling remedy for human rights impact, through the establishment of both proactive

and reactive measures. The protection of the legal interests and human rights of its Customers is outlined in the Bank’s Code of Conduct and

Ethics. In addition, the Group collaborates with its stakeholders (such as governments, NGOs, and others) for facilitating effective remediation.

It has also established mechanisms and channels available to its consumers, that enable them to raise their concerns. Corrective actions are

immediately taken to mitigate potential risks for the affected Customers. Additionally, the Group undertakes actions to further improve and

strengthen existing technical and organizational measures to prevent the recurrence of such incidents. Please refer to [S4-3] Processes to

remediate negative impacts and channels for consumers and end-users to raise concerns for more information regarding the channels in place.

With a view to ensuring its sustainable development, the Group is committed to operating responsibly, taking due account of the economic,

social and environmental parameters of its operation, both in Greece and in the other countries where it is present. To this end, it promotes

communication and cooperation with all its Stakeholders.

The Corporate Responsibility Policy ensures that the Group aligns its activity with internationally recognized guidelines, principles and

initiatives on sustainable development, such as the Organisation for Economic Co-operation and Development (OECD) Guidelines on

Responsible Business Conduct, the Core Conventions of the International Labour Organisation (ILO), and the Universal Declaration of Human

Rights (UDHR).

There have been no incidents of non-respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental

Principles and Rights at Work or OECD Guidelines for Multinational Enterprises that involve consumers and end-users and that have been

reported in the Group’s downstream value chain. For more information on how the Group monitors compliance with policies, please refer to

[G1-1] Business conduct policies and corporate culture as well as to [S1-1] Policies related to own workforce.

Significant changes in policies related to Customers in 2024

During 2024 no significant changes in policies related to Customers have been made. The Complaints Management Policy was updated, in

order to include:

• (a) changes driven from regulatory requirements,

• (b) re-structures in organizational and operational responsibilities and

• (c) aspects of corporate responsibility.

The updated policy ensures transparent, effective, and lawful complaint handline to build trust and comply with regulations, including Bank of

Greece directives. Key changes include a Central Complaints Management Team (CCMT), clear stakeholder roles, a single online submission

channel, prioritization based on risk and complexity, and timelines exceeding legal requirements. Monitoring, escalation mechanisms, and root

cause analysis support accountability and continuous service improvement.

[S4-2] Processes for engaging with consumers and end-users about impacts

The Group’s stakeholder engagement approach is founded on the principles of transparency, inclusivity, and accountability, ensuring that its

sustainability efforts align with stakeholder expectations and values.

Alpha Bank S.A. aims to maintain ongoing dialogue and collaboration with these stakeholders to understand and address their expectations,

needs, concerns, and requests as much as possible. Recognizing the diversity among its stakeholders, the Bank has developed tailored

engagement and communication strategies to meet the unique needs and preferences of its consumers and end-users.

It prioritizes customer satisfaction and the delivery of high-quality products and services. The Customer Service Division, which oversees

Quality Assurance, is dedicated to these goals. Further, the Bank incorporates customer feedback to be reflected in the offering of products

and services.

The Group is dedicated to frequent engagement with its stakeholders, providing them with transparent and material information. Direct

engagement occurs with specific representatives of Customers which are considered as major Customers of Alpha Bank S.A. in Greece.

Furthermore, Relationship Managers collect and communicate customer feedback. Additional details are available under [SBM-2] Interests and

views of stakeholders.

Communication with all stakeholder groups is conducted on an annual, bi-annual, quarterly, and ad hoc basis. For information on the types of

communication and engagement with customers, please refer to [SBM-2] Interests and views of stakeholders.

Operational responsibility for ensuring the accomplishment of engagement and outcomes

The Head of Customer Service Division is the most senior role that has operational responsibility for ensuring that this engagement occurs. The

Division’s primary objective is to ensure customer satisfaction and deliver high-quality products and services. To achieve this, the Division

actively gathers input through customer surveys, relationship managers, and by analyzing data from the Bank’s digital platforms to understand

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consumer behavior and preferences. The insights gathered from these engagement activities are used to inform the Bank’s policies, practices,

and product development, ensuring that customer expectations and concerns are addressed effectively.

Effectiveness of the Customer engagement

The effectiveness of the engagement with consumers and/or end-users is evidenced by identifying specific matters through workshops,

surveys with specific clients, and feedback received through the existing channels for consumers to raise concerns and integrating their

expectations and needs in informing and initiating new initiatives, products and services.

It is mentioned that no specific process with particular steps for engaging and for gaining insight into the perspectives with consumers and/or

end-users who may be particularly vulnerable to impacts (for example, people with disabilities, children, etc.) and/or marginalized consumer

groups is in place. The general approach for consumer engagement applies to all consumers of the Group’s products and services.

Please refer to [GOV-1] The role of the administrative, management and supervisory bodies to see the relevant responsibilities on the

organizational structure.

[S4-3] Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

It is noted that no negative material impact to Customers has been identified through the double materiality assessment conducted in 2024.

However, in the event of negative impacts to its Customers, the Bank has established specific mechanisms and processes for contributing to

the remedy of them.

Any actions that might have caused to the Customers, may be reported through the Whistleblowing mechanism, available on the website. The

Whistleblowing Policy ensures that anonymity of the Whistleblower that utilizes the mechanism, will be properly protected in order to avoid

any possible negative consequences, such as threats or attempts of retaliation, or discrimination or any other form of unfair treatment.

Submitted reports are communicated only to predefined persons, the number of which is narrowed to those responsible for carrying the

investigation and are entitled to act in discretion and confidentiality. By respecting the above would also result in protecting the identity of the

reported persons. Please see the [G1-1] Business conduct policies and corporate culture.

In addition, through the “Notification on the Processing of Personal Data” Group Companies where GDPR is applicable inform their Customers

on how their personal data is processed by the organization or third parties on its behalf and on how to exercise their rights as per the GDPR.

Available on their website and intranet, the "Notification on the Processing of Personal Data", also details the purpose, sources, recipients,

storage duration, and contact information regarding Data Controller and Data Protection Officer. Furthermore, special privacy notices are

provided to Natural Persons whenever necessary.

Furthermore, a Support Centre has been established to address customer grievances. Under this mechanism, the Bank has a Customer Service

Call Centre, Merchants Customer Service Call Centre, and direct lines for different business units/subsidiaries. The main call center directs to

Alpha Bank S.A. with individual contact numbers listed for the Group’s services at Alpha Real Estate S.A., Generali, Alpha Leasing, AlphaTrade,

and Alpha Mutual Funds. Complaints are managed by the Customer Service Division of Alpha Bank. It tracks and monitors issues raised and

addressed via the implementation of a Contact Form on the Bank’s website and listed contact numbers. The Bank aims to revert to customer

issues with a clear and substantiated reply in accordance with the applicable Regulatory and Legal provision. Additionally, the Customer

Service Division employs a Quality Management System based on the ISO 9001 standard. Upon receiving a complaint, the Customer Service

Division undergoes a 4-step process:

1) Acknowledgement of receipt of the case

2) Investigation with cooperation of the competent Units of the Bank

3) Resolution of the issue

4) Customer response

If the customer disagrees with the proposed resolution or reply, they are provided with the option to decline the proposed resolution. In that

event, the consumer may revert to the Hellenic Financial Ombudsman (the contact information of which is provided on the Group’s website).

All the above information is provided on the Bank’s website, including the expected wait time and answers to Frequently Asked Questions.

Customers are updated throughout the process using the contact details they provided (by SMS, phone, or letter).

These processes have been implemented by the Bank without the participation of third-party mechanisms.

The above processes refer to channels provided to Customers for raising their concerns, not only for the Bank’s activities, but as well for any

activities provided to them from the Bank with cooperation of business partners (i.e. suppliers and other external parties). Currently, no

particular assessment takes place for the effectiveness of the mechanisms and channels that the Group utilizes for its consumers to raise their

concerns.

However, Alpha Bank S.A. monitors and tracks the number of complaints submitted, independently of their nature. The number of complaints

received from consumers and/or end-users during FY24 was 24,942. Customer usage of these channels as a means of providing feedback

demonstrates that customers feel empowered to raise concerns and trust the mechanisms for resolution disclosed above.

[S4-4] Taking action on material impacts on consumers and end-users, and approaches to managing material risks and

pursuing material opportunities related to consumers and end-users, and effectiveness of those action

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The key actions that the Group performs to increase the positive impacts created to its Customers, are reflected through its SFF and refer to:

• The development of Green and Sustainable financial products such as products for SME lending in emerging markets, Microfinance

lending, Financing of construction, renovation and maintenance of houses destroyed or damaged by natural disasters, Adequate,

safe and affordable housing for women, low-income and underserved population.

• The integration of sustainability criteria into credit and loan approvals.

The products are targeted especially to affected stakeholder groups, such as Females, Rural populations focusing on agricultural production

and agricultural value chains, Excluded and/or marginalized populations, Financially, disadvantaged groups as referenced also in [S4-1] Policies

related to customers. The SFF does not currently set a defined time horizon regarding the number of products aligned to it, but it has a long-

term view. It currently applies in Greece for Alpha Bank S.A. with the aim to extend to the other Group companies over the next few years.

Regarding the progress of the alignment, the SFF-aligned products are currently summarized in following categories:

I. Dedicated-Purpose Social Loans: Fully directed loans toward projects or initiatives that align with the eligible social themes defined under

Alpha Bank’s SFF. Examples include:

• Affordable Housing Loans

o Loans provided to low-income or vulnerable populations to enhance access to affordable and adequate housing.

o Financing for social housing projects or housing cooperatives aimed at improving living conditions for marginalized groups.

• Microfinance for Underserved Communities

o Small-scale loans to individuals or micro-businesses owned by women, rural populations, or minority communities to

enhance financial inclusion and economic empowerment.

o These loans support small entrepreneurs in starting or expanding businesses in sectors such as agriculture, retail, and local

services.

• Loans for Education and Vocational Training

o Financing for tuition fees or vocational training programs to improve employability, particularly for young individuals,

disadvantaged communities, or those at risk of social exclusion.

o Special education loans designed for students from low-income backgrounds.

• Healthcare Infrastructure Loans

o Loans to fund hospitals, clinics, or medical centers that provide essential health services to underserved populations.

o Financing for mobile health units that reach rural or remote areas.

• Sustainable Transport and Mobility Access Loans

o Financing for projects that improve access to safe and affordable public transportation for low-income groups and people

with disabilities.

o Examples include funding for electric public transport systems in underserved areas or bike-sharing programs that promote

inclusive mobility.

• Loans for Social Enterprises and Nonprofits

o Financing for social enterprises that address pressing societal needs, such as food insecurity, youth employment, or

financial literacy programs.

o Support for non-profit organizations developing community-based solutions for economic inclusion.

II. Sustainability-Linked Loans: Loans that tie financing terms as interest rates to the achievement of predefined sustainability performance

targets (SPTs). The Bank sets key performance indicators (KPIs) related to social-related goals; examples include:

o Financial Inclusion for Banks and Microfinance Institutions

o Workforce Diversity and Inclusion

o Health and Well-Being

o Education and Training for Employers

o Digital Inclusion and Technology Access

For ensuring that Responsible Marketing Practices and Access to Quality Information are in place, key actions include the existence of robust

internal mechanisms for controls, processes that ensure ethical marketing communications, transparency, honesty, and compliance with

regulatory standards. These processes ensure that for every advertising communication plan assessment is performed by the competent

Divisions and, if required, by the Legal Services Units or by the Compliance Division, to ensure objectivity when providing information. This

works to ensure that there is no negative ramification for Customers due to manipulation or misinformation as the above processes serve to

mitigate any such outcome. Advertisements include all necessary details to inform the public. When space or time constraints prevent full

disclosure (such as in TV or radio spots), the Bank provides its website (www.alpha.gr) or Call Center number for more information. These

practices apply in Greece for Alpha Bank S.A., but similar practices are also established in other areas where the Group operates. In this

respect, the Bank complies with the regulatory framework in force regarding transparency in providing information to contractual parties,

precontractual information, advertising as well as the terms of contracts with its Customers.

The above actions do not have a defined time horizon for completion, but govern continuously the Group operations. Regarding the progress

of the actions, regular monitoring takes place to ensure that no incidents of non-compliance with regulatory framework and marketing

practices have been occurred.

Through continuous training programs for staff, the Bank prevents any potential negative impact, or realization of risk that concern Privacy -

related incidents. The trainings improve the internal capacity building to enhance service quality and delivery, leading to increased customer

satisfaction. Trainings are performed on an annual basis. This enhances the Group to serve its Customers effectively, ultimately contributing to

stronger relationships with Customers and driving overall business success.

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Regarding the identification and reaction to Cybersecurity and Information Security risks, employee awareness and training is a critical and

continuous activity. In addition to the program for new employee induction to Group Cybersecurity and Information Security Framework

principles, a sophisticated Cybersecurity Awareness Program is being structured at the beginning of each year and supported by an e-learning

platform. During 2024, the annual Cyber Awareness Program was completed successfully, and new Cybersecurity and Information Security

training modules were introduced. The main training objectives, the appropriate training strategy as well as the initial planning of the trainings

are determined at this stage. Training content is updated regularly to maintain its relevancy and is adjusted to each role, within the Bank to

achieve the necessary growth and development. The training program is reviewed during the year and may be modified according to new

needs that may arise. The training plan includes specialized training and certifications for Managerial/Administration and Technical functions in

Greece, and the other countries where the Group operates. Moreover, data protection training sessions are conducted throughout the year

for all new Employees of the Bank. During 2024, the following sessions took place:

• Control and Risk Culture: boosting awareness in data protection with specialized training sessions to appr. 420 Bank’s Branch

Network Employees.

• Data Protection Institutional Framework: training session with the participation of approximately 170 Group Employees in Greece

that covered various data protection issues such as Artificial Intelligence, emerging regulatory obligations (e.g. DORA, NIS II) and

third-party assessment.

Data protection training sessions take place in Group Companies in Greece, Romania and Cyprus, where GDPR is applicable.

The above actions are ongoing and thus, there is no timeframe of completion. The progress of these actions is regularly monitored to ensure

that no severe incidents of non-compliance with regulatory framework takes place. For this reason, to support the implementation of the

above, human resources are utilized and expected to continue to be utilized in the future time horizon such as through employee training and

consulting services to empower Employees’ knowledge and skills for sustainable projects, and utilization of technological solutions, such as

digital tools.

Furthermore, it should be mentioned that the existing processes reassure not only that no material financial effects will affect the Bank but

also that no material negative impacts will be created to its Customers.

Due to the nature of the Group business activities (i.e. related to the financial services and products), the Group does not require any

significant operational OpEx and/or capital expenditures CapEx that relate to the implementation of its actions towards the achievement of

policy objectives and targets. New requirements are routinely addressed in the broader context of its ongoing operational enhancements and

are in any case considered material.

Actions to enable and provide remedy

No negative material impact to consumers and end-users has been identified. However, the Group, through its policies, procedures and

mechanisms has established certain actions that safeguard its consumers and ensure that negative impacts on them will be prevented and

mitigated. These actions include the design of consumer-centric products that meet their needs, the existence of a robust Risk Management

for credit assessment and prevention of fraudulent activities, the implementation of ethical business practices, and transparency of

information, as well as building among its Employees a culture of corporate responsibility.

Other customer-related initiatives

In 2024, in collaboration with the largest recycling program in Greece, Alpha Bank S.A. supported Customers of the Bonus app with e-coupons

for enhancing their accessibility to goods, while promoting recycling. By recycling household waste at specific Mobile Green Points, Customers

earn “Green City” points, which they can convert into Bonus points through the Bonus app. Until November 2024, Bonus Customers have

responded with great interest and have proceeded into 7,781 conversions of green city points into 19,452,500 Bonus points. The collaboration

between Bonus and “Green City”, actively supports recycling since it offers an extra benefit to Bonus Customers to recycle on a regular basis.

More information can be found by visiting the website.

In pursuit of its mission to increase Access to Finance, the Bank launched the myAlpha Documents service after the first half of 2023, in order

to serve specific banking operations. To date, more than 3,000 requests from individuals and businesses have been served by utilizing the

possibility of exchanging documents with the Bank's Branch Network and Central Services, with the majority of Customers who have used the

service evaluating it positively. Most of the positive feedback focuses on the benefits of being able to exchange and sign files remotely 24/7,

without requiring a store visit. The use of the service has saved more than 20,000 pages of documents that have been distributed digitally.

Approach for identifying, taking actions and ensuring availability and effectiveness of processes to manage material impacts

No negative material impact to Consumers and end-users has been identified.

Cyber Risk Methodology

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The development and evolution of the Cyber Risk Methodology considers international standards and frameworks and is aligned with the

Group Operational Risk Policy, while the assessments are further enhanced with information from data classification and Security evaluations

(Penetration Tests, Vulnerability Assessments). The Cybersecurity and Information Security Business Area directly supports Business Areas and

Group Subsidiaries in conducting Information Classification and Cybersecurity and Information Security Risk Assessments (CISRA) for

applications that support critical business processes including cloud-based applications, as well as conducting the coordination and monitoring

of the execution of improvements and remediation of deviations. Continuous and real time identification of Cybersecurity vulnerabilities for

critical systems is performed via the deployment and configuration of dedicated software on the corresponding infrastructure.

The Alpha Bank Computer Security Incident Response Team (AB CSIRT) is certified as a full member of the global Forum of Incident Response

and Security Teams (FIRST) and the Financial Services Information Sharing and Analysis Centre (FS-ISAC) and cooperates with the National

CSIRT and the National Cybersecurity Authority to ensure continuous information exchange and response to cyber threats. During 2024, the

AB CSIRT has dedicated significant time and effort towards fostering growth across various and critical Threat Management domains. The

Cyber Threat Intelligence Framework has been formalized and included within the Group Cybersecurity and Information Security Framework.

Identity Management (IDM) Governance as well as operational framework adaptations were implemented as part of continuous improvement.

The IDM Governance module was analyzed and designed to be the central repository for user access review and recertification status.

Application owners gain advanced visibility allowing them to perform user access review effortlessly.

The Cybersecurity and Information Security Business Area manages the multilayered security infrastructures and mechanisms for the

protection of the services provided (defense in depth). In 2024, replacements, upgrades and major improvements of critical Cybersecurity

infrastructures were performed, including new SIEM solution and a new MSSP Provider.

Moreover, additional measures have been introduced to protect Customers. Through myAlpha Web, retail Customers are given the

opportunity to temporarily lock their e-Banking subscription if they suspect interception or leakage of their passwords or detect suspicious

activity in their e-Banking. Changes were also made to the myAlpha Code guidelines to provide a more secure experience; the registration of

the 6-digit code is now requested in all transactions to third parties in subscriptions with the service activated as well as during login. Access is

blocked upon incorrect myAlpha Code entries via SMS OTP (one-time password).

Please refer to [GOV-5] Risk management and internal controls over sustainability reporting for more information on the Group’s approach to

risk management.

The Group has not recognized any material negative impacts on consumers and/or end-users through its own practices. However, for further

information please refer to [S4-4] Taking action on material impacts on consumers and end-users, and approaches to managing material risks

and pursuing material opportunities related to consumers and end-users, and effectiveness of those action.

No severe human rights issues and incidents connected to consumers and/or end-users have been reported.

For managing the impacts, the Group utilizes several human resources in its Retail Banking Division, Customer Service Division, Marketing and

Public Relations Division, the Group Data Protection Office, and the Cybersecurity and Information Security Division, among others monitor

impacts to the Group’s consumers. For more information, refer to [S4-4] Taking action on material impacts on consumers and end-users, and

approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those

action.

[S4-5] Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and

opportunities

Regarding its material positive impacts to Access to products and services, and Contribution to Healthy Economies, the Bank’s Strategic Targets

are aligned with SFF and enhance the positive contribution to consumers and end-users. The targets set above are referring to consumers and

end-users (downstream value chain). Progress against targets are monitored through specific Key Performance Indicators (KPIs), as presented

in the following table. Targets have been set at Group level (where no reference exists in the table below), the largest Group entity Alpha Bank

S.A. has reported progress and where relevant other Group entities will progressively adopt them.

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TABLE 61 TARGETS RELATING TO CONSUMERS AND END-USERS

Target description

Target

level

Absolute /

Relative

Baseline value

Baseline

Year

Target

Year

Scope

Progress

in 2024

KPIs

Increase access to

people with mobility

limitations to

85%

of our Branches

85% of

Branches

Absolute

80%

2023

2025

Downstream,

Alpha Bank S.A.

(Greece), Alpha

Bank Romania,

Alpha Bank

Cyprus, Alpha

Bank London

85.5%

Percentage of Branches

accessible (fitted with a

ramp or easily

accessible) by people

with disabilities (%)

Safeguard internal risk

controls that protect

the Customers’ data

N/A

Absolute

N/A

Ongoing

Downstream,

Alpha Bank S.A.

(Greece)

Personal Data breach

incidents (number of

incidents notified to

Personal Data

Protection Authorities)

Achieve at least Euro

300 million of Retail

sustainable loans,

including loans to small

businesses by 2026

measured by total

sustainable

disbursements.

Euro 300

million

Absolute

Ν/Α

2024

2026

Downstream,

Alpha Bank S.A.

(Greece)

67.5

Total amount Euro

million

Launch new

sustainability-based

mortgage and

consumer loan products

and credit cards.

N/A

Relative

(Exoikonomo,

Ecolytiq)

2023

Ongoing

Downstream,

Alpha Bank S.A.

(Greece)

Number of products

launched

Support financial

inclusion through

educational programs

addressed to teachers,

students, women and

people over 55.

N/A

Relative

(Alphabet of

Economics,

Circular

Economy in

Action,

Economy

lessons,

e-conomy for

all)

2023

Ongoing

Downstream,

Alpha Bank S.A.

(Greece)

Number of CSR

programs implemented

for the financial

inclusion addressed to

people over 55 –

Alphabet of Economics

Note 1: Baseline year is the same with base year.

Note 3: Refer to the “Reporting Group” of Sustainability Report 2023.

Please note that these metrics are absolute numbers and as such, there are no significant assumptions or methodologies behind them. It is

noted that the metrics described have not been assured by an external third party. As pertains to the relative targets in the above table, the

methodologies used are indicated by the KPIs detailed in the relevant column. No other methodologies or assumptions were used.

It is noted that the Sustainability strategy of 2023-2025 has been reviewed in 2024 and updated for the next yearly period (2026), i.e.

Sustainability strategy (2024-2026). The aforementioned targets apply for the period 2024-2026. Furthermore, it is noted that no interim

targets or milestones have been set. The methodology for setting the targets includes the review of best practices, peer benchmarking and

understanding of the Group business model, utilizing also input from the Group’s stakeholders, such as investors, and clients. Furthermore,

targets have been set with the aim of aligning the Group business model and strategy with the contribution to the UN Sustainable

Development Goals. For setting the targets no critical assumptions were made.

Further to the above, the Group has also the following targets:

Support Female entrepreneurship

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o In support of female entrepreneurship, the Bank launched the "Alpha Females for VentureGarden" program in collaboration with

Anatolia College in May 2024.

o In 2024, the percentage of female Owners of Individual Businesses which were included in the Segment of Small Businesses (Alpha

Bank S.A. portfolio) out of total owners of individual businesses was 33.8%.

Increase digital sales by 30%.

o Regarding the full digitalization of banking services and the target for 30% increase in digital sales, in 2024, 40% of cards issued

digitally in the like for like category, families using myAlpha Vibe increased to 5,000, 3 out of 4 disbursed consumer loans were

granted through digital channels. Additionally, since the Credit Life Insurance launch, 14% Bancassurance production through digital

has been reached in 3 months.

WHILE THE TARGET TO SAFEGUARD INTERNAL RISK CONTROLS THAT PROTECT THE CUSTOMERS’ DATA REMAINS THE SAME, THREE KPIS

FROM THE 2023 SUSTAINABILITY REPORT ARE NO LONGER INCLUDED AS THE GROUP’S POLICY AND MONITORING PROCESSES REMAIN IN

ACCORDANCE WITH THE GDPR REQUIREMENTS.

The targets relate to consumers and end-users and therefore due to their nature are not based on conclusive scientific evidence.

It is noted that currently, the setting of targets, the tracking of the performance against targets and the improvement of targets set, is

conducted with the involvement of internal stakeholders, and not with the participation or engagement of Customers. However, the Group

continuously seeks the engagement of Customers, for setting its policies, and respond to their needs, and will enhance further the integration

of their views into its decision-making and strategic actions.

It is noted that regarding Responsible Marketing Practices and Access to Quality Information, no specific measurable outcome-oriented target

has been set. Regarding these sustainability matters minimum safeguards apply. The overarching goal of the Group is not to cause or

contribute to significant harm of Customers through either its own operations or its business relationships.

Please refer also to the ESRS S4 Section “Policies related to consumer and end-users” and “Processes to remediate negative impacts and

channels for consumers and end-users”.

Entity-Specific Information

The effectiveness is monitored through specific Key Performance Indicators, that have been established from the Group as follows:

Access to (quality) information

Access to (quality) information has been identified as a material risk pertaining to the Group’s downstream value chain. This pertains to

potentially unsuitable promotion practices (CR), fiduciary breaches (miscellaneous, CR), and product suitability issues / inadequate disclosures

of product terms (CR).

Table 62 Number of incidents of non-compliance concerning product and service information and labelling

Alpha Services and Holdings Group

2024

Number of incidents of non-compliance

concerning product and service information

and labelling

Note 1: GRI Standards, Disclosure 417-2

This metric was calculated based on incidents of non-compliance with regulations resulting in a fine, penalty, or warning, and incidents of non-

compliance with voluntary codes. This metric excludes any incidents of non-compliance in which the Group was determined not to be at fault

as well as any incidents of non-compliance that relate to events in periods prior to the reporting period, if applicable. It is noted that the

metrics described have not been assured by an external third party.

Responsible marketing practices

The Group has identified Responsible Marketing Practices as a material inherent risk pertaining to its downstream value chain through its

products/services and business relationships with Customers. This is due to product suitability issues/inadequate disclosure of product terms

(CR), unsuitable promotion practices (CR), and fiduciary breaches (miscellaneous).

TABLE 63 INCIDENTS OF NON-COMPLIANCE CONCERNING MARKETING COMMUNICATIONS

Alpha Services and Holdings Group

2024

Incidents of non-compliance concerning

marketing communications

1,2

Note 1: It is noted that the data has not been verified externally.

Note 2: GRI Standards, Disclosure 417-3

The Group will consider in the upcoming years to review its strategic plans and enhancing its performance with more outcome-oriented

targets, where applicable.

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This metric was calculated based on incidents of non-compliance with regulations resulting in a fine, penalty, or warning, and incidents of non-

compliance with voluntary codes. This metric excludes any incidents of non-compliance in which the Group was determined not to be at fault

as well as any incidents of non-compliance that relate to events in periods prior to the reporting period, if applicable. It is noted that the

metrics described have not been assured by an external third party.

Personal Data Protection

In 2024, the following personal data breach incidents were identified and reported. For these incidents corrective actions have been

immediately implemented 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.

TABLE 64 METRICS TO SAFEGUARD INTERNAL RISK CONTROLS THAT PROTECT CUSTOMERS DATA

Alpha Services and Holdings Group

2024

Personal Data breach incidents (number of

incidents notified to Personal Data

Protection Authorities)

Note 1: GRI Standards, Disclosure 418-1(b)

For their calculation:

- For the Group Companies in Greece, the data was provided by the Customer Service Department through the ACCM Application.

These metrics were calculated based on complaints received from outside parties and substantiated by the Group and complaints from

regulatory bodies. Substantiated complaints are defined as a written statement issued by a regulatory or similar official body addressed to the

Group that identified breaches of customer privacy, or a complaint lodged with the Group that has been recognized as legitimate by the

Group. Breaches of customer privacy refer to any incidents of non-compliance with existing legal regulations and (voluntary) standards

regarding the protection of customer privacy. No significant assumptions have been made. It is noted that the metrics described have not been

assured by an external third party.

Access to products and services

IQonomy is a corporate social responsibility initiative designed to strengthen financial literacy and advocate for a circular economy, with the

overarching objective of tackling financial exclusion and fostering sustainable growth. It targets social groups identified by the OECD as

particularly susceptible to financial literacy challenges. IQonomy is fully aligned with the Greek national strategy for financial literacy launched

by the OECD and overseen by the Greek Ministry of Economy and Finance. The program aims to instill fundamental financial knowledge and

skills in students at all educational levels, empower women, and educate individuals aged 55 and above on navigating the digital landscape of

transactions. Comprised of four specialized programs,

• Alphabet of Economics

• Circular Economy in Action

• Economy Lessons

• e-conomy for all

These initiatives are carried out in partnership with Civil Society Organizations and Non-Governmental Organizations (NGOs).

TABLE 65 FN-CB240A.4 NUMBER OF PARTICIPANTS IN FINANCIAL LITERACY INITIATIVES FOR UNBANKED, UNDERBANKED, OR

UNDERSERVED CUSTOMERS

Alpha Services and Holdings Group

2024

Alphabet of Economics

593 teachers and 6,693 students

Economy Class

383 women Employees, Customers,

general public

e-conomy for all

195 participants

Circular Economy in action

235 teachers and 16,166 students

Note 1: The total number includes 122 women Employees, 86 women Customers and 175 women from general public through the

collaboration with Women On Top Organization.

The metrics described on Table 67, refer to absolute numbers of participants and as such, there are no significant methodologies behind them.

These, refer to 2024 as year of implementation. The scope of financial literacy is enabled by four programs covered under the IQonomy

initiative, through which students, teachers, women, and people over 55 can apply. All participants are considered as direct beneficiaries,

which the common practice for CR Programs. In more detail:

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Alphabet of Economics:

• Runs in collaboration with NGO ActionAid Hellas.

• The program runs during school year, is addressed to school teachers and students and is approved by the Ministry of Education.

• Εducational method: train the trainer seminars for school teachers. In-class workshop for students aged 10-15 years old.

• An open call takes place before the beginning of each cycle and teachers can apply to participate to training seminars for free.

• The program is monitored through a report sent by Action Aid which is shared to Alpha Bank upon the completion of each cycle.

Economy Class:

• Runs in collaboration with NGO Women On Top.

• Addressed to women 18+ from all over Greece and female Alpha Bank employees.

• Training method: monthly on-one seminars. Runs during a period of 9 months.

• An open call takes place before the beginning of each cycle and women can apply to participate to training seminars for free.

• Monitored through a report sent by Women on Top which is shared to Alpha Bank upon completion.

e-conomy for all:

• Runs in collaboration with NGO People Behind.

• Addressed to people 55+.

• Training method: weekly physical or on-line seminars.

• NGO approach Municipalities that are interested to host the program and the seminars take place at the municipality’s Community

Center for Seniors (ΚΑΠΗ).

• Monitored through a report sent by People Behind which is shared to Alpha Bank upon the completion of each cycle.

Circular Economy in action:

• Runs in collaboration with NGO SciCo (Science Communication).

• Runs during school year (2 cycles per year), is addressed to school teachers and students and is approved by the Ministry of

Education.

• Εducational method: train the trainer seminars (online and physical) for school teachers and in-class workshop for students 12-17

years old.

• An open call takes place before the beginning of each cycle and teachers can apply to participate to training seminars for free.

• Monitored through a report sent by SciCo which is shared to Alpha Bank upon the completion of each cycle.

All four metrics described received no assurance by an external body so far, but a Social Impact Assessment and a SROI are now taking place by

a third-party consultant an external body and results will be available at the end of Q2/2025.

TABLE 66 METRICS FOR ACCESS TO FINANCE AND HOUSING

Alpha Services and Holdings Group

2024

Disbursements of retail sustainable loans and

consumer green loans for housing purposes

during 2024

Euro 39.1 million

Number of voice-directed ATMs for visually

impaired people

299 of 1,193 (~25%)

Note 1: Retail sustainable loans related to co-financed loans under state incentives programs such as, “EXOIKONOMO” and other social loans

(e.g. education) for the low-income and vulnerable population. Consumer green loans for housing purposes related to loans which finance

residential properties with EPC certificate’s grade A or higher for new properties and B+ or higher for properties renovation.

Note 2: As of 31.12.24, most of Alpha Bank's ATMs (>1,100) in Greece have had hardware sockets to support the voice guidance service.

However, the Bank has implemented this service in 299 ATMs as it has a total of 300 licenses for this software. The following factors were

taken into account in the selection of ATMs:

- coverage of as many counties as possible

- central points with high transaction volumes

- proposals of the Panhellenic Association of the Blind (high traffic points, e.g. near/opposite clubs)

The number of ATMs providing this service will increase with the approval of the purchase of additional software licenses.

The type of loans mentioned are aligned with Group’s Sustainable Finance Framework, in which sustainable criteria are clearly defined. It is

noted that the metrics described have not been assured by an external third party.

Please note that these metrics are absolute numbers and as such, there are no significant assumptions or methodologies behind them. It is

noted that the metrics described have not been assured by an external third party.

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CONTRIBUTION TO HEALTHY ECONOMIES

By providing tailored financing solutions such as business loans, credit lines, and trade finance, the Group enables economic growth and

contribute to Healthy economies. More information about how the Group business model and strategy as well as the management of impacts

contribute to Healthy Economies can be found in the sections under ESRS S4 Consumers and end-users’ chapter. The following metrics relate

to new financing volumes achieved in 2024, hence reflect the Group’s actions towards the implementation of its target to reach Euro 4.4

billion by 2026.

TABLE 67 NEW FINANCING VOLUMES TO RETAIL GREEN AND SOCIAL LOANS

Alpha Services and Holdings Group

2024

Disbursements of Retail Green and Social

Loans during 2024

(total amount in Euro million)

Euro 67.5 million

Note 1: Retail Green and Social Loans related to retail sustainable loans, consumer green loans for housing purposes and sustainable loans to

small businesses, such as EU RRF loans and other EU co-financed loans.

It is noted that these metrics are absolute numbers and as such, there are no significant assumptions behind them. The type of loans

mentioned are aligned with Group’s Sustainable Finance Framework, in which sustainable criteria are clearly defined. It is noted that the

metrics described have not been assured by an external third party.

GOVERNANCE

ESRS G1 - BUSINESS CONDUCT

[G1-1] Business conduct policies and corporate culture

Alpha Services and Holdings Group is committed to conducting business according to applicable laws, rules, regulations and the highest ethical

standards, as an essential element of the responsibility towards its Customers, other Stakeholders and Shareholders for the protection of the

reputation and long-term success of business. The Group is committed to maintaining the highest level of ethics and professional behavior,

adopting zero-tolerance approach towards illegal or actions which might negatively affect its reputation and credibility. These commitments

are crucial pre-conditions for the maintenance of a robust corporate culture which contributes to the highest standards of conduct with

business issues.

Alpha Services and Holdings S.A. adheres to effective Corporate Governance, which the Alpha Bank S.A. pursues on an ongoing basis, taking

into account the requirements of the institutional framework, the best practices at international and at European level, the interests of its

Shareholders as well as the expectations of its Stakeholders and the society.

Alpha Services and Holdings S.A., 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 Alpha Bank S.A. adheres to the Code

which is available on its website.

The BoD is responsible for the management of the Alpha Services and Holdings S.A.’s affairs, including oversight of business conduct issues.

The BoD has the ultimate and overall responsibility for the Alpha Bank S.A. and defines, oversees and is accountable for the implementation of

the governance arrangements within Alpha Services and Holdings S.A. that ensure effective and prudent management of the Alpha Services

and Holdings S.A. Amongst others, the BoD:

- ensures the integrity of the accounting and financial reporting systems, including financial and operational controls and compliance

with the law and relevant standards,

- oversees the process of disclosure and communications,

- is responsible for providing effective oversight of senior management.

Overall, the BoD is responsible for the ultimate oversight of all conduct of business-related issues concerning the Alpha Bank S.A., which, in the

context of the present statement are the prevention of bribery and corruption, as well as the ongoing evaluation and development of a robust

corporate culture.

See ESRS 2 for detailed reference to the four Board Committee responsibilities and composition as well as the Corporate Governance

Statement of the Annual Report 2024.

Fostering a Strong Corporate Culture

Alpha Services and Holdings Group’s Corporate Culture has been shaped by the over 140 years of positive contribution to the Economy and

Society. Known for the strong financial expertise and stability, the Group maintains a corporate culture that leverages its Purpose and Values

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as a compass and is supported by a robust set of policies as presented further in the Policies section, covering key areas of business conduct

topics that are material to Alpha Bank S.A. and central to its operational effectiveness.

Policies

All policies, procedures, and controls safeguard the prudent management of non-compliance risk with the applicable regulatory framework, as

well as the alignment of corporate culture with a robust business conduct framework

This framework includes the Code of Conduct and Ethics, the Whistleblowing Policy, the Anti-bribery and Corruption Policy, the Anti-Money

Laundering and Counter-Terrorism Financing Policy, and the Policy on the Prevention of Conflicts of Interests. These policies are available in a

dedicated section of the Group’s intranet, with a corresponding circular uploaded in the event of a new or updated Policy. Additionally,

fundamental Codes and Policies and Compliance Regulations applied by Alpha Bank Group are provided in the Governance section of Alpha

Bank’s and Alpha Services and Holdings websites. The BoD is accountable for these policies, while the Compliance Business Area works as the

owner and is responsible for responding to any concerns or questions from staff, as well as for monitoring their proper implementation

through internal controls which cover all functions. These Policies are addressed to all Employees of the Group, as well as to all stakeholders

related with it. They are designed to complement the Personnel Regulation, Policies and Procedures of the Bank, which refer to the general

duties of all Employees. Policies are in line with the applicable national regulatory framework, the principles of the UN Global Compact to

which the Group is a signatory of and best practices within the European Union. There is alignment with the United Nations Convention

Against Corruption principles through the policies and actions described in this section, however the Group has not formally endorsed the

Convention yet.

The following policies are made available to all potentially affected stakeholders who may wish to use them and/or implement them through

the intranet (for internal stakeholders) and the public website (for external stakeholders). All new Employees are explicitly made aware of the

policies through trainings and are asked to review them upon joining.

Additionally, Alpha Bank Employees follow annual training programs on Anti-money Laundering, Bank Secrecy and Anti-Corruption policies and

procedures including the Whistleblowing policy, the Code of Conduct and Conflict of Interest policy– either in person or online. Through e-

learning, Employees have free access to educational notes concerning these topics, allowing for an interactive presentation containing a series

of questions and enhancing attention and understanding.

The Group has not yet set specific targets related to anti-corruption and anti-bribery, aside from the metrics provided and cover trainings per

policy, as the enforcement of the policies described ensure compliance with a strong corporate culture and values.

Nonetheless, the Group has ensured to take all necessary actions need to address the policy-objectives:

• Wide access of the relevant policies to all internal and external stakeholders

• Availability of appropriate channels for the handling of internal and external complaints

• Regular trainings covering the scope of the policies comprising sound business conduct

Additionally, in 2024 the Group laid the foundation for launching and promoting the key pillars of its corporate culture, including the update of

the Code of Conduct and Ethics, and the introduction of the revamped Purpose and Values (the “Alpha Way” initiative). Specific metrics and

targets will be disclosed in 2025, once these initiatives have been fully operationalized.

Code of Conduct and Ethics

The Code of Conduct and Ethics outlines the principles that Alpha Services and Holdings Group stands for, aiming to provide Personnel with

ample guidance on conducting business in an ethical manner. The Code applies to all persons linked with Alpha Services and Holdings, Alpha

Bank and its Subsidiaries through an employment contract and Board Members as well as individuals or legal entities connected to the Group

or Group companies through a formal agreement e.g., contractors, consultants etc.

In 2024, the Code of Conduct and Ethics was updated and enhanced to include a comprehensive description of the Group’s policies, to set out

clear expectations regarding ethical behavior, a strong risk management culture, and compliance with the applicable regulatory and legislative

framework. More information may be found in [S1-1] Policies related to own workforce regarding the policy update.

The respective training program is mandatory for all Personnel of the Bank, while the BoD took part in a presentation of the updated policy.

Worth mentioning that in 2024, the new Code of Conduct and Ethics was transposed into a theatrical play offering to the Bank Employees in

Greece an immersive learning experience on the Code’s key messages.

The Compliance Function, in conjunction with other Divisions of the Bank, is responsible for managing the risk of non-compliance with the applicable

regulatory framework, in its role as a second line of defense and as part of the Internal Control System. In particular, it identifies, assesses and manages the

risk to which the Bank may become exposed in connection with the applicable regulatory framework.

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The Group conducts internal audits to monitor compliance with the regulatory framework and has put in place specialized control and

reporting systems, working closely with the competent Regulatory Authorities to combat money laundering and financial crime.

In order to ensure compliance with the Policies, the Compliance Function conducts periodic monitoring and control exercises, enabling the

Bank to identify business conduct irregularities and breaches. Depending on the severity of the incidents identified through this periodic

monitoring and control, the Audit Committee will be informed.

Regarding the at-risk functions, these are considered to be these functions that interact directly with Customers, both natural persons and

legal entities; those that operate as part of the Alpha Bank Branch Network fall mostly under this category.

[G1-3] Prevention and detection of corruption and bribery

Whistleblowing Framework

A robust Whistleblowing Framework has been in place for several years, enabling Employees, Customers and Suppliers, or other stakeholders

who become aware of serious irregularities, omissions or offences, to report them in a reliable and confidential manner. The Whistleblowing

Framework is the main monitoring and reporting mechanism available to both internal and external stakeholders to report potential incidents

and allegations as those relate to the entirety of the Policies described herein (i.e. the Policy on the Prevention of Conflicts of Interest, the

Code of Conduct and Ethics, Anti-money Laundering, Counter-Terrorist Financing, and the Anti-Bribery and Corruption Policy). The Bank has

set reporting channels which are available and easily accessible to all Personnel, Customers, Suppliers and other stakeholders. Reports can

either be submitted via phone, or via a dedicated e-mail or by post, directly to the Chief of Compliance. The reports can be submitted on an

anonymous or eponymous basis. In all cases, the identity and anonymity of the whistleblower is protected. All reports are submitted to the

Whistleblowing Committee, and, upon request of the Whistleblower, the report may also be discussed, by means of a physical meeting, with a

member and the secretary of the Committee. The Members of the Committee are the Chief of Compliance, Internal Audit, Legal and HR – as

such, separate from the chain of management involved in the specific matter. When a report is submitted to the Whistleblowing Committee, a

series of actions are undertaken to ensure it is treated appropriately. For one, the Whistleblowing Committee carefully examines the report’s

content to determine the existence of irregularities, omissions or offenses. In the case where those are present, the Committee will then refer

the report for further investigation to the Internal Audit Business Area or for any further necessary actions to the competent Unit(s) of the

Group Alpha Bank S.A., if required. Once these procedures are complete, the findings are referred back to the Whistleblowing Committee

which will determine whether the issue has been resolved satisfactorily and if there is need for further investigation and referral of identified

violations to the Management of the Bank.

The Chair of the Committee submits, on a quarterly basis, an activity report, to inform the Audit Committee of the reports received and

handled during the reported period and is always informed of any significant events on a timely basis.

The Whistleblowing Policy is accessible for all Personnel through the intranet section and to Customers, Third Parties and external

stakeholders through Alpha Bank’s website. 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.

To date, there have been no confirmed convictions or fines for violation of anti-corruption or anti-bribery laws.

Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT)

The AML/CFT Business Area of the Compliance Function develops and implements the evaluation framework with regard to money laundering

and financing of terrorism risk (ML/FT) in terms of the Company.

It introduces, updates and implements appropriate policies and procedures, related to the ML/FT risks, and monitors if the measures, controls

and procedures in place are in accordance with the Bank’s requirements for the prevention of ML/FT. It has the responsibility for the design

and management of the transactions monitoring system, including scenarios related to the ML/FT risks.

In 2024, the Bank updated the AML/CFT Policy, taking into account the applicable AML/CFT regulatory framework, including EBA Guidelines,

the FATF Recommendations and its Compliance Risk Appetite Statement. The policy has been approved by the BoD and reviewed annually, or

earlier if necessary. It applies at a Group level by laying down specialized procedures and installing appropriate IT systems.

Key elements of the AML/CFT policy are:

• The ML/TF risk assessment which includes identification of ML/TF risk factors and ML/TF Risk assessment taking into account the

level of inherent risk as well as factors of risk mitigation.

• The implementation of Customer Due Diligence measures, including the identification and verification of the Customer's identity,

and the identity of the beneficial owner, the creation of a financial/transactional profile and the scrutiny of all transactions or

activities, and continuous monitoring.

• The Customer’s periodic review with respect to ML/TF risk.

• The reporting of the suspicious/unusual transactions when necessary.

• The compliance with sanctions and restrictive measures against countries, persons or entities.

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Regarding the roles and responsibilities in the AML/CFT framework, the Audit Committee is responsible for ensuring compliance with

applicable requirements in the context of the prevention of ML/TF. The BoD implements the appropriate and effective organizational and

operational structure necessary to comply with the AML/CFT strategy, ensures implementation of internal AML/CFT policies and procedures,

reviews the AML/CFT Compliance Officer’s activity report and ensures AML/CFT reporting to the competent authority. Τhe Group Chief of

Compliance is responsible for ensuring that the Group's obligations regarding the prevention of the use of the Financial System for ML/TF

purposes, are met.

The AML Objectives for 2024 focused on the implementation of advanced technology, and optimization of AML and Embargo / Sanctions alert

screening. In parallel, great effort was attributed to reorganizing STRs’ handling in a more efficient manner. The Customers’ periodic

assessment Unit amplified the procedures against non-responsive Customers though the implementation of a robust Consequence

Management. The Transactional Monitoring Unit succeeded both prompt and quality alerts investigation.

AML/CFT Training

The Bank and each Group Company provides training programs, including web training programs, to its Employees, while training is delivered

to the AML/CFT-related Units personnel, as well as of the AML/CFT Compliance Officer and their deputy.

The training programs that are provided to the Employees of the Group Companies include:

• Briefing Officers on the legislation and their obligations arising from the applicable provisions and the procedures adopted by the

Bank or the Group company, including those relating to issues such as the identification and verification of the Customers’ identities,

keeping records and internal reporting.

• The appropriate adjustment of the implementation time, duration and content of training programs, depending on the category and

job of Personnel.

• The repetition, at regular intervals, of training programs in order to ensure the knowledge of Personnel regarding their duties and

obligations and their update on all new developments.

The AML/CFT Compliance Officer is responsible for the design and implementation of Anti-Money laundering and terrorist financing training of

Employees.

More specifically, 2,785 Alpha Bank Employees and 85 Employees from subsidiaries based in Greece attended the mandatory 2 hours “AML

awareness” e-learning.

Anti-bribery and Corruption Policy

As per previous mention, Alpha Bank has developed an Anti-bribery and Corruption Policy which applies to the entire Group. The Policy is

addressed to the Members of the BoD and of the Group Companies (including those of Special Purpose Vehicles), to Chief Executive

Committee Members, Directors, Employees of the Group Alpha Bank S.A., and other stakeholders such as suppliers of goods and/or services

that transact with the Group Alpha Bank S.A., Public and Government Officials, Advisers, and Customers. The Policy is easily accessible to all

internal and external stakeholders through the Alpha Bank S.A.’s website.

Services, hospitality, entertainment and other types of offers are considered as gifts and are not acceptable, according to the Policy.

Exceptionally, gifts of small value may be accepted, to the extent that they are offered within the context of social occasions and traditions.

The Compliance Function monitors all gifts and, upon assessment, provides guidance to the recipient for the acceptance, decline or

appropriate disposal of the gift.

When recruiting new Employees, Alpha Bank takes into account any existing business, financial and other interests in accordance with the

provisions of the Policy on the Prevention of Conflict of Interests. They are also required to participate in trainings regarding the respective

Policy, as well as the Code of Conduct and Ethics. When selecting and subsequently collaborating with Third Parties (e.g. providers,

consultants, suppliers, etc.), Alpha Bank takes all necessary measures to ensure that any new business relationship is based on the principles of

business ethics.

Physical trainings, trainings via Teams, and e-learning programs are provided to all existing Personnel, irrespective of their hierarchical level.

The Group has established dedicated reporting channels such as a direct telephone line, dedicated e-mail and postal address to which

breaches of Anti-Bribery and Anti-Corruption Policy provisions can be addressed, which refer to instances to address allegations or incidents

corruption and bribery. The aforementioned channels operate exclusively for receiving reports and are available 24 hours a day/seven days a

week for all Personnel, Customers and Third Parties.

The Policy is accessible for all Personnel through the intranet section and for Customers, providers, third parties etc., on Alpha Bank’s website.

In 2024, dedicated trainings were conducted by the Compliance Function to the Branch network, covering ethics and including anti-corruption

and anti-bribery training programs.

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Various topics were covered such as defining bribery and corruption, the provisions of Alpha Bank Group’s Policy and the obligations arise for

Group Personnel, issues regarding gifts and hospitality, interaction with public officials, channels for reporting irregularities and breaches of

the Policy as well as the Group’s corporate culture towards bribery and corruption. Additional training (e-learning) is currently being designed,

covering the Policy.

Policy on the Prevention of Conflicts of Interests

The Policy on the Prevention of Conflict of Interests applies to the Group Companies in Greece and abroad, notwithstanding ad-hoc policies

applying to one or more Group companies as a result of additional requirements imposed by the relevant national regulatory framework.

In particular, the Policy aims to:

- Prevent cases of conflict of interests, which may prove detrimental to the interests of Customers or potential Customers when providing

banking and/or investment services.

- Enforce procedures to manage cases of conflict of interests, which may include organizational and administrative measures for handling

such cases and safeguarding Customers’ interests.

- Establish control mechanisms, which allow an overall assessment of the efficiency of the conflict of interests’ prevention framework as

well as of the Bank’s level of adherence to the respective framework.

The Policy covers conflict of interests’ cases, either potential or confirmed. The Bank’s Employees may seek advice from the Compliance

Division, in terms of assessing a potential conflict of interests’ case, as well as providing instructions on the appropriate remediation measures.

It was reviewed in 2023 and updated to include further specifics on procedures for transparency and internal disclosure of relevant incidents

or circumstances. During the reporting year, the Bank did not finance any political party or person and was not charged with any significant

fines or nonfinancial penalties for non-compliance with the legal and regulatory framework in economic, labor, urban planning, social or other

issues.

The policy adheres to the requirements of the regulatory framework, as stipulated among others in the relevant Law on sociétés anonymes, on

Corporate Governance Law, MiFID II, the Bank of Greece (BoG) Governor’s Act 2577/9.3.2006 “Framework of operational principles and

criteria for the evaluation of the organization and Internal Control Systems of credit and financial institutions and relevant powers of their

management bodies”, the EBA Guidelines on Internal Governance (EBA – GL 2017- 11), as well as the Group’s Code of Conduct.

Conflict of Interests Training

To effectively manage cases of Conflict of Interests, the Compliance Division performs regular training to the Bank Employees. The training

aims to enhance awareness of all the risks that may arise from potential Conflict of Interests situations, as well as to ensure comprehension of

responsibilities attached to Employees

Policy on Related Parties Transactions

The Policy covers a set of principles and internal procedures aimed at mitigating the “conflict of Interest” risk, in cases where the “personal or

private interests” of the “Related Parties” may be in conflict with the interests of the Bank.

This Policy applies to the entire Group. For Banks and Branches headquartered abroad, the stipulations of this Policy may be adjusted

accordingly, in cases where the local regulatory and legal provisions prevail over the requirements of this Policy. Such differences must be

communicated to the Bank’s Compliance Division. Group Companies may respectively adjust the limits of the transactions under examination,

based on their size and on the type of their activities, after submitting a relevant proposal to the Bank’s Compliance Division and obtaining the

necessary approvals. At the time of reporting, the Policy undergoes update which will be completed within 2025.

[G1-4] Incidents of corruption and bribery

The Bank has not faced any convictions or fines for violation of anti-corruption and anti-bribery laws. There are no confirmed incidents in

which own employees were dismissed or disciplined for corruption or bribery-related incidents, or cases emanating from relations with

business partners or relevant public legal cases against the Group or related fines.

Scope of trainings on anti-bribery and corruption

A key component of the implementation of the aforementioned Policies is the undertaking of dedicated trainings, as described previously

under each aforementioned policy.

In terms of the overall scope of trainings for the Alpha Services and Holdings Group, the total number of Employees participating during the

reporting year was 1,187, of which:

- 225 Employees belonged to at-risk functions, which represent 88% of the total Employees in at-risk functions

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- 49 were managers

- 40 were part of the administrative, management and supervisory bodies

- 873 were other own Employees

In terms of the method of delivery of these trainings, 4 hours were conducted in class and 6 hours were computer-based. There were 12

trainings in total.

In terms of topics covered during these trainings, they included definitions of corruption, the policy, and procedures on suspicion and

detection. It is noted that 100% of Employees of Alpha Services and Holdings Group have received training regarding AML. In terms of topics

covered during these trainings, they included definitions of corruption, the policy, and procedures on suspicion and detection.

Appendix

TABLE 68 ESRS 2 GENERAL - INDEX TABLE (INDICATIVE)

Disclosure Requirement and related datapoint

GENERAL INFORMATION

[BP-1] General basis for preparation of sustainability statements

[BP-2] Disclosures in relation to specific circumstances

[GOV-1] The role of the administrative, management and supervisory bodies

[GOV-2] Information provided to, and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies

[GOV-3] Integration of sustainability-related performance in incentive schemes

[GOV-4] Statement on due diligence

[GOV-5] Risk management and internal controls over sustainability reporting

[SBM-1] Strategy, business model and value chain

[SBM-2] Interests and views of stakeholders

[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

[IRO-1] Description of the process to identify and assess material impacts, risks and opportunities

[IRO-2] Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement

ENVIRONMENTAL INFORMATION

Disclosures pursuant to Article 8 of Regulation 2020/852 (“EU Taxonomy Regulation”)

ESRS E1 CLIMATE CHANGE

[E1-1] Transition plan for climate change mitigation

[E1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

[E1-2] Policies related to climate change mitigation and adaptation

[E1-3] Actions and resources in relation to climate change policies

[E1-4] Targets related to climate change mitigation and adaptation

[E1-5] Energy consumption and mix

[E1-6] Gross Scopes 1, 2, 3 and Total GHG emissions

[E1-7] GHG removals and GHG mitigation projects financed through carbon credits- N/A

[E1-8] Internal carbon pricing- N/A

[E1-9] Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

ESRS E4 BIODIVERSITY AND ECOSYSTEMS

[E4.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

[E4-1] Transition plan and consideration of biodiversity and ecosystems in strategy and business model

[E4-2] Policies related to biodiversity and ecosystems

[E4-3] Actions and resources related to biodiversity and ecosystems

[E4-4] Targets related to biodiversity and ecosystems

[E4-5] Impact metrics related to biodiversity and ecosystems change- N/A

[E4-6] Anticipated financial effects from biodiversity and ecosystem-related risks and opportunities

ESRS E5- RESOURCE USE AND CIRCULAR ECONOMY

[E5-1] Policies related to resource use and circular economy

[E5-2] Actions and resources related to resource use and circular economy

[E5-3] Targets related to resource use and circular economy

[E5-4] Resource inflows- N/A

[E5-5] Resource outflows- N/A

[E5-6] Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

ESRS S1 OWN OPERATIONS

[S1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

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[S1-1] Policies related to own workforce

[S1-2] Processes for engaging with own workforce and workers’ representatives about impacts

[S1-3] Processes to remediate negative impacts and channels for own workforce to raise concerns

[S1-4] Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own

workforce, and effectiveness of those actions

[S1-5] Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

[S1-6] Characteristics of the undertaking’s Employees

[S1-7] Characteristics of non-Employees in the undertaking’s own workforce- N/A

[S1-8] Collective bargaining coverage and social dialogue

[S1-9] Diversity metrics

[S1-10] Adequate wages- N/A

[S1-11] Social protection

[S1-12] Persons with disabilities- N/A

[S1-13] Training and skills development metrics

[S1-14] Health and safety metrics- N/A

[S1-15] Work-life balance metrics- N/A

[S1-16] Remuneration metrics (pay gap and total remuneration)- N/A

[S1-17] Incidents, complaints and severe human rights impacts

ESRS S4 CONSUMERS AND END USERS

[S4.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

[S4-1] Policies related to consumers and end-users

[S4-2] Processes for engaging with consumers and end-users about impacts

[S4-3] Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

[S4-4] Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities

related to consumers and end-users, and effectiveness of those actions

[S4-5] Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Entity-Specific Information

CONTRIBUTION TO HEALTHY ECONOMIES

[G1-1] Business conduct policies and corporate culture

[G1-2] Management of relationships with suppliers- N/A

[G1-3] Prevention and detection of corruption and bribery

[G1-4] Incidents of corruption or bribery

[G1-5] Political influence and lobbying activities- N/A

[G1-6] Payment practices- N/A

List of Abbreviations

AML/CFT: Anti-Money Laundering and Combating the Financing of Terrorism

BoD: Board of Directors

C&E: Climate and Environment

CGSNC: The Corporate Governance, Sustainability and Nominations Committee

CSR: Corporate Social Responsibility

CSRD: Corporate Sustainability Reporting Directive

DE&I: Diversity, Equity and Inclusion

DMA: Double Materiality Analysis

EBA: European Banking Authority

ESRS: European Reporting Sustainability Standards

GRI: Global Reporting Initiative

IEA: International Energy Agency

NGO: Non-Governmental Organization

NZBA: Net Zero Banking Alliance

PCAF: Partnership for Carbon Accounting Financials

RAF: Risk Appetite Framework

RCSA: Risk and Control Self-Assessment

SASB: Sustainability Accounting Standards Board

SFF: Sustainable Finance Framework

TCFD: Task Force on Climate-related Financial Disclosures

UNEP FI: United Nations Environment Program Finance Initiative

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Corporate Governance Statement

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 2024. The reference date of the Corporate

Governance Statement is 31.12.2024.

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.

CORPORATE GOVERNANCE CODE AND PRACTICES

Our 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”).

Our 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 our Company and the Group with the 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.

Laws

Statement of

Compliance with the

Corporate

Governance Code

B. 1

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Our Company fully complies with the Hellenic Corporate Governance Code, without any exception.

Starting from 1.1.2025, the Chair of the Board of Directors is an Independent Non-Executive Member.

It is noted however that until 31.12.2024, our Company deviated from the provision regarding the election of a Vice-

Chair or Senior Independent Director as outlined in paragraph 2.2.21 “Special Practice” of the Code. During this period,

the Chair of the Board of Directors was appointed from among the Non-Executive Members to coordinate Independent

and Non-Executive Members’ meetings and the responsibilities of the Senior Independent Member were covered by

the Chair of the Board of Directors and the Chair of the CGSNC.

During 2024, our Company revised the Charters of the Board of Directors and its Committees, which include the Audit

Committee, the Risk Management Committee, the Remuneration Committee and the Corporate Governance,

Sustainability and Nominations Committee. Additionally, we have updated the Articles of Incorporation.

Moreover, Policies related to corporate governance have been meticulously reviewed and updated to ensure full

alignment with the current regulatory framework and the most recent best practices of corporate governance. These

Policies include the Suitability and Nomination Policy for the Members of the Board of Directors, the Suitability and

Nomination Process for the Members of the Board of Directors, the Induction and Training Policy and Procedure for the

Members of the Board of Directors, 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, and the

Remuneration Policy for Alpha Services and Holdings and its Group along with its Annexes. Additionally, we have

revised the Policy for the Evaluation of Senior Executives and Key Function Holders.

Furthermore, our Company has also revised the Expenses Policy for the Non-Executive Members of the Board of

Directors. This Policy was approved by the Board of Directors during the meeting held in January 2025.

Throughout 2024, the Board Committees of our Company met with the Board Committees of the Subsidiaries. This

collaboration was pivotal as we reviewed the Annual and Semi-Annual Activity Reports of the Subsidiaries’ Boards of

Directors and Committees, ensuring that their responsibilities were being fulfilled effectively. In addition to these

reviews, we also embarked on important discussions about the Board structure and practices on corporate governance.

These discussions were crucial in maintaining and improving our governance standards.

Explanation on

issues of non-

compliance with the

Hellenic Corporate

Governance Code in

the context of the

“comply or explain”

principle

B. 2

Update of Corporate

Governance

Documents during

2024

B. 3

Corporate

Governance at

Group Level

B. 4

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Appointment of a new Chair of the Board of Directors

The Board of Directors at its meeting of 31.12.2024 and following the resolution dated December 12, 2024, the Board

has appointed Mr. D.C. Tsitsiragos, Independent Non-Executive Member, as the new Chair of the Board of Directors,

effective as of January 1, 2025. The fit and proper assessment process for this appointment was successfully completed

with the Single Supervisory Mechanism (SSM) of the European Central Bank (ECB), prior to the Board’s decision, in

accordance with all applicable laws and regulations.

It is noted that the departing Chair Mr. V.T. Rapanos served as Chair of the Board of Directors since May 2014. Mr

Rapanos contributed significantly to safeguarding and steering the Company’s long-term strategy, engaged with the

Company’s Stakeholders to promote the Company’s interests and contributed decisively to the establishment of best

corporate governance practices in the Company. He has also served as Chair of the Board of Directors of the Hellenic

Bank Association, reinforcing its crucial role and function.

The process to identify suitable candidates to replace Mr. V.T. Rapanos as a Board Member has already commenced,

based on recommendations by the Corporate Governance, Sustainability and Nominations Committee.

Commencement of the process for the merger between Alpha Services and Holdings S.A. and Alpha Bank S.A.

The Company, 100% parent of Alpha Bank S.A., announced that its Board of Directors held on 12.12.2024 approved the

initiation of the merger process, by way of which Alpha Bank S.A. shall proceed with a merger by absorption (in Greek:

«Συγχώνευση με απορρόφηση») of the Company (hereinafter the “Merger”) pursuant to applicable Greek Law,

including, without limitation, Greek Law 4601/2019 on corporate transformations and article 16 of Law 2515/1997 on

banking transformations, as in force (hereinafter the “Greek Transformation Law”).

As per the provisions of the Greek Transformation Law, subject to all necessary regulatory and corporate approvals and

consents, the Merger will result into Alpha Bank, which will retain its license as a credit institution, succeeding by force

of law and by way of a universal succession the Company in any and all of its assets and liabilities. Prior to the Merger

completion, the shares of Alpha Bank, the surviving entity of the Merger, will be admitted to listing on the Athens

Exchange and its shares will be delivered upon Merger completion to the Shareholders of the Company in exchange for

their shares in the Company. It is noted that, completion of the Merger is subject to obtaining all necessary regulatory

approvals and consents, including those by the Prudential Regulator and the Ministry of Development, as well as to all

applicable corporate authorizations and approvals, including those by the General Meeting of Shareholders of both the

Company and Alpha Bank.

2024 Highlights

B. 5

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As we look ahead to 2025, some of the key Corporate Governance priorities that we will be focusing on are shared

below. These priorities will guide our efforts to enhance our governance practices and ensure we remain aligned with

the latest regulatory developments.

First and foremost, we will be working to further

enhance the diversification within our Board of

Directors and the Management team. This will

further strengthen the variety of perspectives and

experiences, which is crucial for our growth and

success.

We will also be reviewing our Company’s Corporate

Governance documents to ensure they reflect the

latest regulatory changes and developments. This

will help us maintain compliance and stay ahead of

any potential challenges.

Another important priority is to provide further

specialized training to the Members of the Board of

Directors. This ensure they remain equipped with

the necessary skills and knowledge to make

informed decisions and lead our Company

effectively.

We will be closely monitoring the adoption of corporate governance practices by our Subsidiaries to ensure

consistency and alignment across the Organization. Additionally, we will be approving new policies in line with the

latest developments in the field of corporate governance.

Additionally, we are committed to sustained transparency regarding our overall strategy, board composition and

effectiveness, remuneration practices, and sustainability initiatives. We will maintain a continued emphasis on board

and executive succession planning and continue to monitor the implementation of the Succession Policy. This will

ensure that we have a robust plan in place for leadership continuity.

We will also continue to enhance our Remuneration Framework aiming to attract and retain highly-skilled executives,

ensure that remuneration practices are aligned with our performance goals and international best practices.

Customer focus remains central to our approach. Our Company is dedicated to deepening its customer relationships by

addressing their diverse expectations and expanding its offerings through strategic partnerships. We will continue to

actively seek and listen to customer feedback, analyze their preferences and needs and integrate their insights into our

product development and service improvements. By doing so, we aim to enhance customer satisfaction, build stronger

relationships, and ensure that our offerings consistently meet or exceed their expectations. Our Company will remain

competitive and innovative in the market by promoting transparency and engagement. .

Lastly, we will continue active engagement with our shareholders and investors through roadshows focused on several

key areas: Strategic Overview, Corporate Governance (including Board Structure, Board Effectiveness, and

Remuneration), and Sustainability, aiming to incorporate their feedback into our practices and ensure our practices

meet their expectations.

2025 Priorities

B. 6

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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’ Model: the business and operational or support Units (first line); the Risk

Management and Compliance Units (second line) and the Internal Audit Unit (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 activities 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 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 in the field of

internal control and 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 person

or Units and on the approval of certain activities by at least two people.

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 accuracy of the entries in the accounting books as well as the completeness and validity of

the Financial Statements.

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The purpose of the Internal Audit Unit 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 Unit 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 Unit 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 Unit 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 Unit.

The Head of 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 Unit. The performance of the Head of 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 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 Head of Internal Audit attends General Meetings of Shareholders.

The Board of Directors authorizes and the Audit Committee supports the Internal Audit Unit 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 Unit’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 are independent of the auditees and

Management and must be objective during the execution of their work. They 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 Internal Audit confirms to the Board of Directors and to the Audit

Committee, at least annually, the organizational independence of the Internal Audit Unit.

Internal Audit Unit

C.1

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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 of the Company.

The Head of 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.

− Ensure the completeness of the Audit Universe at Group level.

− Coordinate accordingly with the Heads of Internal Audits of significant subsidiaries in order to ensure

appropriate and complete communication to the Audit Committee regarding Internal Audit plan,

Internal Audit activity and results, and implementation of the Internal Audit Charter at Group level.

− 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.

− 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.

− Inform, in writing at least quarterly, the Board of Directors, through the Audit Committee, and General

Management about the significant audit findings and recommendations, progress on their

implementation, and the extent to which the Internal Control System meets its objectives

− 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 Unit 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 Unit 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,

if any, on the Internal Audit Plan.

− Ensure that emerging trends and successful practices in internal auditing are considered and are

included in the IPPF.

− Establish and ensure adherence to policies and procedures designed to guide the Internal Audit Unit.

− 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 the Board and the Audit Committee

− Ensure conformance of the Internal Audit Unit with the Global Internal Audit Standards (standards),

with the following qualifications:

Internal Audit Unit

C.1

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a. If the Internal Audit Unit is prohibited by law or regulation from conformance with certain parts

of the standards, the Head of 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 Internal Audit will ensure that the Internal Audit Unit conforms with the

standards, even if it also conforms with the more restrictive requirements set by other

Supervisory Authorities and local laws and regulations.

− Report periodically and be directly accountable to the Audit Committee and the Board of Directors, as

to the evaluation of the overall effectiveness and efficiency of the Company’s and the Group’s Internal

Control System. In particular, the Internal Audit Unit assesses:

a. the appropriateness of the Company’s governance framework;

b. whether existing policies and procedures remain adequate and comply with legal and regulatory

requirements and with the risk strategy and the risk appetite of the Company;

c. the compliance of the procedures with the applicable laws and regulations and with decisions of the

Board of Directors;

d. whether the procedures are correctly and effectively implemented (e.g. compliance of transactions,

the level of risk effectively incurred, etc.); and

e. the adequacy, quality and effectiveness of the controls performed and the reporting done by the 1st

line of defense Business Units and the Risk Management and Compliance Units (three lines of defense

model).

The Internal Audit Unit:

•

Verifies in particular, the integrity of the processes ensuring the reliability of the Bank’s methods and

techniques, and the assumptions and sources of information used in its internal models (e.g. risk modelling

and accounting measurements). It also evaluates the quality and use of qualitative risk identification and

assessment tools and the risk mitigation measures taken.

•

Examines, audits and assesses:

a. the adequacy and integrity of financial and other information, risk management, regulatory compliance

and the corporate charter in force; the implementation of the internal regulation and the system of internal

controls, in particular as regards the adequacy and integrity of the financial and non-financial information

provided, risk management, regulatory compliance and the corporate governance code adopted by the

Company;

b. the quality assurance mechanisms;

c. the corporate governance mechanisms and

d. use of capital raised through public offerings in accordance with information released to the public and

business plans.

•

Ensures that sufficient procedures are in place so that the reports from the audit engagements are

appropriately disseminated.

•

Attests to the Audit Committee and the Management of the Company annually, the organizational

independence of the Internal Audit Unit activity, or discloses the details of any impairment accordingly.

•

Ensures that the Internal Audit Unit complies with sound internal auditing standards and with the code of

conduct and ethics.

•

Upon decision or instruction from any Competent Authority, carries out specific audits in cases where there

are indications that the interests of the Company or its Subsidiaries are compromised.

•

Provides in writing to the Competent Authorities any information requested, collaborates with the

Competent Authorities and facilitates in any possible way their supervisory and control tasks.

Compliance Unit

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The Compliance Unit is responsible for the monitoring of the Compliance Risk at the level of the Company and the

Subsidiaries, as per the duties and responsibilities included in its Charter.

Being part of the Second Line of Defense, the Compliance Unit is responsible for identifying and assessing

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 policies and procedures.

In terms of governance, the Compliance Unit reports functionally through the Audit Committee to the Board of

Directors and administratively to the Chief of Corporate Center and General Counsel. 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 Unit to perform its

duties.

The Compliance Unit 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 Unit.

The Compliance Unit is responsible for:

• Representing the Company to Supervisory and other Authorities regarding compliance matters;

• 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;

• Monitoring the adherence to the Company’s applicable regulatory framework and the adoption of the

Group Policies by the Subsidiaries in order to facilitate a harmonized Compliance approach among them.

• Ensuring the continuous update of the Employees regarding the applicable regulatory framework,

through compliance-oriented training programs.

Compliance Unit

C.2

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The Compliance Unit 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 Units and Business Areas when

appropriate, to deal with compliance matters under a common approach.

The Chief 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 policies and procedures;

− supervising the Employees who performs tasks involving Compliance matters and ensuring their adequate

training and updated information on relevant developments;

− continuously monitoring trends, best practices, laws and regulations on Compliance matters;

− supervising the Subsidiaries’ Compliance units;

− reporting to the Board of Directors through the Audit Committee 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.

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. They are:

• 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.

Compliance Unit

C.2

Risk Management

Function

C.3

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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 risk adjusted

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 Model. The duties

and responsibilities of all lines are clearly defined and separated and the relevant roles are sufficiently

independent. The Risk Management Function is responsible for both supporting - this entails guiding in identifying,

analyzing, and monitoring risks associated with the tasks they undertake – as well as challenging the 1

Line

Business functional areas in implementing internal controls and processes.

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:

• 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. Moreover, 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.

Risk Management

Function

C.3

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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, taking into

consideration the applicable legal and regulatory framework, including articles 99-101 of Law 4548/2018.

Within this framework, the Company adopted the “Policy on Related Parties transactions”, which describes the

method with which the Company handles issues regarding transactions with Related Parties.

All set processes and procedures aim to ensure that the Related Parties transactions are concluded and disclosed

in accordance with the applicable legal and regulatory framework. The Compliance Division of each Subsidiary is

the responsible Unit to monitor the Related Parties transactions for conformity with the principles and process

applied.

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 the Internal Control System.

Parties

Transactions

Periodical

Assessment of

Internal Control

System

C.4

C.5

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ANNUAL FINANCIAL REPORT

SHAREHOLDERS

The General Meeting of Shareholders (the “General Meeting”) is the supreme governing body of our Company and

it plays a crucial role in resolving all corporate affairs in accordance with the applicable legislation. It is essential to

note that the resolutions passed during the General Meeting, when in accordance with the law, are binding upon

all Shareholders, including those who are absent or dissenting.

The General Meeting shall be convened by the Board of Directors or as otherwise stipulated by the applicable

legislation. The meeting shall take place at the Company’s registered office, or in the district of another

municipality within the prefecture of the registered office, or in a contiguous municipality to the registered office.

Alternatively, it may be held at the registered office of the Athens Exchange, where the Company’s shares are

listed for trading. Furthermore, following a resolution by the Board of Directors and in compliance with the

applicable legislation, the General Meeting may also be conducted via teleconference. This decision ensures that

all Shareholders have the opportunity to participate in the meeting, regardless of their physical location.

The General Meeting is held at least once during the fiscal year, no later than the tenth calendar day of the ninth

month following the end of the fiscal year (Ordinary General Meeting). Additionally, meetings may be convened

on an ad hoc basis as necessary.

The General Meeting will initially be presided over by the Chair of the Board of Directors. During this provisional

period, the Chair will appoint provisional secretaries and ballot collectors. This arrangement will continue until the

list of Shareholders with the right to participate in the General Meeting is ratified. Following this, the regular

Presidium, including the permanent Chair, secretaries, and ballot collectors, will be elected by the General

Meeting.

It should be noted that only those who hold Shareholder status on the record date, as defined by the legislative

framework, are entitled to participate in the General Meeting. It is crucial for Shareholders to timely and properly

comply with the provisions of the law and the relevant invitation to the General Meeting. Should there be any

deviations from these guidelines, participation in the General Meeting will only be permitted upon receiving

approval from the General Meeting itself.

Shareholders are welcome to attend the General Meeting either in person or by proxy. In the case of minors,

individuals under judicial guardianship and legal entities, representation must be in accordance with the applicable

legislation. The appointment, revocation, or replacement of representatives should be done in writing, through

either a private or a public document. Additionally, upon a resolution by the Board of Directors, this can also be

accomplished via electronic mail or other electronic means of communication, as detailed in the Invitation to the

General Meeting.

Moreover, upon a resolution by the Board of Directors it may be resolved that the Shareholders may participate in

the General Meeting through a Mail Vote, which can be submitted either by mail or electronically prior to the

meeting. This process will be conducted in accordance with the relevant legislation and the instructions provided

in the invitation.

It is important to note that the Members of the Board of Directors and the auditors of the Company are allowed to

attend the General Meeting. Additionally, other individuals who do not possess shareholder capacity may also be

allowed to attend, upon permission of the Chair of the General Meeting.

General Meeting of

Shareholders

D.1

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ANNUAL FINANCIAL REPORT

During 2024, one General Meeting of Shareholders was held.

out of a total of 2,348,874,407 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:

ITEM

AGENDA

% VALID

VOTES

Approval of the Annual Separate and Consolidated Financial Statements of the financial year 2023 (1.1.2023 -

31.12.2023), together with the relevant reports of the Board of Directors which are accompanied by the Statutory

Certified Auditors’ Report.

99.76%

Approval of dividend distribution of an amount of Euro 61,133,013 in cash from intragroup dividends reserves.

99.96%

a) Approval of the distribution of an amount of Euro 55,919 of the Company’s Intragroup dividends reserves to

Company’s Staff. Granting of authorization to the Board of Directors.

b) Distribution of an amount of up to Euro 12.6 million by Group Companies to their eligible Staff. Granting of

authorization to the Board of Directors.

99.05%

Approval of the overall management for the financial year 2023 (1.1.2023 - 31.12.2023) as per article 108 of law

4548/2018 and discharge of the Statutory Certified Auditors for the financial year 2023, in accordance with article

117(1)(c) of law 4548/2018.

98.85%

Appointment of Statutory Certified Auditors for the financial year 2024 (1.1.2024 - 31.12.2024) and approval of their

fee.

99.10%

Submission of the Activity Report of the Audit Committee for the year 2023, in accordance with article 44 of law

4449/2017 (non-voting item).

NON-

VOTING

ITEM

Submission of the Report of the Independent Non-Executive Members, according to article 9(5) of law 4706/2020

(non-voting item).

NON-

VOTING

ITEM

Deliberation and advisory vote on the Remuneration Report for the financial year 2023, in accordance with article

112 of law 4548/2018.

99.06%

Approval of the Members of the Board of Directors’ remuneration for the financial year 2023 (1.1.2023 -

31.12.2023).

99.06%

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 2024 (1.1.2024 - 31.12.2024).

99.05%

Approval, in accordance with article 86 of law 4261/2014, of an increase of the maximum ratio between the fixed

and variable components of remuneration for the Members of the Executive Committee.

99.03%

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.

99.06%

Approval of the updated and amended Suitability and Nomination Policy for the Members of the Board of Directors.

99.10%

Shareholders (in person or by proxy) 743

Common, registered, dematerialized shares with voting

rights

1,666,062,224

Voting share capital of the Company 70.93%

Ordinary General Meeting of Shareholders on 24.7.2024

Ordinary General Meeting Quorum

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ANNUAL FINANCIAL REPORT

ITEM

AGENDA

% VALID

VOTES

Amendment to the Company’s Share Buyback Program in accordance with article 49 of law 4548/2018 and

authorization to the Board of Directors for its implementation.

99.95%

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 2023 which fall under article

99 of law 4548/2018 (non-voting item).

NON-

VOTING

ITEM

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 Directors of the Company to participate

in the boards of directors or in the management of companies having purposes similar to those of the Company.

99.96%

The Resolutions adopted at the Ordinary General Meeting of Shareholders held on 24.7.2024 have been posted on the Company’s website

(https://www.alphaholdings.gr/en/Holdings/Investor-relations/General-meetings).

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ANNUAL FINANCIAL REPORT

In order to enhance the active participation of the Shareholders in the General Meetings and the genuine interest

in issues relating to its operation, our Company applies procedures of active communication with them and

establishes the appropriate conditions so that the policies and strategies adopted are based on a constructive

exchange of views.

To strengthen our relationships with proxy advisors and investors, particularly those focused on corporate

governance, we have been actively engaging to support their decision-making processes. Throughout the year, we

have conducted bilateral meetings with representatives of proxy advisors, analysts and investors to discuss

corporate governance and sustainability issues.

In 2024, we organized roadshows with investors and international proxy advisors, with the participation of the

Chairs of the Corporate Governance, Sustainability and Nominations Committee, the Remuneration Committee as

well as our Executives. During November and December 2024, 17 meetings with investors were held. Those

roadshows focused on several key areas: Strategic Overview, Corporate Governance (including Board Structure,

Board Effectiveness, and Remuneration), and Sustainability.

One aim with these initiatives is to increase awareness and understanding among key stakeholders regarding our

sustainability efforts. We are dedicated to engaging with stakeholders, maintaining an ongoing dialogue on

sustainability matters and strengthening our relationships with ESG-focused Shareholders. Furthermore, we aim

to demonstrate our progress and commitment to sustainable practices, collect valuable stakeholder feedback and

identify key concerns to shape our future strategies.

Additionally, our efforts to enhance relationships with stakeholders who prioritize corporate governance have

been fruitful. By providing them with the necessary information, we assist in their decision-making processes,

ultimately improving our corporate governance. These efforts also help facilitate voting recommendations on

governance matters in preparation for the upcoming General Meetings of Shareholders.

Our Company’s shareholder structure presents great diversity. On 31.12.2024 the Shareholders structure of the

Company was as follows:

Communication with

Shareholders,

Investor Roadshows

and Corporate

Governance

Meetings

D.2

Shareholders

structure

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ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG)

Commitment to Sustainability

The Company remains deeply committed to conducting its operations responsibly, fostering long-term sustainable value creation for its

Shareholders and other Stakeholders. This commitment encompasses economic, social and governance principles across the Company’s

activities in Greece and other countries of operation. Recognizing the critical role ESG plays in fostering sustainable growth, the Company has

undertaken significant initiatives to enhance its environmental stewardship, social responsibility, and governance practices.

The Bank’s governance framework emphasizes active engagement with Stakeholders to

understand their evolving expectations on ESG matters. Aligned with international guidelines,

relevant laws, and the Group’s policies, the Company’s Sustainability Strategy identifies four

primary Stakeholder groups:

(i) Investors (as well as investment analysts and advisors)

(ii) Customers

(iii) Employees and Society

(iv) Official and Regulatory Authorities

To address their expectations effectively, the Company actively engages and collaborates closely

with key Stakeholders and integrates its profitability goals with sustainability principles into its

corporate strategy and operations. It invests in its workforce, infrastructure, and network to

deliver high-quality, sustainable products and services to the market.

The Company’s Sustainability Strategy is anchored in three core commitments:

• Support an environmentally sustainable economy.

• Foster healthy economic and societal progress.

• Ensure robust and transparent governance.

These commitments are underpinned by measurable targets and Key Performance Indicators (KPIs) which are presented in the annual

Sustainability Report of Alpha Services and Holdings S.A. and the Sustainability Statement included in the Annual Report 2024, please refer to

the 'SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model' section

Environmental Stewardship

Following Alpha Bank’s NetZero Banking Alliance (NZBA) commitment, in 2023, to achieve Net Zero greenhouse gas emissions by 2050, the

Company announced in 2024 the first set of sectors for which net-zero targets have been set, across the lending and investment portfolios. The

sectors include:

i. Power Generation

ii. Oil and Gas

iii. Cement

iv. Iron and Steel

6,924

81,266

1,084

10,726

Greek Institutional Investors Foreign Institutional Investors

Legal Retail Investors Individual Retail Investors

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At the same time, the Company strengthened its focus on environmental impact by fully operationalizing its Sustainable Finance Framework and

further embedding ESG criteria into decision-making and operations.

As a result, sustainable disbursements increased further in the Company’s portfolio, paving the way for ambitious goal setting for the period

2024-2026.

The Company also focused on reducing its own carbon footprint, investing in green building technologies and waste reduction initiatives that

resulted in reduced energy consumption across branches and business centres. These actions are being driven by a number of policies related

to climate change mitigation and adaptation as per the ‘E1- policies section’ in the Sustainability Statement.

Finally, to enhance awareness of ESG and climate risks, the Company continued to provide advanced capability training and support on

sustainable finance and the relevant tools available to Relationship Managers.

Social Responsibility

As part of its sustainable development strategy, the Company has adopted a Corporate Responsibility policy that aligns with internationally

recognized standards, such as the OECD Guidelines for Multinational Enterprises, the ILO Core Conventions, and the Universal Declaration of

Human Rights. In addition, there are several Group-wide policies in place related to own workforce and also policies that ensure that the needs

of consumers and end-users are addressed according to the Company’s Strategy, please refer to ‘policy sections of S1 and S4’ in the Sustainability

Statement. The Company also adheres to all relevant legal and regulatory requirements.

In 2024, the Company joined the United Nations Global Compact, thereby committing to align with the UNGC Ten Principles to uphold human

rights, labor standards, environmental protection, and anti-corruption efforts in all aspects of its operations.

Furthermore, the Company prioritizes Employee development and well-being by offering a healthy work environment where Employees can

enhance their skills and contribute to innovation. The Company’s Diversity, Equity and Inclusion (DEI) Strategy is a critical component of its

corporate culture and Sustainability Strategy, and several initiatives were designed and implemented, underpinning the DEI Strategy’s to

promote a diverse and inclusive work environment where all Employees feel valued and respected.

Community engagement remains a cornerstone of the Company’s social impact. Notable programs include supporting disaster-affected regions

and collaborating with local and nationwide organizations to promote economic resilience and financial inclusion, support of circular economy,

as well as initiatives that enable accessibility to cultural life and heritage.

Robust Governance

The governance framework of the Company reflects its dedication to sound and transparent management practices.

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 2024, the Corporate Governance, Sustainability and Nominations Committee met 14 times.

At the Executive Management level, the Group Sustainability Committee 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 five C-level senior leaders as permanent members and C-level Executives, Members of the Executive-

Committee, as well as Executives of the Bank or Group Companies or external partners, may also be invited to participate in the Committee’s

meetings. The Group Sustainability Committee met nine times during 2024 to review progress on key initiatives related to sustainability and

regulatory compliance thereof. Members discussed, among others, the progress in ESG integration via the operationalization of the Company’s

Sustainability Strategy and approved projects related to the Sustainable Finance business onboarding and science-based climate target setting,

as well as the corresponding action plan to meet the supervisory expectations. Updates and approvals were also provided on the Company’s

preparedness for meeting disclosure requirements under applicable regulations. The Members of the Committee were also informed about the

results of assessments, scenario analyses and strategic initiatives to address climate-related risks and opportunities, such as the sustainable

loans stock-take results and the financed emissions measurement.

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 Business Area 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 adhere to best banking and business practices, guided by the principles of integrity, honesty,

impartiality and independence, confidentiality and discretion, outlined in the Company’s Code of Conduct and Ethics and in the principles of

Corporate Governance, please refer to the policies section of ‘G1-1 for more policies pertaining the business conduct and corporate culture.’

Special emphasis is placed on the identification, measurement and management of risks undertaken, compliance with the prevailing legal and

regulatory framework, and on ensuring transparency through the provision of complete, accurate, and truthful information to the Company’s

Stakeholders.

Sustainability Statement preparation

The Sustainability Statement which is included in the Annual Report 2024 has been prepared in accordance with the Corporate Sustainability

Reporting Directive and the respective Greek Law 5164/2024. In addition, for its compilation, reporting data stemming from other legislative

requirements have been utilised, including the Regulation (EU) 2020/852 (the Taxonomy Regulation);

Regulation (EU) No 575/2013 of the

European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firm (“CRR”),

specifically information relating to Pillar III reporting requirements; Regulation (EU) 2021/1119 of the European Parliament and of the Council

of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999,

as transposed in the Greek National Climate Law (Law 4936/2022). Furthermore, the widely accepted sustainability reporting standards part of

the Global Reporting Initiative (GRI 2021) and the Sustainability Accounting Standards Board (SASB) have been leveraged (please refer to the

Section 'Sustainability reporting resulting from other legislation and standards' within the Sustainability Statement of the Annual Report 2024).

Future Outlook

The Company’s governance structure is designed to remain adaptive to emerging regulatory standards and best practices in ESG integration.

Looking ahead, the Company aims to scale up its Sustainable Finance Strategy and deepen its integration within its business and operating model.

It will continue to innovate and invest in sustainable products and services, strengthen stakeholder engagement, and provide transparent

reporting on its sustainability initiatives and progress.

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BOARD OF DIRECTORS AND COMMITTEES

The Board of Directors (the “Board”) is responsible for the management of our Company’s affairs and its

representation vis-à-vis third parties. It bears the ultimate responsibility for our Company and ensure effective and

prudent management. Here is a breakdown of some key responsibilities:

a. It 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. It ensure the integrity of our accounting and financial reporting systems, including financial and operational

controls and compliance with the law and relevant standards.

c. It oversees the process of disclosure and communications.

d. It is responsible for providing effective oversight of the Senior Management.

The Board consists of no fewer than nine and no more than fifteen Members, with odd numbers being the norm.

An even number of Members can be accepted temporarily for a justified reason. The Board includes Executive and

Non-Executive Members, in accordance with the provisions of the applicable legislation. It should be noted that a

legal entity may also participate in the Board as a Member, pursuant to article 77 par. 4 of Law 4548/2018.

Additionally, Independent Non-Executive Members make up not less than 50% of the total number of Members.

The tenure of the Members of the Board is quadrennial. This tenure 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.

Board of Directors

F.1

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Our Board of Directors meets whenever required to properly discharge its responsibilities. At the beginning of

each calendar year, we adopt a calendar and a work plan, which may be reviewed and adjusted as needed

throughout the year.

Meetings are convened either by the Chair of the Board of Directors or at the request of at least two Members.

We also accommodate meetings via videoconference or teleconference, providing, in such cases, the necessary

information and instructions for participation.

A quorum is achieved when at least half of the Members plus one are present or represented. There must always

be a minimum of six Members present, whether physically, by videoconference, or teleconference. For meetings

concerning the drafting of Financial Statements or requiring decisions by the General Meeting with special

quorum and majority as per Law 4548/2018, at least two Independent Non-Executive Members must be present.

Should an Independent Member be absent without justification from two consecutive meetings, they are

considered to have resigned, and the Board will proceed with their replacement.

Resolutions are passed by an absolute majority of the Members present or duly represented, unless otherwise

specified by our Articles of Incorporation or the law. If no unanimous decision is reached, the minority views are

recorded in the Minutes.

Lastly, the specific duties, responsibilities, principles, and the framework for the proper operation of the Board of

Directors are outlined in our Charter, which is available on the Company’s website.

(https://www.alphaholdings.gr/en/Holdings/esg-and-sustainability/advocating-sound-governance-

practices/management/board-of-directors).

Executive

Members

17%

Independent

Non-Executive

Members

58%

Non-Executive

Members

25%

Board of Directors Composition 2024

(Based on the composition of the Board of Directors on 31.12.2024)

Board of Directors

F.1

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During 2024, the following changes took place with regard to the composition of the Board of Directors and its

Committees:

During the Audit Committee meeting held on July 24, 2024, Mr. P.I.-K. Papazoglou, an Independent Non-Executive

Member, was appointed as Chair of the Audit Committee. He replaced Ms. C.G. Dittmeier, who continued to serve

as a Member of the Committee until September 30, 2024.

On September 26, 2024, Ms. C.G. Dittmeier, an Independent Non-Executive Member of the Board of Directors,

notified the Board of her resignation effective September 30, 2024. Consequently, the Board of Directors resolved

to fill the vacated position and initiated the search for a new Member.

Furthermore, during the Board of Directors meeting on December 31, 2024, following a resolution dated

December 12, 2024, Mr. D.C. Tsitsiragos, Independent Non-Executive Member of the Board, was appointed as the

new Chair of the Board of Directors, effective January 1, 2025, replacing Mr. V.T. Rapanos, following the respective

recommendation by the Corporate Governance, Sustainability, and Nominations Committee. It is noted that the fit

and proper assessment process for this appointment has been completed successfully with the Single Supervisory

Mechanism (SSM) of the European Central Bank (ECB).

Additionally, the Board has commenced the process of identifying suitable candidates for the appointment of a

new Board Member in replacement of Mr. V.T. Rapanos.

The Corporate Secretariat and Governance Policies Business Area supports the functionality of the Board of

Directors, its Committees, and its Members. This includes coordinating communications among the Members of

the Board, the Management, and the Subsidiaries to ensure the effective flow of information to and from the

Board.

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).

Dimitris C. Tsitsiragos

Independent Non-Executive Member

Chair of the Board of Directors since 1.1.2025

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

CVs of the Members

of the Board of

Directors

F.2

Board of Directors

F.1

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(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. He has been a Member of the Board of Directors since July 2020.

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.

Vasileios T. Rapanos

Non-Executive Member

Chair of the Board of Directors from May 2014 to 31.12.2024

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 Chair 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 currently 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.

CVs of the Members

of the Board of

Directors

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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 and contribution:

Vassilios E. Psaltis is the CEO and an Executive Member of the Board of Directors of Alpha Services and Holdings

and Alpha Bank. In his capacity as a Board Member since November 2018, and CEO since January 2019, he actively

contributes to implementing Alpha Bank’s strategic plan. In 2023 he promoted a multilevel milestone deal with

UniCredit. This strategic partnership has unlocked the profitability potential of Alpha Bank’s international

business, while creating upside potential for the rest of the Group.

With over 25 years of experience in the banking industry, he has been appointed to key positions at Alpha Bank

since 2007. Through these posts he has significantly reinforced the position of Alpha Bank. He spearheaded capital

raisings 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 system.

On top of his duties at Alpha Bank, he has also been serving as a Member of the Board of Directors and the

Executive Committee of the Hellenic Federation of Enterprises (SEV) since July 2021 and as a Member of the

Board of Directors of the Hellenic Bank Association (HBA) since October 2021. In 2019 he was appointed member

of the Institut International d' Études Bancaires (IIEB).

He holds a PhD and MA in Business and Banking from the University of St.Gallen, Switzerland.

Current and past appointments:

• CEO, Alpha Bank (2019 - today)

• General Manager, Alpha Bank (2012-2018)

• Group Chief Financial Officer (CFO), Alpha Bank (2010-2018)

• Senior Manager, Corporate Planning and Controlling, Alpha Bank (2007-2010)

• Deputy (acting) Chief Financial Officer, Emporiki Bank (2002-2006)Senior management positions,

ABN AMRO Bank’s Financial Institutions Group, London (1999-2001)

CVs of the Members

of the Board of

Directors

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Lazaros A. Papagaryfallou

Executive Member

Deputy CEO (since 23.7.2024)

Member of the Board of Directors since 27.2.2025

Nationality: Greek

Born in Athens, Greece, in 1971.

Experience: 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.

Other positions of note: On 2.1.2019 he was appointed Chief Financial Officer (CFO) for the Group. On

23.7.2024 he was appointed Deputy CEO.

Education: Business Administration at the Athens University of Economics and Business and holds an

MBA in Finance from the University of Wales, Cardiff Business School.

CVs of the Members

of the Board of

Directors

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Spyros N. Filaretos

Executive Member

Member of the Board of Directors since 2005 until 27.2.2025

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 Chief of Growth and Innovation.

Other positions of note: He is Member of the Executive Committee. 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.

Efthimios O. Vidalis

Non-Executive Member

Member of the Board of Directors from May 2014 until 27.2.2025

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). He is the founder of the SEV Business

Council for Sustainable Development and was the Chairman thereof from 2008 to 2016. Furthermore, he was

President of the Executive Committee of SEV from 2020 to 2024.

Other positions of note: 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

CVs of the Members

of the Board of

Directors

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Annalisa Areni

Non-Executive Member

Member of the Board of Directors since 27.2.2025

Nationality: Italian

Born in 1967.

Experience: She has more than 30 years of experience in the banking and financial sector.

Starting from 1994, she held progressive positions at Credito Italiano SpA, including the

role of Head of Personal Banking Segment in Lombardy Region (January 2000- September

2002). Since September 2002, she has been working at UniCredit SpA, where she has

held various management positions, including the positions of Market Manager – Milano

Cordusio (September 2002 – September 2008), Regional Co-Director – East Lombardy

(September 2008 – October 2010), Head of Customer Satisfaction – Lombardy Region

(November 2010 – December 2012), Area Manager – East Milan (January 2013 –

December 2015), Area Manager – Brescia and Province (January 2016 – December 2016),

Head of Retail – Lombardy Region (December 2016 – June 2019) and Regional Manager

of Southern Italy (June 2019 – September 2022)]. Furthermore, she was a member of the

Board of Directors of CNP Vita SpA (until June 2024).

Other positions of note: Since September 2022, she has been serving as Head of Client

Strategies (Italy) at UniCredit SpA and she has been a member of the National Council of

ABI.

Education: Degree in Business and Economics and a master’s degree in Banking and

Financial Communication from Università Cattolica del Sacro Cuore (Milan). Additionally,

she attended the Business Leaders for Transform and Lead Change Programme at IMD

Business School – International Institute for Management Development (Lausanne).

CVs of the Members

of the Board of

Directors

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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

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.

Elli M. Andriopoulou

Independent Non-Executive Member

Member of the Board of Directors since January 2022

Aspasia F. Palimeri

Independent Non-Executive Member

Member of the Board of Directors since July 2022

CVs of the Members

of the Board of

Directors

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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)

Membership of Board Committees: Chair of the Audit Committee and Member 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. He is also an

Independent Non-Executive Member of the Audit Committee (not a Board of Directors Member) of the Helleniq

Energy.

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).

Panagiotis I.-K. Papazoglou

Independent Non-Executive Member

Member of the Board of Directors since July 2023

CVs of the Members

of the Board of

Directors

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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

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

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).

Carolyn G. Dittmeier

Independent Non-Executive Member

Member of the Board of Directors from January 2017 to September 2024

CVs of the Members

of the Board of

Directors

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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.

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, also a member of the Human Capital and Compensation Committee as well as

Chair of the Corporate Governance, Nominating and Social Responsibility Committee. Since 2024 she has served as

an independent non-executive member of the Board of Directors of Euroclear SA/NV, is a member of the Audit

and Risk Committees, and since January 2025 chairs the newly-formed Technology Committee. Ms Hardwick is

also 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

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

Elanor R. Hardwick

Independent Non-Executive Member

Member of the Board of Directors since July 2020

Diony C. Lebot

Independent Non-Executive Member

Member of the Board of Directors since July 2023

CVs of the Members

of the Board of

Directors

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(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. Since 24.5.2023 until 31.3.2024 she was senior advisor

to the CEO of 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: She is 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, Pantheon-Sorbonne University, France, MSc in Finance and Taxation, University of

Paris, France.

Membership of Board Committees: Member of the Audit Committee, of the Remuneration Committee, of the

Corporate Governance, Sustainability and Nominations Committee. Member of the Risk Management Committee

until 6.3.2024

Nationality: Dutch Born in Vught, the Netherlands, in 1961.

Other positions of note: He has been an independent 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, Chair 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 Ltd.

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.

Johannes Herman Frederik G. Umbgrove

Non-Executive Member

Member of the Board of Directors since April 2018

CVs of the Members

of the Board of

Directors

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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. In August 2022, she was appointed Head of Corporate

Secretariat and Governance Policies (as of 1.1.2024 Corporate Secretariat and Governance Policies Director). In

December 2021, she was appointed Secretary of the Board of Directors.

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

Eirini E. Tzanakaki

Secretary of the Board of Directors since December 2021

Corporate Secretariat and Governance Policies Director

CVs of the Members

of the Board of

Directors

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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 31.12.2024)

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 Members

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.

Member of the Board of Directors of SEV - Stegi Ellinikis Viomihanias

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.]

Director of the Parel van Baarn Foundation

Member of the Management Committee of the Aston Martin Owners Club Ltd

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 Audit Committee (not BoD Member) of the Helleniq Energy

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

Elanor R. Hardwick

Member of the BoD of specialty (re)insurer Axis Capital, Member of the Human Capital and Compensation Committee as

well as Chair of the Corporate Governance, Nominating and Social Responsibility Committee

Member of the BoD of Euroclear SA/NV and Member of the Audit & Compliance Committee and Risk Committee

External member of the Audit Committee of the University of Cambridge

Diony C. Lebot

Member of the BoD of Ayvens (former ALD Automotive)

Member of the BoD and Chair of the Audit Committee of EQT AB

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4. Profile of the Board of Directors and Committee Membership for the year 2024

Board of Directors

Gender

Age

Tenure (in

years)

Term

ends

Shares owned 31.12.2024

Committees

Number of

% of the

share capital

Audit

Risk Management

Remuneration

Corporate

Governance,

Sustainability and

Nominations

Chair

(Non-Executive Member)

Vasileios T. Rapanos

2026

Executive Members

Vassilios E.

Psaltis

CEO

2026

542,424

0.023

Spyros N.

Filaretos

Chief of

Growth and

Innovation

2026

377,012

0.016

Non-Executive Members

Efthimios O. Vidalis

2026

Johannes Herman Frederik G.

Umbgrove

2026

(until 6.3.2024)

Independent Non-Executive Members

Elli M. Andriopoulou

2026

Aspasia F. Palimeri

2026

Panagiotis I.-K. Papazoglou

2026

24,050

0.001

(as of

24.7.2024)

(until

24.7.2024)

Dimitris C. Tsitsiragos

2026

(until 31.12.2024)

Jean L. Cheval

2026

Carolyn G. Dittmeier

(until 30.9.2024)

2026

(as of

24.7.2024 until

30.9.2024)

(until

24.7.2024)

In charge of

overseeing

ESG issues

(until 30.9.2024)

Elanor R. Hardwick

2026

Diony C. Lebot

2026

NPL Expert

C: Chair

M: Member

-: The Member does not participate in this Committee

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During 2024, the Board convened 20 times, with an average participation rate of 99.6%. This high level of

engagement demonstrates the dedication and commitment of our Members.

Additionally, we held four offsite meetings in 2024, with an attendance rate of 100%. The Non-Executive Members

of the Board also convened seven times during the year, significantly exceeding the minimum requirement. This

proactive approach has greatly contributed to our governance.

It is worth noting that all four Committees of the Board of Directors are chaired by Independent Non-Executive

Members, with the majority of their Members also being Independent Non-Executive Members. Their leadership

and support have been instrumental in assisting the Chair in fulfilling their duties and responsibilities.

The Corporate Governance, Sustainability, and Nominations Committee (CGSNC) observed that there were no

Member absences from Board meetings without a valid reason. Those Members who were unable to attend had

informed the Company in advance of the relevant reasons. For your reference, the table of attendance rates for

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).

BOARD AND

COMMITTEES

ATTENDANCE

F.5

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6. 2024 BOARD MEMBERS’ INDIVIDUAL ATTENDANCE RATES AT MEETINGS

Board of Directors

Audit Committee

Risk Management

Committee

Remuneration

Committee

Corporate Governance,

Sustainability and

Nominations Committee

Number of meetings

Chair

(Non-Executive Member)

Vasileios T. Rapanos

100%

(20/20)

Executive Members

Vassilios E. Psaltis

CEO

100%

(20/20)

Spyros N. Filaretos

Chief of Growth and Innovation

100%

(20/20)

Non-Executive Members

Efthimios O. Vidalis

95%

(19/20)

73%

(8/11)

93%

(13/14)

Johannes Herman Frederik G. Umbgrove

100%

(20/20)

100%

(13/13)

100%

(2/2)

(until 6.3.2024)

100%

(11/11)

100%

(14/14)

Independent Non-Executive Members

Elli M. Andriopoulou

100%

(20/20)

100%

(13/13)

100%

(14/14)

Aspasia F. Palimeri

100%

(20/20)

100%

(14/14)

100%

(11/11)

Panagiotis I.-K. Papazoglou

100%

(20/20)

100%

(13/13)

(as of 24.7.2024)

(until 24.7.2024)

100%

(11/11)

Dimitris C. Tsitsiragos

100%

(17/17)

93%

(13/14)

100%

(11/11)

Jean L. Cheval

100%

(20/20)

100%

(13/13)

100%

(14/14)

Carolyn G. Dittmeier (until 30.9.2024)

100%

(16/16)

100%

(10/10)

(until 24.7.2024)

(as of 24.7.2024 until 30.9.2024)

92%

(11/12)

(until 30.9.2024)

Elanor R. Hardwick

100%

(20/20)

86%

(12/14)

100%

(14/14)

Diony C. Lebot

100%

(20/20)

100%

(14/14)

100%

(14/14)

C: Chair

M: Member

-: The Member does not participate in this Committee

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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”), the Bank of Greece Executive Committee Act 224/21.12.2023 and the

Εuropean Central Bank (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 assessment and nomination process.

• Set out the communication channel with the competent authorities (i.e. Bank of Greece, ECB).

• Set out how the assessment is documented.

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 Functions such as Legal Services, Human Resources

SUITABILITY

AND

NOMINATION

POLICY FOR THE

MEMBERS OF

THE BOARD OF

DIRECTORS

F.7

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and/or Internal Control Functions. Internal Control Functions should provide effective input for the review of the

Policy in accordance with their roles. Notably, the Compliance Unit should analyze how the 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 Board of Directors through the CGSNC.

The CGSNC will propose 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 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 with a clear understanding of the Company’s culture, values and overall

strategy. Suitability also covers the honesty, integrity and independence of mind of each Member 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

competent authorities, 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.

The Suitability and Nomination Policy for the Members of the Board of Directors is posted on the

Company’s website (https://www.alphaholdings.gr/en/Holdings/esg-and-sustainability/advocating-

sound-governance-practices/management/codes-and-policies).

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 an internal document that sets out the framework for the succession planning of the

POLICY AND

PROCESS FOR

THE

SUCCESSION

PLANNING OF

NON-

EXECUTIVE AND

INDEPENDENT

NON-

EXECUTIVE

MEMBERS OF

THE BOARD OF

DIRECTORS

SUITABILITY

AND

NOMINATION

POLICY FOR THE

MEMBERS OF

THE BOARD OF

DIRECTORS

F.8

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aforementioned Members and forms an integral part of the Company’s Suitability and Nomination Policy for the

Members of the Board of Directors. 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

ESMA/EBA Guidelines, as in force, the Bank of Greece Executive Committee Act No. 224/21.12.2023 on the

assessment of suitability for the taking up of a post as a member of the Board of Directors and as a key function

holder and the Hellenic Corporate Governance Code.

The Policy is validated during a succession planning meeting that concludes with the identification of successors,

after a thorough discussion and analysis which takes into account “Suitability and Nomination Policy for the

Members of the Board of Directors” and the findings of the annual evaluation.

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 Suitability and Nomination Policy and Process for the Members of

the Board of Directors as well as on 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 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 (the “CGSNC”) and the Human Resources Unit

of the Company. The CGSNC may request the assistance of an external specialist consultant, in accordance with

the resources available to the Company for this purpose.

POLICY AND

PROCESS FOR

THE

SUCCESSION

PLANNING OF

NON-

EXECUTIVE AND

INDEPENDENT

NON-

EXECUTIVE

MEMBERS OF

THE BOARD OF

DIRECTORS

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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 2024, was

supported by an external firm expert in board effectiveness. Individual interviews with all Board Members and

selected Executives were conducted, focusing on Strategy, Purpose and Role of the Board, Management and

Board Succession, Board Culture, Operating Mechanisms and Board Committees.

The Board Self-Evaluation, carried out through an online questionnaire completed by all Board Members and

selected Executives, focused on a variety of topics concerning Strategy, Stakeholders, Board Dynamics, Diversity

and Inclusion, Board Composition, Operating Mechanisms, Board Succession, Purpose and Sustainability, Talent

Management, Relationship with the Executive Team, Digital Readiness, Disrupt and Challenge, as well as Agility.

The survey captured dimensions most relevant for high-performing boards, highlighting collective strengths and

development areas of the Board.

Alpha Bank's key strengths included a robust and diverse board composition, an open and collegiate board

environment, and improved board operations.

The key recommendations were to revisit the balance and alignment between the Executive and Non-Executive

Members, reviewing the approach to Alpha Bank’s strategy and spending more time on strategic discussions, as

well as revisiting board operations to elevate the quality of board papers and presentations.

The Individual Evaluation of the Members of the Board of Directors for the year 2024 was conducted by the

Chair of the Board of Directors.

Following the recent evaluation of the Board of Directors, an in-depth assessment of our collective suitability has

been conducted. This assessment focuses on our collective knowledge, skills, and experience, in accordance with

the ESMA/EBA Guidelines, with the valued support of the CGSNC.

Each Board Member engaged in this process by completing an Individual Self-Assessment questionnaire,

designed around the criteria specified in the ESMA/EBA Guidelines. The Chair of the Board of Directors has

meticulously reviewed these self-assessments and has compiled the Collective Suitability Matrix, taking into

account various critical aspects such as governance, risk management, compliance, audit, management, strategy,

decision-making, basic theoretical knowledge, and past experience.

Moreover, recognizing that the EBA Guidelines Matrix is a dynamic tool, new sections have been incorporated to

reflect the evolving banking landscape and the needs arising from our Company’s Business Plan.

Based on the approved Collective Suitability Matrix, it has been resolved that our Board would greatly benefit

from the inclusion of new Members who possess extensive knowledge and experience in the Greek market, ESG,

IT and Digital, and who are strategic thinkers.

EVALUATION OF

THE BOARD OF

DIRECTORS

ASSESSMENT

OF THE BOARD

MEMBERS’

COLLECTIVE

SUITABILITY

BASED ON THE

ESMA/EBA

GUIDELINES

F.9

F.10

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ANNUAL FINANCIAL REPORT

The Board of Directors, in accordance with its obligations under paragraph 1 of Article 4 of Law 4706/2020, assessed

the implementation and effectiveness of the Company's Corporate Governance System with a reference date of

December 31, 2024. The assessment, conducted with the support of external advisors, PricewaterhouseCoopers S.A.,

did not reveal any material weaknesses.

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 Bank of Greece Executive Committee Act No.

224/21.12.2023, the relevant ESMA/EBA Guidelines, 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.

The fulfillment of the legal requirements as to the classification of a Member of the Board of Directors as an

Ιndependent Μember is reviewed by the Board of Directors at least on an annual basis per fiscal year, and in any

case prior to the publication of the Annual Financial Report which includes the relevant assertion.

As part of our compliance requirements, the Independent Non-Executive Members are requested annually to

complete and sign a Declaration affirming that they meet all criteria for being Independent Non-Executive

Members. In addition, the Corporate Secretariat and Governance Policies Business Area has established a robust

process to ensure these criteria are met. This includes obtaining copies of the Members’ criminal records on a

quarterly basis.

During 2024, in accordance with the internal process and procedures that involve, inter alia, a review by the

competent Business Areas, relevant Declarations by the Independent Non-Executive Members, as well as

assessment of all relevant information and data, the independence of the Board of Directors has been assessed

internally, under the coordination of the Corporate Secretariat and Governance Policies Business Area.

Our Board of Directors, with the support of the CGSNC, and taking into consideration the above, has reviewed the

independence criteria and confirmed that the Independent Non-Executive Members, namely Dimitris C.

Tsitsiragos, Elli M. Andriopoulou, Aspasia F. Palimeri, 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. This confirmation is in accordance with Law 4706/2020 on corporate

governance, the Bank of Greece Executive Committee Act No. 224/21.12.2023, the Articles of Incorporation, and

the Hellenic Corporate Governance Code, as in force.

ANNUAL

CONFIRMATION

OF THE

MEMBERS’

INDEPENDENCE

F.12

ASSESSMENT OF

THE

EFFECTIVENESS OF

COMPANY’S

APPROACH TO

CORPORATE

GOVERNANCE

F.11

F.12

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ANNUAL FINANCIAL REPORT

13.1 Induction and Training Policy and Procedure for the Members of the Board of Directors

The Induction and Training Policy and Procedure for the Members of the Board of Directors is a document of

Alpha Services and Holdings S.A. that sets 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 ESMA/EBA Guidelines, as well as with the 2021 European Central Bank (ECB) Guide

to fit and proper assessments, the Bank of Greece Executive Committee Act No. 224/21.12.2023: “Assessment of

suitability for the taking up of a post as a member of the Board of Directors and as a key function holder – Repeal

of Chapter C of Executive Committee Act No. 142/11.6.2018 ‘Procedures for (a) the authorisation of credit

institutions in Greece; (b) the acquisition of, or increase in, a holding in credit institutions; and (c) the taking up of

a post as a member of the Board of Directors and as a key function holder of credit institutions’” (Government

Gazette B 2674), and 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 relevant general and, as appropriate, individually-tailored training programs.

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.

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;

• The role of the Board Members;

• Corporate Governance principles;

• Risk Management, Compliance and Internal Audit;

• 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.

INDUCTION

AND TRAINING

F.13

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ANNUAL FINANCIAL REPORT

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, focusing 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, strategic and other relevant changes as well as changes in the

applicable legislation and in 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

taking into account their roles and tasks, and, where appropriate, sessions for specific positions according to their

particular responsibilities and involvement in the Board Committees.

The Board of Directors, following relevant recommendation by the CGSNC, approved the 2024 annual training –

informative schedule for the Members of the Board of Directors at its meeting held in January 2024.

Throughout 2024, the following training programs (informative sessions) took place:

BoD Training programs

Regulatory Framework

Cybersecurity awareness

ESG Matters- IFRS & CSRD

Artificial Intelligence

Climate

Regulatory update

Digital Operational Resilience Act (DORA)

Basel Committee on Banking Supervision

(BCBS239) / Risk Data Aggregation and Risk

Reporting (RDARR)

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 2024, several of our Board Members attended individual training programs.

INDUCTION

AND TRAINING

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

The Board has the authority to establish both permanent and ad hoc Committees to support it in discharging its

responsibilities effectively. While these Committees primarily serve an advisory role, they may also assume certain

delegated authorities as determined by the Board.

Each Committee operates under a dedicated Charter that outlines its composition, tenure, functioning and

responsibilities. Currently, there are four Committees at the Board level: the Audit Committee, the Risk

Management Committee, the Remuneration Committee, and the Corporate Governance, Sustainability, and

Nominations Committee.

Each Committee comprises no fewer than three Members, with the composition proposed to the Board by the

Corporate Governance, Sustainability, and Nominations Committee (CGSNC). This proposal takes into account the

"Suitability and Nomination Policy for Members of the Board of Directors" as well as relevant legal and regulatory

frameworks. It is also important to note that the majority of the Members of each Committee are Independent

Non-Executive Members.

The primary focus of these Committees is to oversee policies, practices, and procedures within their respective

areas of mandate, as detailed in the Charters of each Committee. They also play a crucial role in preparing draft

resolutions for Board approval and submitting relevant briefings, reports, key information, and recommendations

to the Board. Furthermore, the Committees report regularly to the Board about their work.

COMMITTEES

OF THE BOARD

OF DIRECTORS

F.14

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ANNUAL FINANCIAL REPORT

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 24.7.2024, in accordance with the provisions of article 44 par. 1 case e)

of Law 4449/2017, as in force.

Mr. P.I.-K. Papazoglou and Mr. J.L. Cheval, Independent Non-Executive Members of the Board of Directors,

possess adequate auditing and accounting knowledge and experience, and at least one of them shall attend the

Committee’s meetings relating to the approval of the Financial Statements.

Audit Committee Composition (as of the date of publication of the 2024 Annual Report)

Audit Committee

Panagiotis I.-K. Papazoglou

Chair, Independent Non-Executive Member

Chair of the Committee since: 24.7.2024

Member of the Committee since: 27.7.2023

Elli M. Andriopoulou

Independent Non-Executive Member

Member of the Committee since: 22.7.2022

Jean L. Cheval

Independent Non-Executive Member

Member of the Committee from 29.6.2018 until 31.7.2020 and

from 22.7.2022 until now

Johannes Herman Frederik G.

Umbgrove

Non-Executive Member

Member of the Committee since: 26.4.2018

Carolyn G. Dittmeier was a Member of the Committee from 29.1.2017 until 28.9.2017 and from 24.7.2024

until 30.9.2024 and Chair of the Committee from 28.9.2017 until 24.7.2024

2024

Number of Audit Committee Meetings

Average ratio of Members’ attendance

100%

AUDIT

COMMITTEE

Independent Non-Executive

Members

75%

Non-

Executive

Members

25%

Audit Committee Composition

(as of the date of publication of the 2024 Annual Report)

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

200 |

ANNUAL FINANCIAL REPORT

The Committee convenes at least on a quarterly 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 its Subsidiaries, 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 its Subsidiaries, 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 Information, the Sustainability Report, reporting processes

and the ESG disclosures.

▪ Reviews the 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 its Subsidiaries and

the recommendations identified in these reports.

▪ Reviews and endorses, for approval to the Board of Directors, policies regarding the Internal Audit

methodology of the Company as well as any amendments thereto.

▪ Reviews and endorses, for approval to the Board of Directors, policies regarding the Compliance

methodology 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 Unit

and of the Compliance Unit of the Company and of the overall Units across the Group.

▪ Is responsible for the procedure followed for the selection of the Statutory Certified Auditors of the

Company and its Subsidiaries 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 its Subsidiaries. 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 its Subsidiaries, based on the relevant policy that the Audit Committee oversees and

recommends to the Board of Directors for approval.

▪ Monitors and assesses the adequacy and effectiveness 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 Unit,

based on the regular Compliance Reports.

▪ Assesses the adequacy and effectiveness of the “Anti-Money Laundering and Combating the Financing of

Terrorism Policy” and of the respective procedures.

▪ Oversees the Company’s effort to foster a culture of ethics and discourage unethical behavior in all

operational levels.

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.

AUDIT

COMMITTEE

AUDIT

COMMITTEE

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

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 2024, the Committee has been actively engaged in several key initiatives aimed at ensuring the continued

strength and integrity of our organization.

Firstly, the Committee evaluated the reports for the year 2023 and proposed their approval by the Board of

Directors for submission to the Bank of Greece. These reports include the Annual Report of the Internal

Audit Division on the Internal Control System of the Bank and the Annual Report of the Compliance

Division, as required by the Bank of Greece Governor’s Act 2577/9.3.2006.

Additionally, the Committee approved and submitted an assessment report on the adequacy and effectiveness of

the Internal Control System of the Group to the Bank of Greece.

The Committee also reviewed the Internal Audit Charter and proposed its approval by the Board of Directors.

In a meeting held without the presence of the Company’s Management, the Committee confirmed the

independence of the Head of Internal Audit. The Committee was also informed of the quarterly activity reports of

the Internal Audit and Compliance Units, based on the plans that were previously endorsed by the Audit

Committee.

Moreover, the Committee endorsed the Internal Audit Methodologies and the Internal Audit Process Manual,

deciding to submit them to the Board of Directors for approval. The Committee also endorsed the revised Group

Annual Audit Plan (AAP) for 2024 and proposed its approval by the Board of Directors as well as the Group Annual

Audit Plan for 2025, recommending its approval by the Board of Directors.

The Committee was updated on the new Institute of Internal Audit (IIA) Global Internal Audit Standards (GIAS),

ensuring that the Company remains aligned with the latest industry standards and best practices.

The Committee endorsed the scope of the External Quality Review (EQA) of the Internal Audit and validated the

objectivity of the selected external consultant for this review. The Committee proposed the approval of this by the

Board of Directors. Additionally, the Committee endorsed the Annual Plan and objectives of the Compliance

Business Area for 2025 and has decided to recommend their approval to the Board of Directors.

AUDIT

COMMITTEE

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

202 |

ANNUAL FINANCIAL REPORT

The Committee also reviewed and endorsed the revised content of the Code of Conduct and Ethics, resolving to

submit it to the Board of Directors for their approval.

Regarding ongoing audits, the Committee received an update on the Statutory Certified Auditors’ Audit Plan for

2024. The Committee proposed to the Board of Directors the approval of the appointment of the Statutory

Certified Auditor and the relevant Statutory and Tax Audit fees for 2024. The Committee also followed up on the

2023 Statutory and Tax Audit fees, as well as the statutory fees for 2024 for Alpha Services and Holdings

Subsidiaries.

In terms of financial statements, the Committee reviewed the annual Financial Statements for Alpha Services and

Holdings S.A. and the Group for the year 2023. The Committee also reviewed the consolidated First Quarter

Financial Statements of Alpha Services and Holdings S.A. for 2024, the standalone and consolidated semi-annual

Financial Statements for Alpha Services and Holdings S.A. for 2024, and the consolidated Third Quarter Financial

Statements of Alpha Services and Holdings S.A. for 2024. These reviews included the relevant Press Releases prior

to their submission to the Board of Directors for approval.

The Board of Directors was informed about the outcome of the statutory audit, and the Committee explained how

the statutory audit contributed to the integrity of financial reporting and the role the Committee played in this

process. The Committee focused on significant accounting issues and areas requiring professional judgment. The

Committee recommended to the Board of Directors that the annual Financial Statements be prepared in

accordance with applicable accounting standards and give a true and fair view of the assets, liabilities, equity, and

financial performance of the Company and its Subsidiaries, as provided for in article 4 pars 3 and 4 of Law

3556/2007.

The Committee performed oversight of the Group Statutory Certified Auditors’ (Deloitte) activity and performance

and reviewed their Audit Plan for 2024. This review included the planned audit approach, key audit matters and

risks, materiality, risk assessment, scope of the audit, audit standards and regulations. The Committee also

evaluated the internal control issues regarding financial reporting processes identified by the Statutory Certified

Auditor and the adequacy of the responses provided by Management. The Committee assessed the Audit Plan for

2024, ensuring it covered the most significant areas of control, taking into account the main areas of business and

financial risk of the Company.

The Committee reviewed the Statutory Certified Auditors’ Audit Report according to article 10 of Regulation (EU)

No 537/2014 and the Additional Report according to article 11 of Regulation (EU) No 537/2014. The Committee

also reviewed the action plan regarding the Significant Deficiencies reported by the Statutory Auditor in its

Additional Report as of 31.12.2023.

The Committee monitored the independence of the Statutory Certified Auditor in accordance with current laws.

This was done during a meeting without the presence of the Company’s Management, particularly focusing on the

provision of Non-Audit Services to the Company and the Group. In this context, the Committee reviewed and

approved these Non-Audit Services provided to the Alpha Services and Holdings Group by the Statutory Certified

Auditor, based on the Policy and Procedures for the Assignment of Non-Audit Services. The fees recognized to our

external auditor, Deloitte Certified Public Accountants S.A. and its network, are detailed in the Consolidated

Annual Financial Statements for 2024.

The Committee also reviewed the annual evaluation of the Statutory Certified Auditor for 2023, taking into

account the overall considerations and evaluation of the Management. Furthermore, the Committee closely

monitored the process followed for drafting the Non-Financial Report and the Sustainability Report for 2023. The

AUDIT

COMMITTEE

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ANNUAL FINANCIAL REPORT

Committee was updated on the materiality analysis process and reviewed the relevant Limited Assurance

Reports by the External Auditor. Deloitte Certified Public Accountants S.A. provided the Limited Assurance Reports

for both the Non-Financial Report and the Sustainability Report for 2023, prepared in accordance with the

International Standard on Assurance Engagements (ISAE) 3000.

The Committee endorsed the Non-Financial Report and the Sustainability Report for 2023 and proposed their

approval by the Board of Directors. Additionally, the Committee acquired a thorough 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 updates on the Regulatory Agenda concerning significant capital adequacy, regulatory

liquidity, supervisory, and environmental issues.

The Committee also met with the Company’s Management and was informed about the progress of significant

projects affecting the Group’s internal control systems. In several meetings with Executives from various Business

Areas of the Company, the Committee reviewed operational risk, cyber, IT, human resources, legal, and other

issues. The Committee endorsed the amendments of the Policy and Procedures for the Selection and

Reappointment of the Statutory Auditor and recommended its approval by the Board of Directors. The Committee

approved the initiation of the procedures and the respective time plan for the statutory auditor selection due to

mandatory rotation.

Furthermore, the Committee reviewed and approved the scorecards and goals of the Head of Internal Audit and

Head of Compliance for 2024. The Committee was also updated on the Supervisory Review and Evaluation Process

(SREP). Additionally, the Committee received updates on the implementation of the Corporate Sustainability

Reporting Directive (CSRD) Project in 2024, the Sustainability Statement, as well as the European Sustainability

Reporting Standards (ESRS) Gap Assessment (Data Collection Sprint 1) and the ESRS Double materiality analysis

methodology.

The Committee conducted a first reading of the updated Related Parties Policy and Procedures.

To further enhance corporate governance and foster collaboration among our Subsidiaries, the Committee

initiated a series of meetings with the Audit Committees of the Subsidiaries. Specifically, the Audit Committee held

joint meetings with the Audit Committees of Alpha Bank London Ltd., of Alpha Bank Cyprus (held in Cyprus), of

Alpha Leasing S.A., Alpha Real Estate Services S.A. and Alpha Finance S.A. These joint meetings have been very

productive and insightful.

The Committee has reviewed the Annual Activity Reports for 2023 and the Semi-Annual Activity Reports for 2024

prepared by the Audit Committees of the Subsidiaries. These reviews have been crucial in ensuring that the

Committees are on the right track and are meeting their goals.

In 2024, the Audit Committee also conducted joint meetings with the Risk Management Committee to discuss

areas of common interest, particularly in risk and capital management, and their effects on the Internal Control

System. Among the key points discussed and endorsed were the Bank’s action plan regarding the OSI on

Operational Risk, which the Committee aims to propose for approval by the Board of Directors.

Furthermore, the Committee was informed about and discussed several important topics, including the

Outsourcing Policy, the Operational Act on Outsourcing from the SSM and the draft action plan, the Non-Financial

Risks Profile update, the ECB Cyber Resilience Stress Test update, the Supervisory Dialogue outcome for 2024

within the context of the Supervisory Review and Evaluation Process (SREP), and the 2024 SREP Decision Letter

along with the relevant Action Plan.

These discussions and meetings have been instrumental in guiding our future actions and ensuring that the

Committee remains compliant and proactive in addressing any potential risks.

AUDIT

COMMITTEE

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

204 |

ANNUAL FINANCIAL REPORT

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 of the date of publication of the 2024 Annual Report)

Risk Management Committee

Jean L. Cheval

Chair, Independent Non-Executive Member

Chair of the Committee since: 22.7.2022

Member of the Committee since: 31.7.2020

Aspasia F. Palimeri

Independent Non-Executive Member

Member of the Committee since: 22.7.2022

Dimitris C. Tsitsiragos

Independent Non-Executive Member

Member of the Committee from: 31.7.2020 until 31.12.2024

Elanor R. Hardwick

Independent Non-Executive Member

Member of the Committee since: 22.7.2022

Diony C. Lebot

Independent Non-Executive Member

Member of the Committee since: 27.7.2023

Mr. Dimitris C. Tsitsiragos was a Member of the Committee from 31.7.2020 until 31.12.2024 and Mr. Johannes

Herman Frederik G. Umbgrove was a Member of the Committee from 26.4.2018 until 6.3.2024

RISK

MANAGEMENT

COMMITTEE

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ANNUAL FINANCIAL REPORT

The Committee convenes at least on a quarterly basis 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:

▪ 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.

▪ Εnsures that the Group’s strategy, budget process, capital and liquidity planning and remuneration

framework are aligned with the risk appetite framework and 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.

▪ Recommends to the Board of Directors for approval high-level policies on the management

of risks.

2024

Number of Risk Management Committee Meetings

Average ratio of Members’ attendance

98%

RISK

MANAGEMENT

COMMITTEE

Independent Non-Executive Members

100%

Risk Management Committee Composition

(as of the date of publication of the 2024 Annual Report)

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

206 |

ANNUAL FINANCIAL REPORT

▪ 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)/Internal Liquidity

Adequacy Assessment Process (ILAAP) and 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 and monitors recent regulatory developments, emerging supervisory

expectations, the results of supervisory requests and the Supervisory Review and Evaluation Process

(SREP) conclusions.

▪ Collaborates with the Corporate, Governance, Sustainability and Nominations Committee and 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.

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).

Throughout 2024 the Committee discussed, challenged and endorsed the updated Risk and Capital Strategy

(RCS)/Risk Appetite Framework (RAF) for 2024. The Committee also discussed, challenged and endorsed the RCS

for 2025 with regards to specific Risk Appetite Framework (RAF) Key Performance Indicators (KPIs).

Additionally, the Committee reviewed the annual Risk Management Report and the Risk Management Unit

Assessment Report for 2023, which were submitted to the Bank of Greece. The Committee resolved to propose

these reports for approval to the Board of Directors as well.

Another significant activity was the discussion and endorsement of the updated Non-Performing Exposures (NPEs)

Reduction Plan for 2024. The Committee resolved to submit this plan to the Board of Directors for their approval.

The Committee also reviewed and proposed the Group Internal Capital Adequacy Assessment Process (ICAAP)

Report for 2024, along with the concluding Group Capital Adequacy Statement (CAS) for 2024. In addition, the

Committee discussed the Group Internal Liquidity Adequacy Assessment Process (ILAAP) Report for 2024 and the

concluding Group Liquidity Adequacy Statement (LAS) for 2024. The Committee proposed all these reports for

approval and submission to the Single Supervisory Mechanism (SSM).

The Committee discussed and endorsed the updated Shareholders Remuneration Policy and resolved to propose

its approval by the Board of Directors.

The Non-Financial Risks Management Policy was thoroughly examined, resulting in a resolution to propose its

approval by the Board of Directors. The Committee also reviewed the Pillar III Disclosures Report for both the Full

Year 2023 and the First Half of 2024 and decided to submit it to the Board for approval. Additionally, the updated

Contingency Funding Plan (CFP) and the Group Recovery Plan (2024) Report were endorsed and proposed for

Board approval.

RISK

MANAGEMENT

COMMITTEE

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ANNUAL FINANCIAL REPORT

In terms of our environmental initiatives, the Committee examined the action plan for the Bank regarding the SSM

Thematic Review/Climate and Environmental Shortcomings and recommended its approval by the Board. The

Committee also focused on the Key Risk Indicators (KRIs) and their respective limits, both for monitoring risks in

synthetic securitization activities and with respect to Interest Rate Risk in the Banking Book (IRRBB). Both were

proposed for Board approval.

Furthermore, the Committee conducted the annual review of its Charter and resolved to recommend its approval

by the Board through the CGSNC. The Committee also reviewed and approved the CEO’s evaluation of the Chief

Risk Officer (CRO) and discussed the CRO's performance for 2023. The CRO scorecard and goals for 2024 were

approved, and the Committee endorsed the Succession Plan of the CRO, proposing its approval by the Board

through the CGSNC.

The Committee took cognizance of the 2023 Supervisory Review and Evaluation Process (SREP) Decision Action

Plan. Additionally, the Committee was informed of and discussed several other matters, including the NPEs Plan

evolution and quarterly performance on NPEs targets, the ECB's final feedback letter on Climate and

Environmental shortcomings, and the SSM and SRB Agendas for 2024.

The Committee also reviewed the evolution of various risks, such as credit, market, liquidity, non-financial, climate

and ESG, enterprise risk management, data risk, and capital adequacy and supervisory issues. Furthermore, the

Committee was updated on the publication of supervisory issues by regulatory authorities (ECB, EBA), the annual

Supervisory Examination Program (SEP) of the Group, the quarterly Data Quality Dashboard (DQD) for the Bank,

and the monthly Credit Committee I approvals for Wholesale Loans.

The Committee was informed about the SSM’s feedback on the 2023 Group Recovery Plan submission, the ECB

Cyber Resilience Stress Test, the final report of the On-Site Inspection (OSI) on Liquidity, the progress of the OSI on

Risk Data Aggregation and Risk Reporting (RDARR) and New Lending, the first RDARR Validation Report, and the

follow-up Letter regarding the Assessment of the Forbearance Framework. Additionally, the Committee discussed

the Final Report on the OSI on Commercial Real Estate, the Risk Culture Measurement, the Requirements of the

Digital Operational Resilience Act (DORA) and the Bank’s Compliance Initiatives, as well as the gap analysis and

action plan for compliance with DORA.

The Committee was informed of and discussed several important topics, including the CSRD Double Materiality

Results and Reporting structure, the Additional Tier I Issuance in the Second Half of 2024, the Synthetic

Securitization Policy and Operating Manual, the ESG report and the Climate Strategy update, the “fit-for-55"

climate scenario analysis submission and results, and the Risk Management excerpt from the 2023 Annual Report

of the Internal Audit on the evaluation of the Internal Control System.

Regarding our Subsidiaries, the Risk Management Committee reviewed the Annual Activity Reports for 2023 and

the Semi-Annual Activity Reports for 2024 prepared by the Risk Management Committees of major subsidiaries. In

this context, joint meetings were held with the Members of the Risk Management Committees of Alpha Bank

Cyprus Ltd, Alpha Bank London Ltd, ABC Factors S.A., and Alpha Finance Investment Services S.A. To further

enhance corporate governance and collaboration among the Subsidiaries, the Committee launched a series of

meetings with the Risk Management Committees of our Subsidiaries abroad.

RISK

MANAGEMENT

COMMITTEE

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ANNUAL FINANCIAL REPORT

In 2024, the Risk Management Committee also had joint meetings with the Audit Committee to review areas of

common interest in risk and capital management and their repercussions on the Internal Control System. During

these meetings, the Audit Committee and the Risk Management Committee endorsed the Bank’s action plan

regarding the OSI on Operational Risk and resolved to propose its approval by the Board of Directors. They were

also informed of and discussed the Outsourcing Policy, the Operational Act on Outsourcing from the SSM and the

respective draft action plan, the Non-Financial Risks Profile update, the Supervisory Dialogue outcome for 2024 in

the context of the Supervisory Review and Evaluation Process (SREP), the 2024 SREP Decision Letter, and the

relevant Action Plan.

Moreover, the Members of the Risk Management Committee participated in the meetings of the Audit Committee

for the review of the Financial Statements.

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 of the date of publication of the 2024 Annual Report)

Remuneration Committee

Aspasia F. Palimeri

Chair, Independent Non-Executive Member

Chair of the Committee since: 27.2.2025

Member of the Committee since: 22.7.2022

Dimitris C. Tsitsiragos

Independent Non-Executive Member

Chair of the Committee from 27.7.2023 until 27.2.2025

Member of the Committee from 31.7.2020 since 27.7.2023 and

since 27.2.2025

Panagiotis I.-K. Papazoglou

Independent Non-Executive Member

Member of the Committee since: 27.7.2023

Johannes Herman Frederik

G. Umbgrove

Non-Executive Member

Member of the Committee since: 26.4.2018

Mr. E.O. Vidalis was a Member of the Remuneration Committee from 15.12.2016 until 31.7.2020 and from 27.7.2023

until 27.2.2025

REMUNERATION

COMMITTEE

RISK

MANAGEMENT

COMMITTEE

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ANNUAL FINANCIAL REPORT

The Committee convenes at least on a quarterly basis 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.

Independent Non-Executive

Members

75%

Non-

Executive

Members

25%

Remuneration Committee Composition

(as of the date of publication of the 2024 Annual Report)

2024

Number of Remuneration Committee Meetings

Average ratio of Members’ attendance

95%

REMUNERATION

COMMITTEE

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ANNUAL FINANCIAL REPORT

▪ Recommends to the Non-Executive Members the remuneration of the Members of the Board of Directors

on a regular basis.

▪ Reviews and advises on fixed salaries, benefits and total remuneration within the Company on a regular

basis.

▪ 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 of the Board of Directors, 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 collectively have 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 2024, the Committee reviewed and recommended the approval of the Remuneration Policy for Alpha

Services and Holdings and its Group, along with its Annexes. This was done by the Non-Executive Members of the

Board of Directors. Additionally, the Committee reviewed and recommended the approval of the Combined Bonus

Plan (STI/LTI) as part of the Variable Remuneration Framework. This was also approved by the Non-Executive

Members and subsequently by the Board of Directors.

Furthermore, the Committee reviewed and recommended the approval of the 2023 Performance Incentive

Program (PIP) Gates, Pool, and Allocation. The Committee also recommended the approval of the award under the

Performance Incentive Program (PIP) 2023 to the Senior Leadership Team (SLT). In terms of executive contracts,

the Committee reviewed the amendments of the contracts of the CEO and Deputy CEO and recommended the

approval of the proposed fixed salary increases by the Non-Executive Members and subsequently by the Board of

Directors.

Moreover, the Committee reviewed the salary structures and recommended their approval to the Board of

Directors. The Committee reviewed and recommended the approval of the Stay-on Bonus Plan by the Non-

Executive Members and subsequently by the Board of Directors.

Additionally, the committee has reviewed and recommended the approval of a one-off payment through Profit

Distribution. Our review also included the list of Material Risk Takers (MRTs) for 2023, which the Committee has

recommended for approval by the Non-Executive Members of the Board of Directors.

REMUNERATION

COMMITTEE

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ANNUAL FINANCIAL REPORT

In preparation for the Ordinary General Meeting of Shareholders, the Committee has reviewed and endorsed, as

part of the material to be submitted, the Remuneration Policy and the Remuneration Report as per Law

4548/2018. Furthermore, the committee recommended that the Board of Directors approved a higher than 100%

maximum level of the ratio between the variable and fixed components of remuneration.

As a token of appreciation for the Staff's contribution to the Company's profitability and objectives, the committee

reviewed and recommended the approval of the distribution of part of the Company’s intragroup dividend reserve

to the Company’s Staff. The committee has also finalized the remuneration amounts for the Members of the

Board of Directors for the financial year 2024.

The Committee has reviewed the Policy for the Evaluation of Senior Executives and Key Function Holders and

provided input to the CGSNC. The committee has also reviewed the Remuneration Committee Charter. Moreover,

the Committee has been updated on several important matters, including the Action Plan regarding the SSM

Thematic Review on Risk Culture and Incentives, the Audit Report on the Remuneration Policy, the Alpha

Performance Dialogue 2023 Results, the Talent Identification Process, a Gender Gap analysis, the Scorecards

Simplification, and the Employee Engagement Survey Results.

Additionally, the Committee has reviewed its Annual Activity Report and submitted it to the Board of Directors for

information.

Regarding the Subsidiaries, the Remuneration Committee has reviewed the 2023 Annual Activity Reports and the

2024 Semi-Annual Activity Reports of the Remuneration Committees of Alpha Bank London Ltd, Alpha Bank

Romania S.A., Alpha Bank Cyprus Ltd, and Alpha Real Estate Services S.A. (former Alpha Astika Akinita S.A.). In an

effort to further enhance corporate governance and collaboration among the Subsidiaries, the committee has

launched a series of videoconference meetings with the Remuneration Committees of the Subsidiaries abroad. In

this context, the committee has held joint meetings with the Remuneration Committees of Alpha Bank London Ltd

and Alpha Bank Cyprus Ltd, as well as with the Remuneration and Nomination Committee of Alpha Real Estate

Services S.A. (former Alpha Astika Akinita S.A.). The Committee has also been updated on Subsidiaries’

remuneration issues.

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 of the date of publication

of the 2024 Annual Report)

Corporate Governance, Sustainability and Nominations Committee

Elanor R. Hardwick

Chair, Independent Non-Executive Member

Chair of the Committee since: 30.9.2021

Member of the Committee since: 31.7.2020

Elli M. Andriopoulou

Independent Non-Executive Member

Member of the Committee since: 22.7.2022

Diony C. Lebot

Independent Non-Executive Member

Member of the Committee since: 27.7.2023

Johannes Herman Frederik G.

Umbgrove

Non-Executive Member

Member of the Committee since: 26.4.2018

Mr. E.O. Vidalis was a Member of the Corporate Governance, Sustainability and Nominations Committee from

15.12.2016 until 27.2.2025 and Ms. C. G. Dittmeier was a Member of the Corporate Governance, Sustainability

and Nominations Committee from 31.7.2020 until 30.9.2024.

Corporate

Governance,

Sustainability and

Nominations

Committee

REMUNERATION

COMMITTEE

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212 |

ANNUAL FINANCIAL REPORT

2024

Number of CGSNC Meetings

Average ratio of Members’ attendance

97%

Corporate

Governance,

Sustainability and

Nominations

Committee

Independent Non-Executive

Members

75%

Non-

Executive

Members

25%

Corporate Governance, Sustainability and Nominations Committee

Composition

(as of the date of publication of the 2024 Annual Report)

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213 |

ANNUAL FINANCIAL REPORT

The Committee convenes at least on a quarterly basis 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 ESG trends and regulatory developments

reporting that may significantly affect the Company’s activities recommending to the Board of Directors

areas that may require actions.

▪ Oversees the process of ESG strategy and targets update by the Board of Directors as well as the

development and implementation of the Company’s ESG and Sustainability policies.

▪ Reviews the sustainability reporting to Stakeholders as well as the respective communication and

ratings in coordination with the Audit Committee.

▪ Acts as the ultimate liaison between the Board Committees and the Board, ensuring proper

coordination 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 and 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 on-going knowledge and skills development for the Members, which support

the effective discharge of their responsibilities.

Corporate

Governance,

Sustainability and

Nominations

Committee

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214 |

ANNUAL FINANCIAL REPORT

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 to adequately discharge the Committee’s responsibilities.

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).

Throughout the year 2024, the Committee was actively engaged in several significant tasks. The Committee held

numerous meetings focusing on Chair Succession Planning, leading to the recommendation for the election of Mr.

D.C. Tsitsiragos as Chair of the Board of Directors of Alpha Services and Holdings S.A, replacing Mr. V.T. Rapanos,

and the subsequent approval thereof by the Board of Directors. Additionally, the Committee recommended the

appointments of Mr. N.V. Salakas as Chief of Corporate Center and General Counsel and Member of the Executive

Committee, of Mr. L.A. Papagaryfallou as Deputy CEO and of Mr. V.G. Kosmas as Chief Financial Officer of Alpha

Services and Holdings S.A.

The Committee also endorsed the CEO’s successor and the successors list for Senior Executive and Key Function

Holders positions, recommending their approval by the Board of Directors. The Committee reviewed and

proposed several important documents for approval, including the Corporate Governance Statement for 2023,

the Code of Conduct and Ethics, the BoD Committees’ Charters, and the Board of Directors’ Charter. The

Committee also worked on the European Banking Authority (EBA) Guidelines Matrix for the collective suitability

assessment of the Board of Directors and policies related to Succession Planning and Nomination for both Senior

Executives and Board Members.

Furthermore, the Committee discussed the Succession Planning for Non-Executive Members of the Board and

confirmed that the Independent Non-Executive Members meet all criteria for their roles, in accordance with Law

4706/2020 on corporate governance, the Articles of Incorporation, and the Hellenic Corporate Governance Code.

The Committee recommended the content of the Draft Invitation and Draft Resolutions for the Ordinary General

Meeting of Shareholders held on 24.7.2024 and the selection of Heidrick & Struggles for the Collective Evaluation

of the Board Members for 2023.

The Committee took cognizance of the Board Evaluation Report for the year 2023, which was meticulously drafted

by Heidrick & Struggles. This report provided valuable insights into the evaluation of our Board of Directors.

Additionally, the Committee recommended to the Board of Directors the selection of PriceWaterhouseCoopers as

the firm to conduct the assessment of Alpha Bank’s approach to Corporate Governance.

The Committee was also informed about the commencement of the merger process between Alpha Services and

Holdings S.A. and Alpha Bank S.A. Furthermore, it received updates on the Extended Leadership Team and an

assessment of the Executive Committee, which are crucial for our organizational development.

Corporate

Governance,

Sustainability and

Nominations

Committee

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ANNUAL FINANCIAL REPORT

Another key point discussed was Talent Management, where the Committee received an update on current

strategies and initiatives. In terms of governance, the Committee was updated on the appointment of Board

Members who will oversee specific issues, ensuring that our governance policies are robust and effective.

Environmental, Social, and Governance (ESG) issues were regularly updated to the Committee, highlighting our

commitment to sustainability and corporate responsibility. Moreover, there was a significant update on the

Corporate Sustainability Reporting Directive (CSRD) Implementation. The Committee also reviewed the

Sustainability Report for the year 2023 and recommended its approval by the Board of Directors. Additionally, an

update on the Materiality Analysis was provided.

The attendance of Members at the Board of Directors' and Committees' meetings for the year 2023 and for the

First Half of 2024 was also reviewed. Finally, the Committee reviewed and submitted its Annual Activity Report to

the Board of Directors for their information.

Regarding our Subsidiaries, the Corporate Governance, Sustainability, and Nominations Committee reviewed the

2023 Annual and the 2024 Semi-Annual Activity Reports of the Subsidiaries’ Nomination Committees and Boards

of Directors. There were also joint meetings held with the Nominations, Corporate Governance, and Sustainability

Committee of Alpha Bank Cyprus Ltd (held in Cyprus) and the Remuneration and Nomination Committee of Alpha

Real Estate Services S.A. (formerly Alpha Astika Akinita).

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, including the strategy on

Environmental, Social and Governance (ESG) issues of the Company and the Group, 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.

EXECUTIVE

COMMITTEE

G.1

Corporate

Governance,

Sustainability and

Nominations

Committee

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216 |

ANNUAL FINANCIAL REPORT

▪ 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) the 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 that have high stature and

significant know-how, as well as sufficient resources to perform their operations, (iii) the 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.

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

Chief Executive Officer (CEO)

Members

Lazaros A. Papagaryfallou

Deputy CEO

Spyros N. Filaretos

Chief of Growth and Innovation

Spiros A. Andronikakis

Chief Risk Officer (CRO)

Ioannis M. Emiris

Chief of Wholesale Banking

Isidoros S. Passas

Chief of Retail Banking

Nikos V. Salakas

Chief of Corporate Center and General Counsel

Stefanos N. Mytilinaios

Chief Operating Officer (COO)

Fragiski G. Melissa

Chief Human Resources Officer (CHRO)

Georgios V. Michalopoulos

Chief Wealth Management Officer

Vasilis G. Kosmas

Chief Financial Officer (CFO)

Mr. S. Oprescu was a Member of the Executive Committee until 3.11.2024 and Mr. S. Filaretos until 5.3.2025.

EXECUTIVE

COMMITTEE

MEMBERS OF

THE EXECUTIVE

COMMITTEE

G.2

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ANNUAL FINANCIAL REPORT

Chair

Vassilios E. Psaltis

CEO

Experience and contribution

Vassilios E. Psaltis is the CEO and an Executive Member of the Board of Directors of Alpha Services and Holdings and

Alpha Bank. In his capacity as a Board Member since November 2018, and CEO since January 2019, he actively

contributes to implementing Alpha Bank’s strategic plan. In 2023 he promoted a multilevel milestone deal with

UniCredit. This strategic partnership has unlocked the profitability potential of Alpha Bank’s international business,

while creating upside potential for the rest of the Group.

With over 25 years of experience in the banking industry, he has been appointed to key positions at Alpha Bank

since 2007. Through these posts he has significantly reinforced the position of Alpha Bank. He spearheaded capital

raisings 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 system.

On top of his duties at Alpha Bank, he has also been serving as a Member of the Board of Directors and the Executive

Committee of the Hellenic Federation of Enterprises (SEV) since July 2021 and as a Member of the Board of Directors

of the Hellenic Bank Association (HBA) since October 2021. In 2019 he was appointed member of the Institut

International d' Études Bancaires (IIEB).

He holds a PhD and MA in Business and Banking from the University of St.Gallen, Switzerland.

Current and past appointments

• CEO, Alpha Bank (2019 - today)

• General Manager, Alpha Bank (2012-2018)

• Group Chief Financial Officer (CFO), Alpha Bank (2010-2018)

• Senior Manager, Corporate Planning and Controlling, Alpha Bank (2007-2010)

• Deputy (acting) Chief Financial Officer, Emporiki Bank (2002-2006)

• Senior management positions, ABN AMRO Bank’s Financial Institutions Group, London (1999-2001)

MEMBERS OF

THE EXECUTIVE

COMMITTEE

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ANNUAL FINANCIAL REPORT

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 Chief Financial Officer (CFO) for the Group. On 23.7.2024 he was appointed Deputy CEO.

He was born in Athens in 1958. He studied Economics at the University of Manchester, and he holds a MPhil in

Development Economics and International Development from the University of Sussex. 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 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.

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 Chief Risk Officer (CRO).

Member

Lazaros A. Papagaryfallou

Deputy CEO

Member

Spyros N. Filaretos

Chief of Growth and Innovation

Until 5.3.2025

Member

Spiros A. Andronikakis

Chief Risk Officer (CRO)

MEMBERS OF

THE EXECUTIVE

COMMITTEE

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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 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 Chief of Retail Banking.

Member

Nikos V. Salakas

Chief of Corporate Center and General Counsel

He was born in Athens in 1972. He studied Law at the National and Kapodistrian University of Athens and holds a

postgraduate degree (LL.M. in International Business Law) from the University College London. In March 2019, he

joined Alpha Bank as Chief Legal and Governance Officer, after more than twenty years of cooperation with

Koutalidis Law Firm, at which he had been Head of the Banking and Finance Department since 2010. In 2022 he

returned to Koutalidis Law Firm, while taking up the role of Special Legal Counsel to the Board of Directors and the

Executive Committee of the Bank, making, thus, a key contribution to the implementation of critical and strategic

transactions. He has more than 25 years of experience in Greek and International Banking and Regulation,

Finance, Restructuring and Securities Transactions and he is ranked amongst the top Greek lawyers by the

International Financial Law Review (IFLR), the Legal 500 guide and Chambers and Partners. He has supported

Alpha Bank in regulatory issues, M&As, and strategic transactions since 1999. On 1.4.2024 he was appointed Chief

of Corporate Center and General Counsel and Member of the Executive Committee.

MEMBERS OF

THE EXECUTIVE

COMMITTEE

MEMBERS OF

THE EXECUTIVE

COMMITTEE

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

220 |

ANNUAL FINANCIAL REPORT

Member

Sergiu-Bogdan A. Oprescu

Chief of International Network

until 3.11.2024

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 Chief

of International Network.

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

Chief Operating Officer (COO).

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 Chief Human Resources

Officer (CHRO).

MEMBERS OF

THE EXECUTIVE

COMMITTEE

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

221 |

ANNUAL FINANCIAL REPORT

Member

Georgios V. Michalopoulos

Chief Wealth Management Officer

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 Chief Wealth Management Officer.

Member

Vasilis G. Kosmas

Chief Financial Officer (CFO)

He was born in Athens in 1971. He holds a BA in Economics from the Athens University of Economics and Business

(graduated in top 3rd percentile) and an MBA, concentration in Finance from the New York University Leonard N.

Stern School of Business. During his career, he held many positions of responsibility, such as Finance Manager at

Procter & Gamble and Senior Engagement Manager at McKinsey & Company. He served as Director in Structured

Finance and Wholesale Funding as well as Corporate Development and Group Strategy in National Bank of Greece

and as Chief Operating Officer in Ethniki Insurance. Moreover, he worked as Managing Director, Deal Advisory at

KPMG LLP. He was partner at Alantra in London, UK until 15.5.2024. On 23.7.2024 he was appointed Chief

Financial Officer (CFO).

MEMBERS OF

THE EXECUTIVE

COMMITTEE

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

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ANNUAL FINANCIAL REPORT

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 outlines our principles and approach

towards achieving diversity within both our Board of Directors and our Employees. We are committed to adhering

to the legislative and regulatory frameworks currently in force, including the Joint ESMA/EBA "Guidelines on the

assessment of the suitability of members of the management body and key function holders," as well as

embracing European best practices in corporate governance.

In essence, diversity at Alpha Services and Holdings S.A. is defined as the presence of sufficiently varied

characteristics among the Members of the Board of Directors and our Employees. This includes factors such as

age, gender, geographical provenance as well as educational and professional background. Our goal is to ensure

that these differences are significant enough to foster a variety of perspectives and views

within the Board of

Directors and among our Employees.

By promoting diversity, we aim to create a more inclusive and dynamic environment that values and leverages the

unique contributions of each individual. This, in turn, enhances our decision-making processes and ultimately

drives our success as an organization.

Chair

Number of Shares

% of the

share capital

Vassilios E. Psaltis

Chief Executive Officer (CEO)

542,424

0.023

Members

Lazaros A. Papagaryfallou

Deputy CEO

317,780

0.014

Spyros N. Filaretos

(Member of the Executive Committee

until 5.3.2025)

Chief of Growth and Innovation

377,012

0.016

Spiros A. Andronikakis

Chief Risk Officer (CRO)

384,464

0.016

Ioannis M. Emiris

Chief of Wholesale Banking

408,457

0.017

Isidoros S. Passas

Chief of Retail Banking

278,463

0.012

Nikos V. Salakas

Chief of Corporate Center and General

Counsel

101,910

0.004

Sergiu-Bogdan A. Oprescu

(Member of the Executive Committee

until 3.11.2024)

Chief of International Network

153,429

0.007

Stefanos N. Mytilinaios

Chief Operating Officer (COO)

45,272

0.002

Fragiski G. Melissa

Chief Human Resources Officer (CHRO)

96,790

0.004

Georgios V. Michalopoulos

Chief Wealth Management Officer

332,037

0.014

Vasilis G. Kosmas

Chief Financial Officer (CFO)

0.000

NUMBER OF

ALPHA

SERVICES AND

HOLDINGS S.A.

SHARES OWNED

ON 31.12.2024

DESCRIPTION

OF THE

DIVERSITY

POLICY APPLIED

TO THE

MEMBERS OF

THE BOARD OF

DIRECTORS AND

EMPLOYEES

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ANNUAL FINANCIAL REPORT

While the diversity of the Board of Directors is not a criterion for assessing the Members' individual suitability, it is

a vital factor when selecting and evaluating Members of the Board. A diverse Board of Directors brings a broader

range of experiences, knowledge, skills, and values, which enhances its overall functioning and effectively

addresses the phenomenon of "groupthink." By fostering a more diverse Board, we can encourage independent

opinions and constructive challenges during the decision-making process.

The Policy applies not only to the selection procedures for the Board Members but also to the appointment of our

Senior Management and Employees. The key objectives of this Policy are to support and promote diversity across

all levels of our organization. We aim to engage a wide array of qualities and competencies when recruiting Board

Members and Employees, ensuring a variety of views and experiences. This approach facilitates independent

opinions and sound decision-making within the Board of Directors.

Additionally, we are committed to ensuring appropriate gender representation within the Board of Directors and

respecting the principle of equal opportunities during the selection process. This commitment extends to our

Employees, guaranteeing equal treatment and opportunities for individuals of all genders.

The objectives of our Policy are. first and foremost to support and promote diversity within our Board of Directors

and Employees. This means engaging a broad set of qualities and competencies when recruiting. By doing so, we

aim to achieve a variety of views and experiences, which we believe are crucial for facilitating independent

opinions and sound decision-making within the Board.

Moreover, we strive to ensure appropriate representation of all genders within the Board of Directors. This

principle of equal opportunities is paramount when selecting Board Members. Similarly, we are dedicated to

ensuring equal treatment and opportunities for Employees of different genders.

Additionally, when setting diversity objectives, the Company considers diversity benchmarking results published

by competent authorities, such as the European Banking Authority (EBA) or other relevant international bodies or

organizations. This helps us align our goals with best practices and standards in the industry.

Our Policy is approved by the Board of Directors and undergoes a review every two years by the Corporate

Governance, Sustainability and Nominations Committee (CGSNC). The CGSNC may propose relevant amendments

to the Board of Directors, as necessary.

The Company 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, thus reducing the phenomena of “groupthink” and

“herd behavior”.

DESCRIPTION

OF THE

DIVERSITY

POLICY APPLIED

TO THE

MEMBERS OF

THE BOARD OF

DIRECTORS AND

EMPLOYEES

BOARD OF

DIRECTORS

H.1

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ANNUAL FINANCIAL REPORT

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.

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 the 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.

BOARD OF

DIRECTORS

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ANNUAL FINANCIAL REPORT

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 based on 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 31.12.2024)

BOARD OF

DIRECTORS

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ANNUAL FINANCIAL REPORT

The provision of equal opportunities for employment and career advancement to all its Employees is not simply a

statutory requirement for the Company, but a fundamental cornerstone of its Human Resources Strategy.

Consequently, this principle is integrated into the Company’s Human Resources management procedures and

practices, with the Company ensuring their implementation in every country in which it operates.

When setting diversity objectives, the Company considers diversity benchmarking results, published by competent

authorities, the EBA or other relevant international bodies or organizations.

In its commitment to translating gender equality into practice and addressing the underrepresentation of women

in leadership roles, a common challenge in the Greek labor market, the Company has implemented a range of

measures to support Employees in balancing their professional and personal lives. This initiative also promotes

fair treatment and merit-based career advancement, ensuring equal opportunities for the advancement of female

Employees. Furthermore, a variety of training, coaching and mentoring programs have been established to foster

gender equality. The Company is also dedicated to achieving gender diversity within its Senior Management,

reflecting the diversity of its broader workforce.

The Company applies uniform, gender-neutral Remuneration as well as 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 cultivates a work environment free of discrimination and harassment, recognizing and valuing the

contribution and worth of each Employee. It guarantees high-quality working conditions and advancement

opportunities that are grounded in merit ensuring fairness and equality across all levels of the Organization. The

Company offers fair remuneration, based on contracts that align with the conditions of the corresponding

national labor market, ensuring compliance with applicable national regulations, including those related to

minimum wage, working hours and the provision of leave. In order to monitor and minimize diversity gaps, the

Company reviews relevant data on an annual basis and implements corrective measures to narrow gaps, where

these exist.

The Company defends human rights and opposes all forms of child, forced or compulsory labor. It 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.

(data for Alpha Services and Holdings S.A. and Alpha Bank S.A.)

Employees in management positions * as of 31.12.2024 (data for Alpha Services and Holdings S.A. and Alpha

Bank S.A.)

EMPLOYEES

H.2

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227 |

ANNUAL FINANCIAL REPORT

* Management positions are defined as the positions from the level of Branch Manager and above.

** A VSS program was implemented in 2024.

The percentage and the number of Employees in managerial positions per educational level indicate that Employees

in managerial positions holding postgraduate degrees represent in 2024 the highest percentage, i.e. 58%.

To enhance the soft skills of Employees with managerial duties and promote continuous training, the Company has

invested in various training channels and initiatives. Continuous learning is ensured through specialized leadership

journeys and learning paths on the Company’s online platform, as well as soft skills training via ACE Academies’

webinars and eLearnings. In 2024, Alpha Bank launched additional programs for managerial employees as part of the

Leadership Academy. The “Unconscious Bias” Training is aimed at the Bank’s Directors and Managers, helping them

recognize and understand unconscious biases, and mitigate biases, fostering fairness and respect. The “Leading for

Impact” program is an advanced Leadership Development initiative, specifically designed for the Senior Leadership

Team, enhancing leadership skills through interactive workshops, practical experimentation, peer learning, and

coaching sessions. Lastly, within the context of Digital Certification, a tailor-made initiative for Alpha Bank retail

network designed in cooperation with the National Technical University of Athens (NTUA), Branch Managers were

exposed to a hands-on training in digital skills, leading to certification by the NTUA.

EMPLOYEES

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228 |

ANNUAL FINANCIAL REPORT

Our Company's and the Group’s remuneration practices are consistent with the applicable legal and regulatory

framework, as in force, including Law 4261/2014 (which transposed European Directive 2013/36/EU CRD IV), Law

4548/2018, EBA Guidelines on sound remuneration policies, as well as the Bank of Greece Executive Committee’s

Act 231/15.7.2024.

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 24.7.2024, 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-

24072024/eggrafa-gs/politiki-apodoxon-melon-ds-en.pdf.

The Board of Directors’ remuneration is determined by the Company's Ordinary General Meeting of Shareholders,

upon recommendation of the Board of Directors following proposal by the Remuneration Committee.

It is noted that, in accordance with the Company’s standard practice, the Executive Members of the Board of

Directors do not receive any remuneration in their capacity as Members of the Board of Directors. Executive

Members of the Board of Directors participate in the Stock Option Plan and Stock Award Program established by

the Company following the relevant approvals by the Ordinary General Meetings dated 31.7.2020 and 27.7.2023,

respectively.

The Ordinary General Meeting of Shareholders dated 24.7.2024, following the relevant recommendation by the

Board of Directors as per respective recommendation of the Remuneration Committee, approved the

remuneration of the Non-Executive Members of the Board of Directors, including the Independent Non-Executive

Members, in their capacity as Members, for the financial year 2023 and resolved to maintain the annual

remuneration of the Non-Executive Members of the Board of Directors for 2024, including the Independent Non-

Executive Members, at the same level as that of 2023.

It is noted that, due to the fact that the composition of the Board of Directors of Alpha Services and Holdings S.A.

and that of the Board of Directors of its 100% Subsidiary Alpha Bank S.A. are the same, the remuneration of the

Members of the Board of Directors is paid by one company only, specifically, by the Bank.

For more information, please refer to the Remuneration Report, which 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.

REMUNERATION

BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2024

229 |

ANNUAL FINANCIAL REPORT

The Bank acts responsibly when using artificial intelligence systems or other technological means for the

collection and processing of data of its customers, employees, and external partners, by ensuring transparency,

legality, and respect for privacy. Specifically, it is committed to applying strict ethical data management rules,

complying with legislation, and protecting individual rights by adhering to the following key principles for data

usage:

• Legality and Transparency: Data is processed in accordance with relevant legislation, including banking secrecy

laws and personal data protection laws, for clearly defined and transparent purposes. The Bank clearly informs

data subjects about what data is collected, how it is used, and why it is being processed.

• Limitation of purpose: Data is used exclusively for the purposes defined.

• Data Minimization: Only the necessary data for each use is collected.

• Security and Protection: Technical and organizational measures are applied to protect data from unauthorized

access or leakage, as well as to ensure the integrity and availability of the data.

• Accountability: The Bank ensures that all employees and partners comply with the principles of ethical data use

and continuously trains its staff on this matter.

• Outsourcing Data Processing to Third Parties: In cases where data processing is outsourced, the Group uses

only third parties that provide sufficient assurances for the application of applicable legislation and appropriate

technical and organizational measures to protect the data.

• Respect for Data Subjects' Rights: Data is used in a manner that ensures respect for the rights of data subjects,

without discrimination or unfairness. Furthermore, the ability to exercise the rights provided by the relevant

legislation is made available.

• Automated Decision Making: In cases where data processing is done through automated means for decision-

making purposes, the data subject is informed accordingly, their consent is obtained (if required), and the

possibility for human intervention (review of the request) is provided.

• Record Keeping: A Data Processing Activities Log and a Registry of Systems using Artificial Intelligence are

continuously maintained and updated.

• Integration of Key Principles: The protection of data and the rights of data subjects is also ensured through the

relevant Policy Framework and procedures for all stages of any project, whether it involves systems or processes.

Athens, March 6, 2025

THE CHAIRMAN

OF THE BOARD OF DIRECTORS

THE CHIEF

EXECUTIVE OFFICER

DIMITRIS C. TSITSIRAGOS

ID No A 00808440

VASSILIOS E. PSALTIS

ID. No ΑΙ 666591

INFORMATION

ARTICLE 10 OF

LAW 4961/2022

"EMERGING

INFORMATION

AND

COMMUNICATION

TECHNOLOGIES,

STRENGTHENING

DIGITAL

GOVERNANCE,

AND OTHER

PROVISIONS"

TRANSLATION FROM THE ORIGINAL IN THE GREEK LANGUAGE

Independent Auditor’s Limited Assurance Report on Alpha Services and Holdings S.A.’s Sustainability Statement

INDEPENDENT AUDITOR’S LIMITED ASSURANCE REPORT

To the Shareholders of Alpha Services and Holdings S.A.

We have conducted a limited assurance engagement on the consolidated Sustainability Statement of Alpha Services

and Holdings S.A. (henceforth the “Company”) and its subsidiaries (collectively the “Group”), included in section

“FY24 Sustainability Statement” of the consolidated Board of Directors’ Management Report (the “Sustainability

Statement”), for the period from 01/01/2024 to 31/12/2024.

Limited assurance conclusion

Based on the procedures we have performed, as described below in the “Scope of Work Performed” paragraph, and

the evidence we have obtained, nothing has come to our attention that causes us to believe that:

• the Sustainability Statement has not been prepared in all material respects, in accordance with Article 154 of

Law 4548/2018, as amended and in force by Law 5164/2024, based on which, Article 29(a) of EU Directive

2013/34 was transposed into Greek legislation,

• the Sustainability Statement does not comply with the European Sustainability Reporting Standards

(hereinafter “ESRS”), in accordance with EU Regulation 2023/2772 of the Commission of 31 July 2023, and EU

Directive 2022/2464 of the European Parliament and the Council of 14 December 2022,

• the process carried out by the Group to identify and assess material impacts, risks and opportunities (the

“Process”), as set out in Note “Description of the process to identify and assess material impacts, risks and

opportunities” of the Sustainability Statement, does not comply with the “Disclosure Requirement IRO-1-

Description of the process to identify and assess material impacts, risks and opportunities” of ESRS 2 “General

Disclosures”,

• the disclosures included in section “Disclosures pursuant to Article 8 of Regulation 2020/852 (Taxonomy

Regulation)” of the Sustainability Statement, do not comply with Article 8 of EU Regulation 2020/852.

This assurance report does not extend to information in respect of earlier periods.

Basis for conclusion

We conducted a limited assurance engagement in accordance with International Standard on Assurance

Engagements 3000 (Revised), “Assurance Engagements Other than Audits or Reviews of Historical Financial

Information” (“ISAE 3000”).

The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a

reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance

engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance

engagement been performed.

Our responsibilities are further described in the “Auditor’s Responsibilities” section of our report.

Deloitte Certified Public

Accountants S.A.

3a Fragkokklisias & Granikou str.

Marousi Athens GR 151-25

Greece

Tel: +30 210 6781 100

www.deloitte.gr

Professional Ethics and Quality Management

We are independent of the Company, during the whole period of this engagement and we have complied with the

requirements of the International Code of Ethics for Professional Accountants issued by the International Ethics

Standards Board for Accountants (IESBA Code), the ethical and independence requirements of Law 4449/2017 and

EU Regulation 537/2014.

Our audit firm applies the International Standard on Quality Management 1 (ISQM 1), “Quality Management for

firms that perform audits or reviews of financial statements, or other assurance or related services engagements”

and accordingly, maintains a comprehensive system of quality management, including documented policies and

procedures regarding compliance and ethical requirements, professional standards and applicable legal and

regulatory requirements.

We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion.

Management’s responsibilities regarding the Sustainability Statement

Management of the Company is responsible for designing and implementing a process to identify the information

reported in the Sustainability Statement, in accordance with ESRS, and for disclosing this Process in Note

“Description of the process to identify and assess material impacts, risks and opportunities” of the Sustainability

Statement.

This responsibility includes:

• Understanding the context in which the Company’s and the Group’s activities and business relationships take

place and developing an understanding of its affected stakeholders.

• The identification of the actual and potential impacts (both negative and positive) related to sustainability

matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the

Company’s and the Group’s financial position, financial performance, cash flows, access to finance or cost of

capital over the short, medium, or long-term.

• The assessment of the materiality of the identified impacts, risks and opportunities related to sustainability

matters by selecting and applying appropriate thresholds, and

• Making assumptions that are reasonable in the circumstances.

Management of the Company is further responsible for the preparation of the Sustainability Statement, in

accordance with Article 154 of Law 4548/2018, as amended and in force by Law 5164/2024, based on which, Article

29(a)

of EU Directive 2013/34 was transposed into Greek legislation.

In this context, Management’s responsibility includes:

• Compliance of the Sustainability Statement with ESRS.

• Preparing the disclosures in section “Disclosures pursuant to Article 8 of Regulation 2020/852 (Taxonomy

Regulation)” of the Sustainability Statement, in compliance with Article 8 of EU Regulation 2020/852.

• Designing implementing and maintaining such internal controls that management determines are necessary

to enable the preparation of the Sustainability Statement is free from material misstatement, whether due to

fraud or error, and

• The selection and application of appropriate sustainability reporting methods and making assumptions and

estimates about individual sustainability disclosures that are reasonable in the circumstances.

The Audit Committee of the Company is responsible for overseeing the sustainability reporting process of the Group.

Inherent limitations in preparing the Sustainability Statement

As discussed in Notes “Entity-Specific Information” and “CONTRIBUTION TO HEALTHY ECONOMIES” in the

Sustainability Statement, sustainability information for which the applicable criteria are self-defined, the nature of

this sustainability information, and absence of consistent external standards, allow for different, but acceptable,

measurement methodologies to be adopted which may result in variances between entities. The adopted

measurement methodologies may also impact the comparability of sustainability matters reported by different

entities and from year to year within an entity as methodologies develop.

In reporting forward-looking information in accordance with ESRS, Management of the Company is required to

prepare the forward-looking information on the basis of disclosed assumptions about events that may occur in the

future and possible future actions by the Company and the Group. The actual outcome is likely to be different since

anticipated events frequently do not occur as expected.

As discussed in Note “ESRS E1 CLIMATE CHANGE”, the sustainability information includes, among others, information

based on climate-related scenarios, that is subject to inherent uncertainty regarding the likelihood, timing or effect

of possible future physical and transitional climate-related impacts.

Our work covered the subject matters listed in the section “Scope of Work Performed” for obtaining limited

assurance and is based on the procedures included in the Program, as defined in this section of our report. Our work

does not constitute an audit or review of historical financial information in accordance with the applicable

International Standards on Auditing or International Standards on Review Engagements, and for this reason, we do

not provide any other assurance beyond what is stated in the section “Scope of Work Performed”.

Auditor’s responsibilities

This limited assurance report has been prepared based on the provisions of Article 154C of Law 4548/2018 and

Article 32A of Law 4449/2017.

Our responsibility is to plan and perform the limited assurance engagement to obtain limited assurance about

whether the Sustainability Statement is free from material misstatement, whether due to fraud or error and to issue

a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are

considered material when, individually or in the aggregate, they could reasonably be expected to influence the

economic decisions of users taken on the basis of the Sustainability Statement as a whole.

As part of a limited assurance engagement in accordance with ISAE 3000, we exercise professional judgment and

maintain our professional skepticism throughout the engagement.

Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:

• Performing risk assessment procedures, including obtaining an understanding of internal controls relevant to

the engagement, to identify risks in the Process applied by the Group to identify the information reported in

the Sustainability Statement does not address the applicable requirements of the ESRS, but not for the

purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process

and

• Designing and performing procedures to evaluate whether the Process to identify the information reported in

the Sustainability Statement is consistent with the Company’s description of its Process as disclosed in Note

“Description of the process to identify and assess material impacts, risks and opportunities”.

In addition, we are responsible for:

• Performing risk assessment procedures, including obtaining an understanding of internal control relevant to

the engagement, to identify disclosures where material misstatements are likely to arise, whether due to

fraud or error, but not for the purpose of providing a conclusion on the effectiveness of the Group’s internal

controls.

• Designing and performing procedures responsive to disclosures in the consolidated Sustainability Statement,

where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting

from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional

omissions, misrepresentations, or the override of internal controls.

Scope of the Work Performed

Our work involves performing procedures and obtaining audit evidence to form a limited assurance conclusion and

are limited to the procedures listed in the limited assurance program issued by the Hellenic Accounting and Auditing

Supervisory Oversight Board according to its 262/22.01.2025 decision (hereinafter the “Program”), developed for

the purpose of issuing of a limited assurance report on the Group’s Sustainability Statement.

Our procedures were designed for the purpose of obtaining a limited level of assurance to support our conclusion

but not for obtaining evidence that would be required to provide a reasonable level of assurance.

Athens, 6 March 2025

The Certified Public Accountant

Dimitris Katsibokis

Reg. No SOEL: 34671

Deloitte Certified Public Accountants S.A.

3a Fragoklissias & Granikou Str.

15125 Marousi

Reg. No SOEL: E120

This document has been prepared by Deloitte Certified Public Accountants Societe Anonyme.

Deloitte Certified Public Accountants Societe Anonyme, a Greek company, registered in Greece with registered number 0001223601000 and its registered office at

Marousi, Attica, 3a Fragkokklisias & Granikou str., 151 25, is one of the Deloitte Central Mediterranean S.r.l. (“DCM”) countries. DCM, a company limited by guarantee

registered in Italy with registered number 09599600963 and its registered office at Via Tortona no. 25, 20144, Milan, Italy is one of the Deloitte NSE LLP geographies.

Deloitte NSE LLP is a UK limited liability partnership and member firm of DTTL, a UK private company limited by guarantee.

DTTL and each of its member firms are legally separate and independent entities. DTTL, Deloitte NSE LLP and Deloitte Central Mediterranean S.r.l. do not provide

services to clients. Please see www.deloitte.com/about to learn more about our global network of member firms.

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 2024, and the separate

and consolidated income statement, statements of 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 2024, 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 €

38,638 million for the Group as at 31 December 2024

(31.12.2023: € 35,916 million) and allowance for

expected credit losses amounted to € 601 million, as at

31 December 2024 (31.12.2023: € 842 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 (the “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 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 models.

Management has provided further information about

accounting policies for determining the ECL on loans at

amortized cost and management of credit risk in noted

1.2.13, 1.3, 11, 23 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 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 models

- the selection of macro-economic scenarios and probability

weightings.

- accuracy and completeness of data used in models.

For specific of the above controls we further tested whether

they operated effectively.

• We assessed the design and implementation of relevant

controls over the ECL measurement of credit impaired

exposures 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 and for selected

controls we further tested whether they operated effectively .

• With the support of our financial risk modelling specialists we:

- assessed the appropriateness of the Group’s IFRS9

impairment policies and 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 the Significant Increase in Credit Risk (SICR)

or the Unlikeness to Pay (UTP) trigger and other criteria

used for staging allocation. On a sample basis, assessed the

timely identification of SICR, UTP and other criteria used

for staging allocation;

- inspected the 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 external market sources.

• We further performed substantive procedures to test the

accuracy and completeness of critical data used in the

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 accuracy and completeness of post model

adjustments, made by management in order to

incorporate the impact of the uncertainty in the economic

environment in specific loans, not captured by the models.

In addition, we assessed any contradictory evidence and

performed retrospective review.

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

Fair Value Measurement and Classification of Investments in UniCredit Romania and Alpha Bank Romania in the context of

Project Unicorn

In the context of Project Unicorn, on 4 November 2024, the

Group completed the sale of its 90.1% stake holding in Alpha

Bank Romania to UniCredit S.p.A. As an exchange the Group

received an amount of € 254 million in cash and 9.9% stake

holding in UniCredit Romania. As of 31.12.2024 the Group

has recognized in «Investments in associates and joint

ventures” the 9.9% of its stake holding in Alpha Bank

Romania and the acquired 9.9% of its stake holding in

UniCredit Romania at their fair value of € 58 million and

€ 272 million, respectively.

Fair value measurement and classification of the investments

in UniCredit Romania and Alpha Bank Romania is considered

a key audit matter, as the accounting treatment involves high

degree of management judgement and significant

accounting estimates.

The most significant management judgements and

accounting estimates, relate to:

• Methods, assumptions, terms and market data used

for the determination of the fair value of the two

investments in Romania as of the date of the sale.

• Assessment of the “significant influence” exercised by

the Group on the aforementioned entities in order for

management to determine the classification at initial

recognition and the accounting treatment of these

investments, in accordance with the relevant

provisions of IFRS.

Management has provided further information in notes

1.2.1, 1.3, 25 and 52 to the consolidated financial

statements.

Based on our risk assessment and following a risk-based

approach, we have evaluated the judgments and 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 completion of sale to

UniCredit S.p.a.of the 90.1% of the Group stake holding

in Alpha Bank Romania in the context of “Unicorn

project”, including internal controls over the review and

approval process of the completion of the sale

transaction as well as over the classification and

measurement of the investments in Alpha Bank Romania

and UniCredit Romania.

• We obtained the fair value exercise of UniCredit

Romania, performed in the context of Project Unicorn by

a third party and with the assistance of our fair value

specialists, we assessed the reasonableness of the

assumptions used, and appropriateness of the fair value

method applied. In addition, we tested the accuracy of

the data included in the calculations.

• We assessed whether, management has properly

measured and classified Group Investments (9.9% stake

holding in UniCredit Romania and its 9.9% stake holding

in Alpha Bank Romania), and in specific whether the

Group exercise significant influence on each investment,

are in accordance with the provisions of the relevant

IFRS. In addition, we tested the accuracy and

completeness of the relevant accounting journal entries.

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 € 4,815

million as at 31 December 2024, (€ 4,978 million as at 31

December 2023).

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 1.2.15, 1.3, 17 and 29 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.

• With the support of our tax specialists, 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.

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’ Management Report, referred to in

the section “Report on Other Legal and Regulatory Requirements” and the Statement by the Members of the Board

of Directors, but does not include the separate and consolidated financial statements and our auditor’s report

thereon.

Our opinion on the separate and consolidated financial statements does not cover the other information and we will

not express any form of assurance conclusion thereon.

In connection with our audit of the separate and consolidated financial statements, our responsibility is to read the

other information and, in doing so, consider whether the other information is materially inconsistent with the

separate and consolidated financial statements, or our knowledge obtained in the audit, or otherwise appears to be

materially misstated. If, based on the work we have performed, we conclude that there is a material misstatement

in this other information, we are required to report that fact. We have nothing to report in this regard.

Responsibilities of Management and Those Charged with Governance for the separate and consolidated financial

statements

Management is responsible for the preparation and fair presentation of the separate and consolidated financial

statements in accordance with IFRSs, as endorsed by the European Union, and for such internal control as

management determines is necessary to enable the preparation of separate and consolidated financial statements

that are free from material misstatement, whether due to fraud or error.

In preparing the separate and consolidated financial statements, management is responsible for assessing the

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.

• Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial

information of the entities or business units within the Group as a basis for forming an opinion on

consolidated financial statements. We are responsible for the direction, supervision and review of the audit

work performed for the purposes of the group audit. We remain solely responsible for our audit opinion.

We communicate with those charged with governance regarding, among other matters, the planned scope and

timing of the audit and significant audit findings, including any significant deficiencies in internal control that we

identify during our audit.

We also provide those charged with governance with a statement that we have complied with relevant ethical

requirements regarding independence and communicate with them all relationships and other matters that may

reasonably be thought to impair our independence, and where applicable, related safeguards applied.

From the matters communicated with those charged with governance, we determine those matters that were of

most significance in the audit of the separate and consolidated financial statements of the current year and are

therefore the key audit matters.

Report on other Legal and Regulatory Requirements

1. Board of Directors’ Management Report

Taking into consideration that management is responsible for the preparation of the Board of Directors’

Management Report which also includes the Corporate Governance Statement, according to the provisions

of paragraph 1, sub paragraphs aa), ab) and b) of article 154C of Law 4548/2018, which however do not

include the Sustainability Statement, for which we have issued a related limited assurance report according

to International Standard on Assurance Report 3000 (Revised) dated 6 March 2025, we note the following:

a) The Board of Directors’ Management 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’ Management Report has been prepared in accordance with

the applicable legal requirements of articles 150 and 153 of Law 4548/2018, except for the

provisions relating to the submission of the Sustainability Statement of paragraph 5A of article 150

of this Law, and its content is consistent with the accompanying separate and consolidated

financial statements for the year ended 31 December 2024.

c) Based on the knowledge we obtained during our audit of the Company and the Group and its

environment, we have not identified any material inconsistencies in the Board of Directors’

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 we have provided to the Company

and the Group during the year ended 31 December 2024 are disclosed in notes 28 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 eight 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

Subject Matter

We have undertaken the reasonable assurance work to examine the digital archives of Alpha Services and

Holdings S.A. (the Company or/and the Group), which has been prepared in accordance with the European

Single Electronic Format (ESEF), Including the separate and consolidated financial statements of the

Company and the Group for the year ended 31 December 2024, in XHTML format, as well as the envisaged

XBRL file (5299009N55YRQC69CN08-2024-12-31-en.zip) with the appropriate tagging on the above

consolidated financial statements, including the notes to the financial statements(the Subject Matter), in

order to conclude whether they been prepared in accordance with the requirements set out in the section

Applicable Criteria.

Applicable Criteria

The Applicable Criteria for the European Single Electronic Format (ESEF) are laid down in European

Commission Delegated Regulation (EU) 2019/815, as amended by Regulation (EU) 2020/1989 (the ESEF

Regulation) and 2020/C 379/01 European Commission interpretative communication of 10 November

2020, as provide by Law 3556/2007 and the related announcements of the Securities and Exchange

Commission and the Athens Stock Exchange. In summary, these criteria provide, inter alia, that:

- Annual financial reports should be prepared in XHTMB 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, total comprehensive income, statement of changes in equity and statement of

cash flows as well as financial information included in the notes to these financial statements shall be

tagged with XBRL mark-up (“XBRL tags” and “block tags”) in accordance with ESEF Taxonomy, as

currently in force. The technical specifications of ESEF, including the related taxonomy, are included

in ESEF Regulatory Technical Standards.

Responsibilities of 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 2024, in accordance

with the Applicable Criteria, as well as for such internal control as management determines is necessary to

enable the preparation of digital files free from material misstatement, whether due to fraud or error.

Αuditor’s Responsibilities

Our responsibility is to issue this report in relation to the assessment of the Subject Matter, based on the

work performed, as described below in the section “Scope of work performed”.

Our work has been conducted in accordance with International Standard on Assurance Engagements 3000

(revised) “Assurance engagements other than audits or review of historical financial information (ISAE

3000).

ISAE 3000 requires that we plan and perform our work so as to obtain reasonable assurance to assess the

Subject Matter in accordance with the Applicable Criteria. In the course of the assurance engagement we

assess the risk of material misstatement in the information relating to the Subject Matter.

We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our

reasonable assurance opinion, as set out in this report.

Professional Ethics and Quality Management

We have been independent of the Company and the Group during the whole period of our assignment and

have comply with the requirements of of the Code of Conduct for professional Auditors of the Board of

International standards of Conduct for Auditors (Code of Ethics), the ethical and independence

requirements of Law 4449/2017 and Regulation (EU) 537/2014.

Our auditing firm implements the International Quality Management Standard (ISQM) 1 ‘Quality

Management for companies that perform audits or reviews of financial statements or other assurance or

related service assignments’ and therefore maintains an integrated quality management system that

includes documented policies and procedures related to compliance with ethical requirements,

professional standards and applicable legal and regulatory requirements.

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.

Scope of work performed

The assurance work performed, is limited to the items included in the Decision No 214/4/11-02-2022 of the

Board of Hellenic Accounting and Auditing Oversight Board (HAASOB) and the “Guidelines in connection

with the procedures and the assurance report of the certified auditors on the ESEF reported of Issuers with

trading securities on a regulated market in Greece” dated 14/02/2022, as issued by the Institute of

Certified Public Accountants, in order to obtain reasonable assurance about whether the separate and

consolidated financial statements of the Company and the Group, prepared by management, comply in all

material respects with the Applicable Criteria.

Inherent Limitations

Our work covered the items mentioned in the section "Scope of work performed" so as to obtain

reasonable assurance based on the procedures described therein. In this context, the work performed

could not provide an absolute assurance that all matters that could be considered as material weaknesses

are revealed.

Conclusion

On the basis of the work performed and the evidence obtained, we conclude that the separate and

consolidated financial statements of the Company and the Group, for the year ended 31 December 2024,

in XHTML format as well as the envisaged XBRL file (5299009N55YRQC69CN08-2024-12-31-en.zip) with the

appropriate tagging on these consolidated financial statements, including the notes, are prepared in all

material respects in accordance with the Applicable Criteria.

Athens, 6 March 2025

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

244 | ANNUAL FINANCIAL REPORT

Group Financial Statements as at 31.12.2024

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

245 | ANNUAL FINANCIAL REPORT

The attached notes (pages 251-398) form an integral part of these consolidated financial statements

Consolidated Income Statement

(Amounts in millions of Euro)

From 1 January to

Note

31.12.2024

31.12.2023 as restated

Interest and similar income

4,408

3,582

Interest expense and similar charges

(2,763)

(1,923)

Net interest income

1,645

1,659

- of which: net interest income based on the effective interest rate

1,730

1,734

Fee and commission income

480

433

Commission expense

(60)

(59)

Net fee and commission income

420

374

Dividend income

Gains less losses on derecognition of financial assets measured at amortised cost

(17)

Gains less losses on financial transactions

Other income

Total income from banking operations

2,222

2,129

Staff costs

(370)

(333)

General administrative expenses

(317)

(325)

Depreciation and amortization

26,27,28

(179)

(157)

Total expenses

(866)

(815)

Impairment losses and provisions to cover credit risk

(360)

(381)

Expenses relating to credit risk management

(93)

(88)

Impairment losses on fixed assets and equity investments

(15)

(19)

Gains/(Losses) on disposal of fixed assets and equity investments

Provisions

(85)

(46)

Transformation costs

(14)

(4)

Share of profit/(loss) of associates and joint ventures

Profit/(loss) before income tax

816

780

Income tax

(219)

(226)

Net profit/(loss) from continuing operations after income tax

597

554

Net profit/(loss) after income tax from discontinued operations

Net profit/(loss) for the year

654

618

Net profit/(loss) attributable to:

Equity Holders of the Company

654

618

- from continuing operations

597

554

- from discontinued operations

Non-controlling interests

Earnings/(losses) per share:

Basic (€ per share)

0.2619

0.2531

Basic (€ per share) from continuing operations

0.2374

0.2256

Basic (€ per share) from discontinued operations

0.0245

0.0275

Diluted (€ per share)

0.2616

0.2528

Diluted (€ per share) from continuing operations

0.2371

0.2253

Diluted (€ per share) from discontinued operations

0.0245

0.0275

* Certain figures of the previous year have been restated as described in note 2.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

246 | ANNUAL FINANCIAL REPORT

The attached notes (pages 251-398) form an integral part of these consolidated financial statements

Consolidated Statement of Comprehensive Income

(Amounts in millions of Euro)

From 1 January to

Note

31.12.2024

31.12.2023 as restated

Net profit/(loss), after income tax, recognized in the Income Statement

654

618

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

Net change in cash flow hedge reserve

Foreign currency translation net of investment hedges of foreign operations

Income tax

(7)

(16)

Items that may be reclassified subsequently to the Income Statement from continuing operations

Items that may be reclassified subsequently to the Income Statement from discontinued operations

Items that will not be reclassified to the Income Statement

Remeasurement of defined benefit liability/ (asset)

(2)

Gains/(losses) from investments in equity securities measured at fair value through other comprehensive income

(13)

Income tax

(3)

Items that will not be reclassified to the Income Statement from continuing operations

(9)

Other comprehensive income, after income tax, for the year

Total comprehensive income for the year

724

694

Total comprehensive income for the period attributable to:

Equity holders of the Company

724

694

-from continuing operations

615

598

-from discontinued operations

109

Non controlling interests

* Certain figures of the previous year have been restated as described in note 2.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

247 | ANNUAL FINANCIAL REPORT

The attached notes (pages 251-398) form an integral part of these consolidated financial statements

Consolidated Balance Sheet

(Amounts in millions of Euro)

Note

31.12.2024

31.12.2023 as restated

ASSETS

Cash and balances with central banks

2,998

4,219

Due from financial institutions

2,296

1,572

Trading securities

Derivative financial assets

628

727

Loans and advances to customers

39,050

36,161

Investment securities

- Measured at fair value through other comprehensive income

24a

1,009

1,369

- Measured at amortized cost

24b

16,420

14,490

- Measured at fair value through profit or loss

24c

167

159

Investments in associates and joint ventures

570

100

Investment property

290

301

Property, plant and equipment

534

501

Goodwill and other intangible assets

438

467

Deferred tax assets

4,815

4,978

Other assets

808

945

70,076

66,022

Assets classified as held for sale

1,999

6,399

Total Assets

72,075

72,421

LIABILITIES

Due to banks

6,533

6,921

Derivative financial liabilities

793

934

Due to customers

51,032

48,449

Debt securities in issue and other borrowed funds

3,208

2,920

Liabilities for current income tax

Deferred tax liabilities

Employee defined benefit obligations

Other liabilities

895

919

Provisions

161

120

62,733

60,316

Liabilities related to assets classified as held for sale

1,153

4,782

Total Liabilities

63,886

65,098

EQUITY

Equity attributable to holders of the Company

Share capital

682

Share premium

4,784

4,783

Other Εquity Ιnstruments

700

400

Reserves

(93)

(111)

Amounts directly recognized in equity and are associated with assets classified as held for sale

(14)

(64)

Retained earnings

2,175

1,626

Less: Treasury shares

(61)

(11)

8,173

7,305

Non-controlling interests

Total Equity

8,189

7,323

Total Liabilities and Equity

72,075

72,421

* Certain figures of the previous year have been restated as described in note 2.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

248 | ANNUAL FINANCIAL REPORT

The attached notes (pages 251-398) form an integral part of these consolidated financial statements

Consolidated Statement of Changes in Equity

(Amounts in millions of Euro)

Note

Capital

Treasury

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 Equity

Balance 1.1.2023

681

(1)

5,259

296

(273)

283

6,245

6,263

Profit/(loss) for the year, after income tax

618

Other comprehensive income for the year,

after income tax

Total comprehensive income for the year,

after income tax

624

694

Share Capital Increase through options

exercise

(3)

Offsetting of Retained Earnings

(479)

(296)

(1)

776

Transfer of cumulative income and expenses

recognised directly in equity that relate to

assets classified as held for sale

(64)

(3)

Valuation reserve of employee stock option

program

Reserve valuation for stock awards

Payment of AT1 dividend, after income tax

(24)

Sales and purchases of treasury shares

(10)

(9)

AT1 Capital instrument Issuance

400

(6)

394

Appropriation of reserves

(24)

Dividend distribution

(1)

Other

(1)

Balance 31.12.2023

682

(11)

4,783

400

(111)

(64)

1,626

7,305

7,323

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

249 | ANNUAL FINANCIAL REPORT

The attached notes (pages 251-398) form an integral part of these consolidated financial statements

(Amounts in millions of Euro)

Note

Capital

Treasury

premium

Other Equity

Instruments

Reserves

Amounts directly recognized in equity

and associated with assets classified as

held for sale

Retained

earnings

Total

Non-controlling

interests

Total Equity

Balance 1.1.2024

682

(11)

4,783

400

(111)

(64)

1,626

7,305

7,323

Profit/(loss) for the year, after income tax

654

Other comprehensive income for the year, after

income tax

(8)

Total comprehensive income for the year, after

income tax

646

724

Share Capital Increase through options exercise

(1)

Shares awarded to employees, after expenses

(6)

Transfer of cumulative income and expenses

recognised directly in equity that relate to assets

classified as held for sale

(3)

Valuation reserve of employee stock option

program

Sale of subsidiary

(42)

Payment of AT1 dividend,

(48)

Sales and purchases of treasury shares

(56)

(55)

AT1 Capital instrument Issuance

300

(4)

296

Appropriation of ordinary reserve

(37)

Dividend distribution

(61)

(Acquisitions)/Disposals/Other changes of

ownership interest in subsidiaries

(2)

Other

Balance 31.12.2024

682

(61)

4,784

700

(93)

(14)

2,175

8,173

8,189

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

250 | ANNUAL FINANCIAL REPORT

The attached notes (pages 251-398) form an integral part of these consolidated financial statements

Consolidated Statement of Cash Flows

(Amounts in millions of Euro)

From 1 January to

Note

31.12.2024

31.12.2023 as restated

Cash flows from continuing operating activities

Profit/(loss) before income tax from continued operations

816

780

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

134

107

Impairment losses, provisions to cover credit risk and related expenses

504

528

Gains less losses on derecognition of financial assets measured at amortised cost

(31)

Fair value (gains)/losses on financial assets measured at fair value through profit or loss

(61)

(Gains)/losses from investing activities

(552)

(512)

(Gains)/losses from financing activities

257

244

Share of (profit)/loss of associates and joint ventures

(1)

1,140

1,275

Net (increase)/decrease in assets relating to continuing operating activities:

Due from financial institutions

(484)

(42)

Trading securities and derivative financial instruments

Loans and advances to customers

(3,213)

(621)

Other assets

(44)

128

Net increase/(decrease) in liabilities relating to continuing operating activities:

Due to banks

(388)

(7,142)

Due to customers

2,583

1,181

Other liabilities

(261)

(97)

Net cash flows from continuing operating activities before income tax

(619)

(5,229)

Income tax paid

(15)

Net cash flows from continuing operating activities

(634)

(5,229)

Net cash flows from discontinued operating activities

(176)

(128)

Cash flows from continuing investing activities

Proceeds from disposals of subsidiaries

300

369

Dividend Received

Investments in associates and joint ventures

(56)

Acquisitions of investment property, property, plant and equipment and intangible assets

25,26,27

(153)

(150)

Disposals of investment property, property, plant and equipment and intangible assets

Interest received from investment securities

363

249

Purchases of Greek Government Treasury Bills

(1,665)

(2,056)

Proceeds from disposal and redemption of Greek Government Treasury Bills

2,062

1,964

Purchases of investment securities (excluding Greek Government Treasury Bills)

(4,214)

(4,544)

Disposals/maturities of investment securities (excluding Greek Government Treasury Bills)

2,440

1,366

Net cash flows from continuing investing activities

(902)

(2,783)

Net cash flows from discontinued investing activities

(21)

(117)

Cash flows from continuing financing activities

Share Capital Increase and Amounts intended for Share Capital Increase

AT 1 issuance

296

394

Payments for AT1 issuance

(48)

(24)

Proceeds from issue of debt securities and other borrowed funds

977

614

Repayments of debt securities in issue and other borrowed funds

(769)

(533)

Interest paid on debt securities in issue and other borrowed funds

(178)

(126)

Payments of lease liabilities

(18)

(28)

Dividend payments

(61)

(1)

Treasury Shares

(55)

(8)

Net cash flows from continuing financing activities

144

289

Net cash flows from discontinued financing activities

(3)

116

Effect of foreign exchange changes on cash and cash equivalents

Net increase/(decrease) from continuing cash flows

(1,388)

(7,721)

Changes in cash equivalent from discontinued operations

(200)

(129)

Cash and cash equivalents at the beginning of the year from continuing operations

4,434

12,155

Cash and cash equivalents at the end of the year from continuing operations

3,046

4,434

* Certain figures of the previous year have been restated as described in note 2.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

251 | ANNUAL FINANCIAL REPORT

Notes to the Consolidated Financial Statements

GENERAL INFORMATION

The Alpha Services and Holding Group, (hereinafter the “Group”), which includes companies in Greece and abroad, offers the following

services: corporate and retail banking, financial services, investment banking and brokerage services, insurance services, real estate

management, hotel services.

On 16 April 2021, the demerger by way of hive-down of the banking business sector of Alpha Bank S.A. (the “Demerged”) was completed and

its core banking operations were contributed into a new company – credit institution which was registered under G.E.M.I. on the same date

under the name “Alpha Bank S.A.” (the “Beneficiary”). Specifically, Alpha Bank S.A substituted the Demerged as universal successor, in all of its

assets and liabilities within the banking business sector transferred to it, as these are included in the Transformation balance sheet of

30.6.2020 and were formed until 16.4.2021, the completion date of the demerger.

The “Demerged” by assuming the 100% of the issued shares of Alpha Bank S.A., becomes the parent entity of the bank and its subsdiaries

(Alpha Bank 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.”

As a result of the above it is noted that in the notes to the Financial Statements “Alpha Bank” (the “Demerged”) and “Alpha Services and

Holdings S.A.” will be mentioned as “the Company”, while “Alpha Bank S.A.” after the demerger will lbe mentioned as “the Bank”.

The Company’s business scope is:

a. the direct and indirect participation in domestic and/or foreign companies and undertakings that already exist or will be established, of

any form and objective whatsoever,

b. the design, promotion and distribution of insurance products in the name and on behalf of one or more insurance undertakings in the

capacity of insurance agent in accordance with the applicable legislation,

c. the provision of supporting accounting and tax services to affiliated companies and third parties as well as the elaboration of studies on

strategic and financial management and

d. the issuance of securities for raising regulatory capital, which are expected to have the form of debit/credit titles.

The corporate name and distinctive title of the Company were established as “Alpha Sevices and Holdings S.A.” and “Alpha Sevices and

Holdings” respectively. The Company has its registered office at 40 Stadiou Street, Athens and is listed in the General Commercial Register with

registration number 223701000 (ex societe anonym registration number 6066/06/B/86/05). Its duration has been set until 2100 and can be

extended following a decision of the General Assembly.

On 18.1.2022 the Company was granted a licence to operate as a Financial Holdings Company by the European Central Bank.

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.

The composition of the Board of Directors as at December 31, 2024, is as follows:

CHAIR (Non-Executive Member) INDEPENDENT NON-EXECUTIVE MEMBERS Vasileios T. Rapanos Elli M. Andriopoulou */**** EXECUTIVE MEMBERS Aspasia F. Palimeri **/*** Vassilios E. Psaltis, CEO Panagiotis I. – K. Papazoglou */*** Spyros N. Filaretos, Chief of Growth and Innovation Dimitris K. Tsitsiragos **/*** NON- EXECUTIVE MEMBERS Jean L. Cheval */** Efthimios O. Vidalis ***/**** Elanor R. Hardwick **/**** Johannes Herman Frederik G. Umbgrove */***/**** Diony C. Lebot **/**** SECRETARY Eirini E. Tzanakaki * Member of the Audit Committee ** Member of the Risk Management Committee *** Member of the Remuneration Committee **** Member of Corporate Governance, Sustainability and Nominations Committee

From 1.1.2025, Chair of the Board of Directors is appointed Mr. D. C. Tsitsiragos following the resignation of Mr. V. T. Rapanos.

Since 27.2.2025, following the resignations of Messrs. Spyros Filaretos and Efthimios Vidalis, the Board of Directors elected Mr. Lazaros

Papagaryfallou in replacement of the Executive Member Mr. Spyros Filaretos and Ms. Annalisa Areni as Non-Executive Member of the Board of

Directors of the Company, in replacement of the Non-Executive Member Mr. Efthimios Vidalis.

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 CEO Act,

delegating powers and authorities to the Committee.

Indicatively, the main responsibilities of the Committee include, but are not limited to the following:

The Executive 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,

- prepares and submits for approval by the Board of Directors the annual and interim Financial Statements,

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

252 | ANNUAL FINANCIAL REPORT

- 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,

- reviews and approves, in the framework of its authorities, the Company’s Policies 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 Human Resources for the Staff (including any bonus schemes, voluntary separation schemes, etc.).

Furthermore, the Committee 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, (iii) an adequate and effective

framework for the implementation of the Company’s strategy on ESG issues, (iv) the selection and suitability assessment process for Key

Function Holders, (v) the amounts, types and distribution of both internal capital and regulatory capital to adequately cover the risks of the

Company, (vi) the means for achieving targets for the liquidity management of the Company 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.

The composition of the Executive Committee as at December 31, 2024 consisted of:

CHAIR

Vassilios E. Psaltis, Chief Executive Officer (CEO)

MEMBERS

Lazaros A. Papagaryfallou, Deputy CEO

Spyros N. Filaretos, Chief of Growth and Innovation (until 5.3.2025)

Spiros Α. Andronikakis, Chief Risk Officer (CRO)

Ioannis Μ. Emiris, Chief of Wholesale Banking

Isidoros S. Passas, Chief of Retail Banking

Nikos V. Salakas, Chief of Corporate Center and General Counsel

Stefanos N. Mytilinaios, Chief Operating Officer (COO)

Fragiski G. Melissa, Chief Human Resources Officer (CHRO)

Georgios V. Michalopoulos, Chief Wealth Management Officer

Vasilis G. Kosmas, Chief Financial Officer (CFO)

There has been no change in the composition of the Executive Committee from 31.12.2024 and until the publication date of the financial

report, with the exception of Mr Spyros N. Filaretos who resigned on 5.3.2025.

The share of 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 Bank’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 2024 were

2,352,977,294 ordinary, registered, voting, dematerialized shares with a face value of each equal to € 0.29. During the year 2024, the average

daily volume of the share per session was € 9.

The present Consolidated financial statements of the Company have been approved by the board of directors on 6th March 2025.

Commission Delegated Regulation (EU) 2019/815, as amended by Regulation (EU) 2020/1989 introduces the obligation for issuers of securities

traded on a regulated EU market to prepare the annual financial report in HTML format, in accordance with the European Single Electronic

Format. For the year ended 31.12.2024 the consolidated financial statements, included in the annual financial report, have been marked with

XBRL tags (XBRL ‘tags’), according to the ESEF Taxonomy (ESEF Taxonomy), using the Inline XBRL (“iXBRL” specifications).

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

253 | ANNUAL FINANCIAL REPORT

1. Accounting policies applied

1.1 Basis of presentation

The financial statements for the current period ending at 31.12.2024 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 Group in preparing the financial statements are the same as those stated in the published financial

statements for the year ended on 31.12.2023, 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 1.1.2024, for which further analysis is provided in note

1.1.2.

It is also noted that:

• During the second quarter of the current year the accounting treatment of the AT1 interest was re-evaluated and as it was estimated that

the payment of said interest constitutes in essence distribution of profits relevant income tax will be recognized in profit or loss at the

time of interest payment. This treatment was applied retrospectively for the August 2023 and February 2024 payments of the instrument

issued by the Bank (note 2).

• During the third quarter of the current year, the terms of the agreements governing derivatives cleared in Central Counterparties through

Clearing Members were reassessed and it was estimated that the IAS 32 offsetting criteria are met for derivative assets and liabilities

arising from those agreements as well as for the related cash collateral exchanged. The change in the presentation of those financial

instruments in order to be presented net in the balance sheet was applied retrospectively (note 2).

The financial statements have been prepared on the historical cost basis except for specific financial instruments measured at fair value either

through profit or loss or through other comprehensive income.

The financial statements are presented in Euro, rounded to the nearest million, unless otherwise indicated. Any differences between the

amounts presented in the primary financial statements and the relevant amounts presented in the accompanying notes are due to rounding.

1.1.1 Going concern

The financial statements as at 31.12.2024 have been prepared based on the going concern principle. 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 macroeconomic environment is characterized by uncertainty, which is mainly caused by the following:

•

Geopolitical developments and inflationary pressures, and in particular the continuation and outcome of the war in Ukraine and the

tensions in the Middle East and the Red Sea. Despite the recent ceasefire in Gaza, a possible re-escalation of the conflict between Israel

and Iran could trigger a new energy crisis and consequently inflationary pressures, especially if Iranian oil facilities are affected.

•

The risks for the Greek economy arising from possible natural disasters or any impacts of climate change, such as the extreme weather

events that have affected various regions of the country in recent years.

•

Political instability in major European countries and important trading partners of Greece such as France and Germany, as well as the

effects of USA policy with the possible increase in trade protectionism, which are likely to have a negative impact on the external sector of

the Greek economy in the coming years.

However, despite the fact that the economic environment is characterized by uncertainty, the Greek economy is expected to remain resilient,

achieving high GDP growth rates (between 2% and 2.5%) in the two years 2024-2025, supported by the continued strengthening of

employment, tourism performance, the gradual normalization of inflationary pressures, the implementation of investments both within the

framework of the Recovery and Resilience Fund and the Public Investment Program, as well as the expected increase in Foreign Direct

Investment (FDI) and exports.

Liquidity

The Group's liquidity levels are particularly satisfactory, as evidenced by the liquidity ratios (liquidity coverage ratio and net stable liquidity

ratio) which remain at high levels and significantly exceed the regulatory limits set (note 47.3), the stress tests for liquidity purposes

conducted internally, which demonstrate that the Bank remains viable in all scenarios, as well as the annual update of the Recovery Plan,

completed in September 2024, which showed that the Bank is able to respond even to particularly adverse liquidity crisis scenarios. Finally, in

2024, the credit rating agency Moody's upgraded, among other things, the Bank's long-term senior debt rating to Investment Grade,

confirming its potential to achieve higher sustainable profitability, while improving the resilience of its balance sheet.

Capital Adequacy

The Group, due to the strong profitability of the year and the successful completion of the planned bond issues, maintains a strong capital

base from both a financial and regulatory perspective, while the MREL ratio provides an adequate buffer against the interim MREL

requirements that must be met from 30.6.2025 (note 48).

Strategic Plan

Taking into account the actions taken in the context of the implementation of the Group's strategic plan as well as the fact that so far the goals

that had been set have been achieved, a significant improvement in profitability and qualitative structure of the balance sheet is expected, as

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well as the creation of capital, which ensure the availability of the required resources for the continuation of the Group's activities and its

further development.

Based on the above, the Board of Directors estimates that these financial statements have been prepared on the going concern basis.

1.1.2 Adoption of new standards and of amendments to existing standards

The following are the new standards and the amendments to standards applied from 1.1.2024:

Amendment to International Financial Reporting Standard 16 “Leases”: Lease liability in a sale and leaseback (Regulation

2023/2579/20.11.2023)

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. 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 adoption of the above amendment had no impact on the financial statements of the Group.

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)

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.

•

The amendments clarify that 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.

The adoption of the above amendment had no impact on the financial statements of the Group since in it’s balance sheet liabilities are not

classified as current and non-current.

Amendment to the International Accounting Standard 1 “Presentation of Financial Statements”: Non-current liabilities with covenants

(Regulation 2023/2822/19.12.2023)

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.

The adoption of the above amendment had no impact on the financial statements of the Group since in it’s balance sheet liabilities are not

classified as current and non-current.

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 (Regulation 2024/1317/15.5.2024)

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. Also, IFRS 7 was amended to include access to such agreements with third finance providers in the liquidity risk

disclosures.

The adoption of the above amendments had no impact on the financial statements of the Group.

In addition, the European Union has adopted the following amendment to IAS 21 which is effective for annual periods beginning after 1.1.2024

and has not been early adopted by the Group.

Amendment to the International Accounting Standard 21 “The Effects of Changes in Foreign Exchange Rates”: Lack of exchangeability

(Regulation 2024/2862/12.11.2024)

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 Group is examining the impact from the adoption of the above amendment on its financial statements.

In addition, the International Accounting Standards Board has issued the following standards and amendments to standards which have not

been endorsed yet by the European Union and which have not been early applied by the Group.

Amendment to International Financial Reporting Standard 7 “Financial Instruments: Disclosures” and to International Financial Reporting

Standard 9 “Financial Instruments”: Amendments to the Classification and Measurement of Financial Instruments

Effective for annual periods beginning on or after 1.1.2026

On 30.5.2024 the International Accounting Standards Board issued amendments to IFRS 7 and IFRS 9 to address matters identified during the

post-implementation review of IFRS 9 regarding classification and measurement of financial instruments. More specifically, the amendments

clarify issues relating to the derecognition of a financial liability settled through electronic matter and the assessment of whether the cash

flows of a financial asset are solely payments of principal and interest while they provide for disclosures for equity instruments measured at fair

value through other comprehensive income and contractual terms that could change the timing or amount of contractual cash flows on the

occurrence of a contingent event.

The Group is examining the impact from the adoption of the above amendments on its financial statements.

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Amendment to International Financial Reporting Standard 7 “Financial Instruments: Disclosures” and to International Financial Reporting

Standard 9 “Financial Instruments”: Contracts Referencing Nature-dependent Electricity

Effective for annual periods beginning on or after 1.1.2026

On 18.12.2024, the International Accounting Standards Board issued an amendment to IFRS 9 to specify the factors that should be considered

to determine whether contracts referencing nature-dependent electricity are within its scope and under what conditions a contract for nature

dependent renewable electricity can be designated as a hedging instrument. IFRS 7 was also amended to include disclosures regarding such

contracts.

The Group is examining the impact from the adoption of the above amendments on its financial statements

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 align the accounting

treatment of a transaction of sale or contribution of assets between an investor and its associate or joint venture

The Group 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.

It is noted that European Union has decided not to launch the endorsement of this standard and to wait for the final standard.

The above standard does not apply to the financial statements of the Group.

International Financial Reporting Standard 18 “Presentation and Disclosure in Financial Statements”

Effective for annual periods beginning on or after 1.1.2027

On 9.4.2024 the International Accounting Standards Board issued IFRS 18. IFRS 18 replaces IAS 1 and sets out presentation and disclosure

requirements for financial statements.

To meet this objective, IFRS 18 introduces:

•

two new defined subtotals in the statement of profit or loss: operating profit and profit before financing and income taxes,

•

disclosures about management-defined performance measures (“MPM’s”), and

•

enhanced requirements for grouping of information (aggregation and disaggregation) in the financial statements.

IFRS 18 requires that a company presents income and expenses in separate operating, investing and financing categories. The operating

category consists of all income and expenses that are not classified in the investing, financing, income taxes or discontinued operations

categories.

The Group is examining the impact from the adoption of the above standard on its financial statements.

International Financial Reporting Standard 19 “Subsidiaries without Public Accountability: Disclosures”.

Effective for annual periods beginning on or after 1.1.2027

On 9.5.2024 the International Accounting Standards Board issued IFRS 19. IFRS 19 specifies reduced disclosure requirements that an eligible

entity (it is subsidiary, does not have public accountability and has an ultimate or intermediate parent that publishes IFRS consolidated financial

statements) is permitted to apply instead of the disclosure requirements in other IFRS Accounting Standards.

The above standard does not apply to the financial statements of the Group.

Annual Improvements – Volume 11

Effective for annual periods beginning on or after 1.1.2026

As part of the annual improvements project, the International Accounting Standards Board issued on 18.7.2024 non-urgent but necessary

amendments to IFRS 1, IFRS 7, IFRS 9, IFRS 10 and IAS 7.

The Group is examining the impact from the adoption of the above amendments on its financial statements.

1.2 Material accounting policies

1.2.1 Basis of consolidation

The consolidated financial statements include the parent company Alpha Services and Holdings, its subsidiaries, associates and joint ventures.

The financial statements used to prepare the consolidated financial statements have been prepared as at 31.12.2024 and the accounting

policies applied in their preparation, when necessary, were adjusted to ensure consistency with the Group accounting policies.

a. Subsidiaries

Subsidiaries are entities controlled by the Group.

The Group takes into account the following factors, in assessing control:

•

power over the investee,

•

exposure, or rights, to variable returns from its involvement with the investee, and

•

the ability to use its power over the investee to affect the amount of the investor’s return.

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Power arises from currently exercisable rights that provide the Group with the current ability to direct the relevant activities of the investee. In

a straightforward case, rights that provide power are derived from voting rights granted by equity instruments such as shares. In other cases,

power results from contractual arrangements.

The Group’s returns are considered variable, when these returns have the potential to vary as a result of the investee’s performance. Variability

of returns is judged based on the substance of the arrangement, regardless of their legal form.

The Group, in order to evaluate the link between power and returns, assesses whether it exercises its power for its own benefit or on behalf of

other parties, thus acting as either a principal or an agent, respectively. If the Group determines that it acts as a principal, then it controls the

investee and consolidation is required. Otherwise, control does not exist and there is no requirement to consolidate.

In cases where the power over an investee arises from voting rights, the Group primarily assesses whether it controls the investee through

holding more than 50% of the voting rights. However, the Group can have power even if it holds less than 50% of the voting rights of the

investee, through:

•

a contractual arrangement between the investors and other vote holders,

•

rights arising from other contractual arrangements,

•

the size of the investor’s holding of voting rights relative to the size and dispersion of holdings of the other vote holders,

•

potential voting rights.

In cases of structured entities where the voting rights relate to administrative tasks only and the relevant activities are directed by means of

contractual arrangements (i.e. securitization vehicles or mutual funds), the Group assesses the existence of control based on the following:

•

the purpose of the entity and the contractual rights of the parties involved,

•

the risks to which the investee was designed to be exposed, the risks it was designed to pass on to the parties involved with the investee

and the degree of exposure of the Group to those risks,

•

indications of a special relationship with the entity, which suggests that the Group has more than a passive interest in the investee.

The Group, based on the above criteria, controls structured entities established for the securitization of loan portfolios.

The Group reassess whether it controls an investee if facts and circumstances indicate that there are changes to one or more of the elements

of control.

The financial statements of subsidiaries are fully consolidated from the date that control commences until the date that control ceases.

The acquisition method is applied when the Group obtains control of other companies or units that meet the definition of a business.

Application of the acquisition method requires identifying the acquirer, determining the acquisition date and measuring the consideration

transferred, the identifiable assets acquired, the liabilities assumed and any non controlling interest in the acquiree, in order to determine the

amount of goodwill or gain arising from the business combination.

The consideration transferred is measured at fair value on acquisition date.

The identifiable assets acquired and liabilities assumed are initially recognised on acquisition date at their fair value, except from specific assets

or liabilities for which a different measurement basis is required. Any non controlling interests are recognised at either fair value or at their

proportionate share in the acquiree’s identifiable net assets, as long as they are present ownership interests and entitle their holders to a

proportionate share of the entity’s net assets in the event of liquidation. Otherwise, they are measured at their acquisition date fair values.

Any difference between:

•

the sum of the consideration transferred, the fair value of any previously held equity interest of the Group in the acquiree and the amount

of any non – controlling interests, and

•

the net of the acquisition date amounts of the identifiable assets acquired and the liabilities assumed,

is recognised as goodwill if the above difference is positive or as a gain in profit or loss if the difference is negative.

During the measurement period, the provisional amounts recognized at the acquisition date are adjusted in order to reflect new information

obtained about facts and circumstances that existed as of the acquisition date and, if known, would have affected the measurement of the

amounts recognized as of that date. These adjustments affect accordingly the amount of goodwill. The measurement period ends as soon as

the information about facts and circumstances existed as of the acquisition date has been obtained. However, the measurement period shall

not exceed one year from the acquisition date.

When the Group’s interest in a subsidiary increases as a result of an acquisition, the difference between the consideration paid and the share of

net assets acquired is recognized directly in retained earnings.

Sales of ownership interests in subsidiaries that do not result in a loss of control for the Group are accounted for as equity transactions and the

gain or loss arising from the sale is recognized directly in retained earnings.

Intercompany transactions are eliminated, unless the transaction provides evidence of impairment of the asset transferred, in which case, it is

recognized in the consolidated balance sheet.

b. Associates

Associates are entities over which the Group has significant influence but not control. Significant influence is generally presumed to exist when

the Group holds, directly or indirectly, more than 20% of the share capital of the company concerned without having control or joint control,

unless the ownership of more than 20% does not ensure significant influence, e.g. due to lack of representation of the Group in the company’s

Board of Directors or due to the Group’s non-participation in the policy making process. Additionally, significant influence may exist when less

than 20% of the share capital is held, when the Group participates in the process of formulating the company's policies through its participation

in its Board of Directors and when, based on the shareholders' agreement, there is the possibility of exercising a veto on significant decisions.

Investments in associates are accounted for using the equity method of accounting. The investment is initially recognised at cost and adjusted

thereafter for the post acquisition change in the Group’s share of net assets of the associate. In case the losses according to the equity method

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exceed the investment in ordinary shares, they are recognized as a reduction of other elements that are essentially an extension of the

investment in associate.

The Group’s share of the associate’s profit or loss and other comprehensive income is separately recognized in the income statement and in the

statement of comprehensive income, accordingly.

c. Joint ventures

The Group applies IFRS 11 which deals with the accounting treatment of interests in joint arrangements. All joint arrangements in which the

Group participates and has joint control are joint ventures, which are accounted for by using the equity method.

A detailed list of all Group subsidiaries, associates and joint ventures, as well as the Group’s ownership interest in them, is provided in note 44.

1.2.2 Operating Segments

Operating segments are determined and measured based on the information provided to the Executive Committee of the parent Company of

the Group, which is the body responsible for the allocation of resourses between the Group’s operating segments and the assessment of their

performance.

Based on the above, and given the Group’s administrative structure and activities, the following operating segments have been determined:

•

Retail

•

Wholesale

•

Wealth Management

•

International

•

Non Performing Assets

•

Corporate Center

Since the Group operates in various geographical areas, apart from the operating segments identified above, the financial statements contain

information based on the below distinction:

•

Greece

•

Other Countries

It is noted that the methods used to measure operating segments for the purpose of reporting to the Executive Committee are not different

from those required by the International Financial Reporting Standards.

Detailed information relating to operating segments is provided in note 46.

1.2.3 Transactions in foreign currency and translation of foreign operations

a. Transactions in foreign currency

The consolidated financial statements are presented in Euro, which is the functional currency and the currency of the country of incorporation

of the parent company of the Group.

Items included in the financial statements of the subsidiaries are measured in the functional currency of each subsidiary which is the currency

of the company’s country of incorporation or the currency used in the majority of the transactions held.

Transactions in foreign currencies are translated into the functional currency of each subsidiary 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.

b. Translation of foreign operations

The financial statements of all group entities that have a functional currency that is different from the presentation currency of the Group

financial statements are translated as follows:

•

Assets and liabilities are translated to Euro at the closing rate applicable on the balance sheet date.

•

Income and expense items are translated to Euro at average exchange rates applicable for each period presented.

The resulting exchange difference from the retranslation and those arising from other monetary items designated as a part of the net

investment in the entity are recorded in equity. When a foreign entity is sold, the exchange differences are reclassified to the income statement

as part of the gain or loss on sale.

1.2.4 Cash and cash equivalents

For the purposes of the consolidated cash flow statement, cash and cash equivalents consists of:

•

Cash on hand

•

Non-restricted balances with Central Banks and

•

Short-term balances due from banks and Reverse Repo agreements

Short-term balances due from banks are those that upon initial recognition mature within three months.

Non-restricted placements with Central Banks, short-term balances due from banks and Reverse Repo agreements are measured at amortised

cost.

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1.2.5 Classification and measurement of financial instruments

Initial recognition

The Group 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 Group 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 on 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 Group classifies its financial assets as:

a. Financial assets measured at amortised cost

b. Financial assets measured at fair value through other comprehensive income, with gains or losses reclassified in profit or loss on

derecognition

c. Equity instruments measured at fair value through other comprehensive income, with no reclassification in gains or losses to profit or

loss on derecognition

d. Financial assets measured at fair value through profit or loss.

For each of the above categories the following apply:

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 note 1.2.13.

Cash and balances with central banks, due from financial institutions, loans and advances to customers that meet the above criteria and

investment securities measured at amortized cost are included in this category.

Due from financial institutions include receivables arising from the transactions of the Treasury business area with credit institutions and

related companies that are not governed by loan agreements.

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 a 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 note 1.2.13.

Investment securities measured at fair value through other comprehensive income are included in this category.

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 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 Group 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.

In particular, this category includes loans and advances to customers that are not measured at amortized cost, investment securities measured

at fair value through profit or loss and derivative financial assets.

•

those the Group 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 Group had not designated, at initial recognition, any financial assets as at fair value through profit or loss.

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Business Model assessment

The business model reflects how the Group manages its financial assets in order to generate cash flows. That is, the Group’s business model

determines whether cash flows will result from collecting contractual cash flows, selling financial assets or both. The Group’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.

The business models of the Group are determined by the Asset Liability Committee (ALCO) or the Executive Committee (ExCo) which decide on

the determination of the business model both for the loans and advances to customers and the securities portfolio. In this context:

•

For loans and advances to customers the Group 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) and

•

Business model whose objective is the sale of financial instruments which is applied only to syndicated loans that the Group grants in

order to sell them.

•

Due from financial institutions are included in the business model whose objective is to hold financial assets in order to collect contractual

cash flows (hold to collect)

•

For bonds and in general for fixed income investments, the Group 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 classification in the above business models is carried out at the level of the individual business units/companies based on the framework

set at the group level and after an assessment of the way financial instruments are managed by the business units/companies.

The Group, 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

within specific criteria of significance and frequency. It is noted that the sales of non-performing exposures that take place due to the

deterioration of the borrowers' credit rating, with the exception of those created by the Group and characterized as credit impaired upon initial

recognition, do not affect the hold to collect business model.

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.

In this context, in assessing whether contractual cash flows are SPPI, the Group assesses whether the instrument contains contractual terms

that change the timing or amount of contractual cash flows such as conversion to equity terms and terms based on which the performance of

the instruments is affected by equity or commodity prices.

Especially in the case of financing of a special purpose vehicle, in order for the loan to meet the criterion that its cash flows are solely

payments of principal and interest on the principal amount outstanding the Group takes into account factors such as the capital structure of

the debtor and the LTV (Loan to Value) ratio.

In addition, in determining whether contractual cash flows are solely payments of principal and interest on the principal amount outstanding, it is

assessed whether time value of money element has been modified. The time value of money element does not provide consideration for other

risks or costs associated with holding the financial asset. However, in some cases, the time value of money element may be modified. That would

be the case, for example, if a financial asset’s interest rate is periodically reset but the frequency of that reset does not match the tenor of the

interest rate or if a financial asset’s interest rate is periodically reset to an average of particular short- and long-term interest rates. In such cases,

the Group assesses the modification to determine whether the contractual cash flows represent solely payments of principal and interest on the

principal amount outstanding. The objective of the assessment is to determine how different the contractual (undiscounted) cash flows could be

from the (undiscounted) cash flows that would arise if the time value of money element was not modified (benchmark test). The effect of the

modified time value of money element must be considered in each reporting period and cumulatively over the life of the instrument. If the Group

concludes that the contractual (undiscounted) cash flows could be significantly different (based on specified limits) from the (undiscounted)

benchmark cash flows, the contractual cash flows are not solely payments of principal and interest on the principal amount outstanding.

Reclassification of financial assets

Reclassifications of financial assets between measurement categories occur when, and only when, the Group 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 Group that lead to the reclassification of financial assets are

expected to be rare. They arise from decisions of the Asset Liability Committee (ALCO) or 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.

Derecognition of financial assets

The Group derecognizes financial assets when:

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•

the contractual rights to the assets cash flows expire,

•

the contractual right 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.

In the case of transactions where despite the transfer of the contractual right to receive the cash flows from financial assets both the risk and

rewards remain with the Group, no derecognition of these financial assets occurs. The amount received by the transfer is recognized as a

financial liability. The accounting practices followed by the Group in such transactions are discussed in notes 1.2.20 and 1.2.21.

In the case of transactions, whereby the Group neither retains nor transfers risks and rewards of the financial assets, but retains control over

them, the financial assets are recognized to the extent of the Group’s continuing involvement. If the Group does not retain control of the assets

then they are derecognised, and in their position the Group recognizes, distinctively, the assets and liabilities which are created or retained

during the transfer. No such transactions occurred upon balance sheet date.

In case of a change in the contractual terms of a financial asset, when the change is considered significant it results in the derecognition of the

original financial asset and the recognition of a new one. Significant modifications that lead to derecognition include criteria such as, for

example, a change in issuer/borrower and a change in currency.

In case of derecognition due to significant modification, the difference between the carrying amount of the original asset and the fair value of

the new asset is directly recognized in the Income Statement, as specifically mentioned in notes 1.2.26 and 1.2.27. Additionally, in case the

original asset was measured at fair value through other comprehensive income, the cumulative gains or losses recognized in other

comprehensive income are transferred to profit or loss.

In contrast, if the change in contractual cash flows is not significant, the gross carrying amount of the asset is recalculated by discounting new

contractual cash flows with the original effective interest rate and the difference compared to the current gross carrying amount is directly

recognized in profit or loss (modification gain or loss) in the line item “Impairment losses and provisions to cover credit risk”. Fees related to the

modification adjust the carrying amount of the asset and are amortised over the remaining term of the modified financial asset through the

effective interest method.

Subsequent measurement of financial liabilities

The Group 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,

•

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 1.2.6.

•

This category also includes financial liabilities which are designated by the Group 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 group is provided

internally on that basis to the Group’s key management personnel;

•

Finally, this category includes contracts containing one or more embedded derivatives and the Group measures the compound financial

instruments as financial liabilities measured at fair value through profit or loss.

It is noted that in the above case, the amount of the change in fair value attributable to the Group’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 reclassified to profit or loss.

As at the reporting date, the Group had not designated, at initial recognition, any financial liabilities as at fair value through profit or loss.

b. Financial liabilities carried at amortised cost

Liabilities to credit institutions and customers, debt securities issued by the Group and other loan liabilities are classified in this category.

The liabilities classified in this category are measured at amortised cost using the effective interest method.

In cases when financial liabilities included in this category are designated as the hedged item in a hedge relationship, the accounting principles

applied are those set out in note 1.2.6.

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 a 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 (note 1.2.13),

•

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

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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 Group, if the transferred asset is measured at amortised cost or

•

Equal to the fair value of the rights and obligations retained by the Group 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 amount are reported net on the balance sheet, only in cases when the Group 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.

1.2.6 Derivative financial instruments and hedge accounting

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).

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.

All derivatives are recognized as assets when their fair value is positive and as liabilities when their fair value is negative.

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 1.2.5.

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.

The Group uses derivatives as a means of exercising Asset-Liability management within the guidelines established by the Asset-Liability

Committee (ALCO).

Valuation differences arising from derivatives are recognized in “Gains less losses on financial transactions” except when derivatives participate

in hedging relationships in which case the principles for hedge accounting mentioned below apply.

It is noted that the Group uses FX swaps in order to economically hedge the exposures arising from customer loans and deposits.

The result arising from these derivatives is recognized as interest and foreign exchange differences, in order to match with the interest element

and foreign exchange differences resulting from the deposits and loans, and as other gains less losses on financial transactions.

Hedge accounting

Hedge accounting establishes the valuation rules to offset the gain or loss of the fair value of a hedging instrument and a hedged item which

would not have been possible if the normal measurement principles were applied. It is noted that the Group has opted to continue to apply the

provisions for hedge accounting of IAS 39.

Documentation of the hedging relationship upon inception and of the effectiveness of the hedge on an on-going basis are the basic

requirements for the adoption of hedge accounting.

The hedge relationship is documented upon inception and the hedge effectiveness test is carried out upon inception and is repeated at each

reporting date.

A hedge is regarded as highly effective only if both of the following conditions are met:

•

at the inception of the hedge and in subsequent periods the hedge is expected to be highly effective in achieving offsetting changes in fair

value or cash flows attributable to the hedged risk during the period for which the hedge is designated,

•

the actual results of the hedge are within a range of 80%-125%.

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The main causes that may lead to hedging ineffectiveness are the following:

•

The credit risk (counterparty risk) of the hedging instruments used to hedge interest rate or currency risk, which is minimized by using

derivatives with high credit rating counterparties

•

The timing difference in the cash flows of the hedging instruments and the hedged items.

A hedging relationship is disccontinued prospectively when:

•

the hedging instrument expires, sold, terminated or excercised,

•

the hedge ceases to be effective (in this case the discontinuation is applied from the last date the effectiveness criteria were met),

•

the Group revokes the designation,

•

the forecast transaction (in case of a hedge of a forecast transaction) is no longer expected to occur.

a. Fair value hedges

A fair value hedge of a financial instrument offsets the change in the fair value of the hedged item in respect of the risks being hedged.

The Group uses interest rate swaps (IRS’s) to hedge risks relating to borrowings, deposits, loans and bonds. For all interest rate risk hedging

relationships, the Group defines at the inception of the relationship the reference interest rate related to the hedged risk (euro interest rate)

and calculates the changes in the fair value of the hedged instrument as changes in the euro interest rate curve.

Changes in the fair value of both the hedging instrument and the hedged item, in respect of the specific risk being hedged, are recognized in

the income statement.

When the hedging relationship no longer exists, the hedged items continue to be measured based on the classification and valuation principles

set out in note 1.2.5. Specifically any adjustment, due to the fair value change of a hedged item for which the effective interest method is used,

up to the point that the hedging relationship ceases to be effective, is amortised to interest income or expense based on a recalculated

effective interest rate, over its remaining life.

Especially with regard to deposits, it is noted that the Group applies interest rate risk hedge accounting on a deposit portfolio using the hedge

accounting provisions adopted by the European Union (EU Carve-out)

b. Cash flow hedge

A cash flow hedge changes the cash flows of a financial instrument from a variable rate to a fixed rate.

The Group defines at the inception of the hedging relationship the reference interest rate related to the hedged risk (euro interest rate) and

measures the changes in the fair value of the hedging instrument and a hypothetical derivative in relation to changes in the euro interest rate

curve. The floating leg of the hypothetical derivative simulates the cash flows of the hedged item while the cash flows of the fixed leg are

defined in a way that makes the valuation of the hypothetical derivative zero at the inception of the hedge.

The effective portion of the gain or loss on the hedging instrument is recognized directly in other comprehensive income, in cash flow hedge

reserve, whereas the ineffective portion is recognized in Gains less losses on financial transactions. The accounting treatment of the hedged

item does not change.

When the hedging relationship is discontinued, the amount recognized in equity remains there separately until the cash flows or the future

transaction occur. When the cash flows or the future transaction occur the following apply:

•

If the result is the recognition of a financial asset or a financial liability, the amount is reclassified to profit or loss in the same periods

during which the hedged forecast cash flows affect profit or loss.

•

If the result is the recognition of a non-financial asset or a non-financial liability or a firm commitment for which fair value hedge

accounting is applied, the amount recognized in equity either is reclassified to profit or loss in the same periods during which the asset or

the liability affect profit or loss or adjusts the carrying amount of the asset or the liability.

When a forecasted transaction or the expected cash flows are no longer expected to occur, the cumulative gain or loss that was recognized in

equity is reclassified to profit or loss. In particular, the amount that has been recognized in equity, as a result of revoked cash flow hedging

relationships for term deposits, is linearly amortised as interest expense in the periods during which the hedged cash flows from the

aforementioned term deposits affect profit or loss.

c. Hedges of net investment in a foreign operation

The Group, following the decision of the Asset-Liability Committee (ALCO), uses foreign exchange derivatives, mainly cross currency interest

rate swaps and foreign exchange swaps, to hedge foreign exchange risks arising from investment in foreign operations. To hedge the currency

risk of the net investment in a foreign operation, the net assets are measured at the current exchange rate and the resulting exchange

differences are compared with the exchange differences of the derivative.

Hedge accounting of net investment in a foreign operation is similar to cash flow hedge accounting. The cumulative gain or loss recognized in

equity is reversed and recognized in profit or loss, at the time that the disposal of the foreign operation takes place.

1.2.7 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 Group 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.

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 cashflows, discount rates, probability of counterparty default and prepayments.

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In all cases, the Group uses the assumptions that ‘market participants’ would use when pricing the asset or liability, assuming that market

participants act in their economic best interest.

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 Group, to the extent that relevant observable inputs are not available

In particular, the Group applies the following:

Financial instruments

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 Group takes into consideration the effect of credit risk. Specifically, for derivative contracts, the Group

estimates the credit risk of both counterparties (bilateral credit valuation adjustments).

The Group measures fair value for all assets and liabilities separately. Regarding derivative exposures, however, that the Group 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.

Non- financial assets and liabilities

The most important category of non- financial assets for which fair value is estimated is real estate property.

The process, mainly, followed for the determination of the fair value is summarized below:

•

Assignment to the engineer - valuer

•

Case study- Setting of additional data

•

Autopsy - Inspection

•

Data processing - Calculations

•

Preparation of the valuation report

To derive the fair value of the real estate property, the valuer chooses among the three following valuation techniques or a combination of two

of them in cases required by the special characteristics of the property or in cases that special conditions prevail such as for example an energy

crisis:

•

Market approach (or sales comparison approach), which measures the fair value by comparing the property to other identical ones for

which information on transactions is available.

•

Income approach, which capitalizes future cash flows arising from the property using an appropriate discount rate.

•

Cost approach, which reflects the amount that would be required currently to replace the asset with another asset with similar

specifications, after taking into account the required adjustment for impairment.

Examples of inputs used to determine the fair value of properties and which are analysed to the individual valuations, are the following:

•

Commercial property: price per square meter, rent growth per annum, long-term vacancy rate, discount rate, expense rate of return, lease

term, rate of non leased properties/units for rent.

•

Residential property: Net return, reversionary yield, net rental per square meter, rate of continually non leased properties/units, expected

rent value per square meter, discount rate, expense rate of return, lease term etc.

•

General assumptions such as the age of the building, residual useful life, square meter per building etc are also included in the analysis of

the individual valuation assessments.

It is noted that the fair value measurement of a property takes into account a market’s participant 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 it’s highest and best use.

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1.2.8 Property, Plant and Equipment

This caption includes: land, buildings used by branches or for administrative purposes, additions and improvements of leased property and

equipment. It also includes right of use assets in case those assets are used by the Group (the accounting policies applicable to those assets are

presented in note 1.2.11).

Property, plant and equipment are initially recognised at cost which includes any expenditure directly attributable to the acquisition of the

asset.

Subsequently, property, plant and equipment are 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.

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 property, plant and equipment and it is calculated on the

asset’s cost minus residual value.

Under the Group policy, the estimated useful lives are as follows:

•

Buildings:

•

commercial properties with office / shop use and residential properties:

• up to 50 years for properties with high criteria for construction - reconstruction - renovation and which are characterized as

sustainable. In some cases, for newly built properties with very high criteria and construction elements, the useful life can reach

70 years.

• up to 45 years for the remaining properties that do not meet the above characteristics.

•

for industrial - craft and other commercial properties:

• up to 45 years for properties with high criteria for construction - reconstruction - renovation and which are characterized as

sustainable.

• up to 40 years for the remaining properties that do not meet the above characteristics.

•

embedded mechanical equipment: up to 25 years.

•

Additions to leased fixed assets and improvements: duration of the lease

•

Equipment and vehicles: up to 33 years

Land is not depreciated but is tested for impairment.

The residual value of property and equipment and their useful lives are periodically reviewed and adjusted if necessary at each reporting date.

Property, plant and equipment are 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 property, plant and equipment as well as when no economic benefits are expected for the Group, 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.

1.2.9 Investment property

The Group includes in this category buildings or portions of buildings together with their respective portion of land that are held for the

purpose of long-term lease or for capital appreciation. The Group has also included in this category right of use assets when the Group is an

intermediate lessor in an operating lease (the accounting policies applicable to those assets are presented in note 1.2.11).

Investment property is initially recognised at cost which includes any expenditure directly attributable to the acquisition of the asset.

Subsequently investment property 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 and can be measured

reliably. All costs for repairs and maintenance are recognized in profit or loss as incurred.

The estimated useful lives over which depreciation is calculated using the straight line method are the same as those applied to property, plant

and equipment.

Transfers to and from the category of investment property are made when the property meets (or ceases to meet) the definition of investment

property and there is evidence of change in its use. In particular, the property is reclassified in “Property, plant and equipment” if the Group

decides to use it while it is reclassified in the category of property held for sale if a decision is taken to sell it and if the criteria referred to in

paragraph 1.2.16 are met. Conversely, for property not classified within “Investment Property”, the commencement of its lease constitutes a

proof of change of use and may lead to the reclassification to investment property.

In case of sale of investment property as well as when no economic benefits are expected for the Group, 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.

1.2.10 Goodwill and other intangible assets

Goodwill

Positive goodwill 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. Goodwill on acquisitions of associates or joint ventures is included in “Investment in associates and

joint ventures”.

Negative goodwill is recognized in profit or loss.

Other intangible assets

The Group has included in this caption:

a. Intangible assets which are recognized from business combinations or which are individually acquired. These intangible assets include the

value attributed to the acquired customer relationships and to deposit bases. Intangible assets arising from business combinations are initially

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measured at fair value while those individually acquired are initially measured at cost. Subsequently, they are depreciated, using the straight

line method, during their useful life, and are assessed for impairment when there are triggers for impairment.

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 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

during its useful life which has been set from 1 to 15 years.

Regarding internally generated software, the Group 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, using the straight line method, 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 1.2.14).

No residual value is estimated for intangible assets.

In case of sale of an intangible asset the intangible asset is derecognised, while when no economic benefits are expected for the Group, 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.

1.2.11 Leases

The Group enters into leases either as a lessee or as a lessor. At inception, the Group assesses whether a contract is or contains a lease.

The lease term is determined as the non-cancellable period of a lease, together with both periods covered by an option to extend the lease if

the lessee is reasonably certain to exercise that option and periods covered by an option to terminate the lease if the lessee is reasonably

certain not to exercise that option.

a. When the Group is the lessor

When the risks and rewards incident to ownership of an asset are transferred to the lessee they are classified as finance leases.

All other lease agreements are classified as operating leases:

i. Finance leases:

For finance leases where the Group is the lessor the present value of lease payments is recognized as loans and advances.

The difference between the present value (net investment) of lease payments and the aggregate amount of lease payments is recognized as

unearned finance income and is deducted from loans and advances.

The finance lease receivables are subject to the same impairment testing as applied to customer loans and advances as described in note

1.2.13.

ii. Operating leases:

When the Group is a lessor of assets under operating leases, the leased asset is recognized and depreciation is charged over its estimated

useful life. Income arising from the leased asset is recognized as other income on an accrual basis.

b. When the Group is the lessee

The Group, as a lessee, for all leases recognizes a right of use asset and a lease liability at the commencement of the lease. The right of use

asset is initially measured at cost, comprising the initial lease liability amount, any initial direct costs and an estimate of the obligation for costs

to refurbish the asset, less any lease incentives received.

Right-of use assets are subsequently measured at cost less any accumulated depreciation, any accumulated impairment losses and adjusted for

any remeasurement of the lease liability.

Depreciation is charged on a straight line basis from the commencement date to the earlier of the end of the useful life of the right-of-use asset

or the end of the lease term. Right-of-use assets are reviewed at each reporting date 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

(note 1.2.14).

For short-term leases (lease term of 12 months or less) and leases for which the underlying asset is of low value (less than 5.000 EUR when

new) the Group does not recognize a right-of-use asset and a lease liability but instead recognizes the lease payments as an expense on a

straight-line basis over the lease term.

The lease liability is initially measured at the present value of lease payments that are not paid at that date, net of cash lease incentives. Lease

payments are discounted using the lessee’s incremental borrowing rate. Incremental borrowing rate is determined by using as reference rate

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the estimated cost of Alpha Bank’s secured funding rate, adjusted for different currencies and taking into consideration government yield

curves, where applicable.

After the commencement date, the Group measures the lease liability by increasing the carrying amount to reflect interest, reducing the

carrying amount to reflect lease payments made and remeasuring the carrying amount to reflect any reassessment or lease modifications.

In case of a sale and leaseback transaction only the amount related to the rights that have been transferred to the buyer-lessor is recognized in

profit or loss.

Right of use assets are included within Property, plant and equipment and the lease liability is included in Other liabilities. In cases where the

Group is an intermediate lessor in an operating lease, right of use assets recognized for the head lease are included within Investment property

while in case the Group is an intermediate lessor in a finance lease right of use asset, or the part of it which is subleased, is derecognized and a

finance lease receivable is recognized.

Specifically for the Bank, the duration of the professional lease contracts is defined in most cases for three years, with the possibility of

unilateral extension in some of them by the Bank for an additional period of time. The Bank decides whether to make use of this option by

evaluating current conditions, with the Bank retaining the right to terminate the lease at any time during the term of the contract. The Bank's

policy is to renew these contracts if it wishes to remain in the properties.

Finally, in the leases of premises for the Off Site ATM operation, their duration, in their majority, is set at one or two years and if they are

renewed, as the contract provides for their conversion to an indefinite period, it is estimated that the duration of the lease will be ten years.

1.2.12 Insurance activities

a. Insurance contracts

The Group through its subsidiary company Alpha Life enters into insurance contracts. Insurance contracts are contracts under which the

insurance company accepts significant insurance risk from the policyholder by agreeing to compensate the policyholder if a specified uncertain

future event adversely affects the policyholder.

For the Group, insurance risk is significant when the amount paid in the event of insurance risk exceeds 5% of the total benefit arising from the

contract.

The contracts that Alpha Life enters into and which do not involve a significant insurance risk are classified as investment contracts, are

included in caption “Due to customers” in the balance sheet and are measured as financial liabilities under IFRS 9.

b. Level of aggregation of insurance contracts

Insurance contracts are grouped into portfolios of contracts. A portfolio comprises contracts subject to similar risks and managed together.

Contracts included in a group of contracts are issued less than 12 months apart while the annual basis is determined as the calendar year, i.e.

the period from 1.1 to 31.12.

c. Measurement

he insurance contracts of the Group are contracts with direct participation features and are measured based on the variable fee approach. In

particular, on initial recognition, groups of insurance contracts are measured at the total of:

•

the fulfillment cash flows, which comprise:

•

estimates in present value of future cash flows within the boundary of each contact and

•

a risk adjustment for non-financial risk,

•

the contractual service margin.

Fulfillment future cash flows are those that relate directly to the contract, such as premiums, payments to policyholders, insurance acquisition

cash flows, administration costs etc. while the contract boundary is determined by its duration as this is stated in the insurance contract. In the

actuarial models are also included expenses which are within the scope of IFRS 17 and which are allocated based on their nature.

To discount cash flows, the Group uses discount rates based mainly on the interest rate curve as determined by the European Insurance and

Occupational Pensions Authority (EIOPA) applying zero liquidity premium.

The risks covered by the risk adjustment for non-financial risk are insurance risk and other non-financial risks such as lapse risk and expense

risk. The cost of capital approach is used for the calculation of the adjustment. A confidence level of 99.5% is used to determine the risk

adjustment for non-financial risk.

In accordance with the Group policy, changes in the risk adjustment for non-financial risk are not disaggregated and as a result the total change

is included in the insurance service result.

On initial recognition, the contractual service margin is measured at an amount that results in no income or expenses arising from:

•

the initial recognition of an amount for the fulfilment cash flows,

•

the derecognition at the date of initial recognition of any asset or liability recognised for insurance acquisition cash flows , and

•

any cash flows arising from the contracts in the group at that date.

Subsequently, the contractual service margin is adjusted for the change in the Group’s share of the fair value of the underlying items, the effect

of any new contracts added, the changes in fulfilment cash flows relating to future service and the amount recognised as insurance revenue

because of the transfer of services in the period.

At the end of each reporting period, the carrying amount of a group of insurance contracts is the sum of the following:

•

the liability for remaining coverage (fulfillment cash flows related to future service and the contractual service margin) and

•

the liability for incurred claims (fulfillment cash flows related to past service).

The methodology for the identification of coverage units is determined by considering for each contract the quantity of the benefits provided

under a contract as well as its expected coverage duration, in particular by taking into consideration the fund value.

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d. Presentation

The liabilities from insurance contracts that fall within the scope of the IFRS 17 are presented in the line "Liabilities from insurance contracts"

while receivables from reinsurance contracts are presented in the line "Reinsurance contracts assets".

Regarding the Income Statement, insurance revenue and insurance service expenses are presented separately in captions “insurance revenue”

and “insurance expenses” respectively, whereas their total is presented in caption “Net Insurance income”. In addition, insurance finance

income or expenses are separately presented in caption “Finance income/(expense) from insurance contracts”.

It is noted that as Alpha Life, from which the insurance contracts arise, has been classified as held for sale and its results as arising from

discontinued operations, the liabilities from insurance contracts are included in "Liabilities related to assets classified as held for sale" and the

results from insurance contracts in "Net profits/(loss) after income tax, from discontinued operations".

1.2.13 Provisions – Expected credit losses

The Group, at each reporting date, recognizes a loss allowance for expected credit losses on all debt financial instrumentss measured at

amortised cost or at fair value through other comprehensive income as well as for off-balance sheet exposures (letters of guarantee, letters of

credit, undrawn loan commitments) and finace lease receivables.

The loss allowance is based on expected credit losses related to the probability of default within the next twelve months (Stage 1), unless there

has been a significant increase in credit risk from the date of initial recognition or the instrument has become impaired in which cases expected

credit losses are recognized over the life of the instrument (Stages 2 or 3). 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.

Purchased or originated credit impaired exposures include:

•

Exposures that at the time of acquisition meet the criteria to be classified as non-performing exposures.

•

Exposures for which there has been a change in repayment terms, either due to financial difficulty or not, which resulted in derecognition

and recognition of a new impaired asset (POCI) except when derecognition is due to the change of debtor of a corporate loan in which

case the creditworthiness of the new debtor is reassessed.

Especially for investments in debt securities, the following apply:

•

The instrument (or the issuer) is characterised as purchased or originated credit impaired when it 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 Group

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 Group.

Finally, for receivables from customers derived from the Group’s commercial, other than loan, activity, the loss allowance for receivables from

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.

Default definition

For credit exposures, the Group has adopted the default definition defined in the EBA Guidelines (GL/2016/07). It is noted that the Group has

harmonized the perimeter of exposures recognized as “Defaulted Exposures”, as “Non-Performing Exposures” and as “IFRS 9 Impaired

Exposures”.

Due from financial institutions 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.

Calculation of expected credit loss

The measurement of expected credit losses is made as follows:

•

For financial assets, a credit loss is the present value of the difference between:

•

the contractual cash flows and

•

the cash flows that the Group expects to receive

•

For undrawn loan commitments, a credit loss is the present value of the difference between:

•

the contractual cash flows that are due if the holder of the loan commitment draws down the loan; and

•

the cash flows that the Group expects to receive if the loan is drawn down.

•

For letters of guarantee and letters of credit, the loss is equal to the expected payments to reimburse the holder for a credit loss that it

incurs less any amounts that the Group expects to receive from the holder.

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.

More information on the calculation of expected credit loss (individual/collective assessment, credit risk parameters, incorporation of future

information, adjustments by management) is included in note 47.1.

Presentation of expected credit losses in financial statements

Loss allowances for expected credit losses are presented in the Balance Sheet as follows:

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•

Financial assets measured at amortised cost and finance lease receivables: 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.

•

Letters of credit/letters of guarantee: loss allowance is recognized in line “Provisions” of liabilities in Balance Sheet.

•

Undrawn loan commitments: When there is not also a loan, loss allowance is recognized in line “Provisions” of liabilities in Balance Sheet.

If a financial asset includes both a loan and an undrawn loan commitment, the accumulated expected credit losses of the loan

commitment are presented together with the accumulated expected credit losses of the loan, as a deduction from its gross carrying

amount. To the extent that the combined expected credit losses exceed the gross carrying amount of the loan, the expected credit losses

are recognized in line “Provisions” of liabilities in Balance Sheet.

The amount of expected credit losses for the period is presented in the caption “Impairment losses and provisions to cover credit risk”. In the

same caption the following are also recognized: recoveries from written-off loans measured at amortised cost, the amounts received from

financial guarantee contracts as well as the reimbursements received from synthetic securitization transactions, modification gains or losses of

loans measured at amortised cost as well as 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.

Write-offs

The Group proceeds with the write-off of loans and advances to customers when it has no reasonable expectations for their recovery. In this

case, the loss allowance is used against the carrying amount of the financial asset. Write-off is an event of derecognition.

1.2.14 Impairment losses on investments and non-financial assets

The Group assess as at each balance sheet date its investments in associates and joint ventures as well as non-financial assets for impairment,

particularly, right of use assets, goodwill and other intangible assets and at least annually property, plant and equipment and investment

property.

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.

•

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.

•

Evidence is available of obsolescence or physical damage of an asset.

Specifically for right of use assets, triggers for impairment include:

•

The existence of leased properties that are neither used nor leased by the Group.

•

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.

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 Group.

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.

1.2.15 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.

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 associates and joint ventures, 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.

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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. In this context, the tax related to the dividend distribution, as assessed to

constitute the payment of the return on the AT1 instrument, is recognized in profit or loss.

1.2.16 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. In the event that the sale is not completed within one year, the asset remains classified as held for sale when

the cause of the delay is beyond the Group's control and/or when the Group is still committed to the plan for its disposal and the sale is

considered probable. 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 Group subsequently decides either to use or to lease, are reclassified to the categories of property,

plant and equipment or investment property respectively. Also, assets cease to be classified as held for sale when the classification criteria are

no longer met. 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 Group intends to sell but which 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.

1.2.17 Defined contribution and defined benefit plans

The Group has both defined benefit and defined contribution plans.

A defined contribution plan is where the Group pays fixed contributions into a separate entity and the Group has no legal or constructive

obligation to pay further contributions if the fund does not have sufficient assets to pay all employees the benefits relating to employee service

in current or prior years. The contributions are recognized as employee benefit expense on an accrual basis. Prepaid contributions are

recognized as an asset to the extent that a cash refund or a reduction in the future payments is available.

A defined benefit plan is a pension plan that defines an amount of pension benefit that an employee will receive on retirement which is

dependent, among others, on years of service and salary on date of retirement and it is guaranteed by the entity of the Group.

The defined benefit obligation is calculated, separately for each plan, based on an actuarial valuation performed by independent actuaries

using the projected unit credit method.

The net liability recognized in the consolidated financial statements is the present value of the defined benefit obligation less the fair value of

plan assets.

The present value of the defined benefit obligation is calculated based on the return of high quality corporate bonds with a corresponding

maturity to that of the obligation, or based on the return of government bonds in cases when there in no deep market in corporate bonds.

Interest on the net defined benefit liability (asset), which is recognised in profit or loss, is determined by multiplying the net defined benefit

liability (asset) by the discount rate used to discount post-employment benefit obligation, as determined at the start of the annual reporting

period, taking into account any changes in the net defined benefit liability (asset).

Service cost, which is also recognised in profit or loss, consists of:

•

Current service cost;

•

Past service cost and

•

Any gain or loss on settlement.

Past service cost, in particular, is directly recognized to profit or loss at the earliest of the following dates:

•

When the plan amendment or curtailment occurs and

•

When the Group recognizes related restructuring costs (according to IAS 37) or termination benefits.

Likewise, the Group recognizes a gain or loss on the settlement when the settlement occurs.

Remeasurements of the net defined benefit liability (asset) which comprise:

•

actuarial gains and losses;

•

return on plan assets, excluding amounts included in net interest on the net defined benefit liability (asset); and

•

any change in the effect of the limitation in the asset recognition, excluding amounts included in net interest on the net defined benefit

liability (asset),

are recognized directly in other comprehensive income and are not reclassified in profit or loss in a subsequent period.

Finally, when the Group decides to terminate the employment before retirement or the employee accepts the Group’s offer of benefits in

exchange for termination of employment, the liability and the relative expense for termination benefits are recognized at the earlier of the

following dates:

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•

when the Group can no longer withdraw the offer of those benefits; and

•

when the Group recognizes restructuring costs which involve the payment of termination benefits.

1.2.18 Variable remuneration

a. Variable remuneration paid in cash

The obligation to pay variable remuneration to employees in cash, either through payroll or under a profit-sharing scheme, is recognized in the

fiscal year for the performance of which the benefit is provided or during the servicing period in case the payment is deferred in order to be

paid gradually in future years, provided that the employee remains in service. The cost of the remuneration is recognized in Staff Costs.

b. Share options granted to employees

The granting of share options of the parent company of the Group to the employees, their exact number, the price and the exercise date are

decided by the Board of Directors in accordance with the 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 with an increase of a reserve in

equity respectively. 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 is 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 Group 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.

c. Stock 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 (expense) with a corresponding increase in an equity

reserve, during the period when the relevant services are provided by the employees. 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 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.

1.2.19 Provisions and contingent liabilities

A provision is recognized if, as a result of a past event, the Group 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 Group.

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.

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 while their amount shall not 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 provided that both amounts are recognized within the same

fiscal year.

The Group does not recognize in the statement of financial position contingent liabilities when it is not probable that an outflow of resources

will be required to settle the obligation or the amount of liability cannot be measured reliably or in cases where the obligation is possible only

to the extent that one or more uncertain future events occur, which are not only within the control of the Group.

The Group provides disclosures for contingent liabilities taking into consideration their materiality.

1.2.20 Securities sale and repurchase agreements and securities lending

The Group enters into purchases of securities under agreements to resell at a certain date in the future at a fixed price (reverse repos).

Securities purchased subject to commitments to resell them at future dates are not recognized in the balance sheet.

The amounts paid, including interest accruals, are recognized in “Loans and advances to customers” or “Due from financial institutions”. The

difference between the purchase price and the resale price is recognized as interest income using effective interest method.

Similarly, securities that are sold under agreements to repurchase (repos) are not derecognized but they continue to be measured in

accordance with the accounting policy of the category that they have been classified.

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The proceeds from the sale of the securities are reported as “Due to customers” or “Due to banks”. The difference between the sales price and

the repurchase price is recognized as interest expense using effective interest method.

Securities borrowed by the Group under securities lending agreements are not recognized in the consolidated balance sheet except when they

have been sold to third parties whereby the liability to deliver the security is recognized and measured at fair value.

1.2.21 Securitization

The Group securitises financial assets by transferring these assets to special purpose entities, which in turn issue bonds.

In each securitization of financial assets the assessment of control of the special purpose entity is considered, based on the circumstances

mentioned in note 1.2.1, so as to examine whether it should be consolidated. In addition, the contractual terms and the economic substance of

transactions are considered, in order to decide whether the Group should proceed with the derecognition of the securitised financial assets, as

referred in note 1.2.5.

1.2.22 Equity

Distinction between debt and equity

Financial instruments issued by Group companies to obtain funding are classified as equity when, based on the substance of the transaction,

the Group 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 titles have been classified in this category since they are perpetual and there is no oblligation to pay either principal or interest.

In cases when Group companies are 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 Group.

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 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 Group.

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 or specific equity reserves and recorded as a liability in the period that the dividend is approved

by the Shareholders in General Meeting.

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.

1.2.23 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 1.2.6. 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 Group 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.

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1.2.24 Fee and commission income

Fees and commission income from contracts with customers are recognized based on the consideration specified in the contract when the

Group 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, in 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.

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.

1.2.25 Dividend Income

Dividend income from investments in shares is recognised in the income statement when the dividend distribution is approved by the

appropriate body of the company that the Group has invested in.

1.2.26 Gains less losses on financial transactions

Gains less losses on financial transactions include:

•

fair value changes of financial assets and liabilities,

•

gains and losses arising from the modification of the contractual terms of financial assets measured at fair value through profit or loss,

•

gains and losses arising from the derecognition of financial assets and liabilities due to early repayment, including conversion of loans into

shares, disposal or significant modification of the contractual terms, except for gains and losses arising from the derecognition of financial

assets measured at amortised cost which are recognized in a separate line item of the Income Statement, and

•

exchange differences arising from the translation of financial instruments denominated in foreign currencies.

1.2.27 Gains less losses on derecognition of financial assets measured at amortised cost

Gains less losses on derecognition of financial assets measured at amortised cost include:

•

Gains and losses from the derecognition of financial assets measured at amortised cost

•

The difference, at initial recognition, between the nominal and the fair value of a financial asset measured at amortised cost that is the

result of the derecognition of another financial asset due to significant modification of its contractual terms.

1.2.28 Impairment losses on fixed assets and equity investments

Impairment losses on fixed assets and equity investments include the impairment or write-off losses recognized on:

•

property, plant and equipment and investment property,

•

intangible assets,

•

right of use assets,

•

fixed assets classified within other assets as inventories,

•

investments in associates and joint ventures and

•

non-financial assets or disposal groups classified as held for sale.

1.2.29 Gains/(losses) from the disposal of fixed assets and equity investments

The line item “Gains/(losses) from the disposal of fixed assets and equity investments” includes gains and losses from the disposal of:

•

property, plant and equipment and investment property,

•

intangible assets,

•

fixed assets classified within other assets as inventories,

•

investments in associates and joint ventures and

•

non-financial assets or disposal groups classified as held for sale.

1.2.30 Provisions (Income Statement)

The "Provisions" line of the Income Statement includes changes in provisions for the period (except those related to credit risk coverage),

including restructuring plan and operational risk provisions, as well as related expenses.

1.2.31 Transformation costs

The line item “Transformation costs” include the costs recognized on an accrued basis and related to those projects carried out by the Group

that lead to significant changes in its operation (transformation costs) and which do not meet the criteria to be recognized as a provision for a

restructuring plan under IAS 37.

1.2.32 Expenses relating to credit risk management

The line item "Expenses relating to credit risk management" includes:

•

servicing costs relating to overdue loans and

•

the protection fee paid in the context of synthetic securitization transactions as well as the costs of said transactions.

1.2.33 Discontinued operations

A discontinued operation is a component of the Group 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; or

•

a subsidiary acquired exclusively with a view to resale.

When assessing whether a component meets the definition of a major line of business, its contribution to the Group's total assets and profit or

loss is taken into account, as well as the extent to which discrete information is provided to the Executive Committee for that component.

The profit or loss after tax 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.

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273 | ANNUAL FINANCIAL REPORT

The comparative financial statements are restated only for the income statement and the cash flow statement.

1.2.34 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 Group, in

particular, related parties are considered:

•

An entity that constitutes for the Group:

•

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 Group.

•

A person and his close family members, if that person is a member of the key management personnel.

The Group considers as key management personnel all the members of the Board of Directors and of the Executive Committee of the parent

company of the Group while as their close family members it considers their children and spouses or domestic partners and their dependants

and the dependants 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%.

1.2.35 Earnings per share

Basic earnings per share are calculated by dividing profit or loss attributable to ordinary equity holders of the parent company of the Group 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.

1.2.36 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 Group, 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:

Business Model Assessment (notes 1.2.5)

The Group, on the initial recognition of a debt financial asset, exercises judgment in order to determine the business model in which it would

be classified, taking into account the way of evaluating its performance, the risks associated with it as well as the expected frequency and value

of sales. Also, on a quarterly basis, it exercises judgment in order to reassess the business models, taking into account the sales that have been

made as well as any changes in the management operating model of the assets. Based on this assessment, it decides whether it should define

new business models or in rare circumstances proceed with the reclassification of financial assets to another business model.

Assessment of whether contractual cash flows of a debt financial instrument represent solely payments of principal and interest on the

principal amount outstanding (SPPI) (note 1.2.5)

The Group, at initial recognition of a debt financial asset, assesses whether cash flows are solely payments of principal and interest on the

principal amount outstanding. The assessment requires judgement mainly on:

•

Whether contractual terms that affect the performance of the instrument relate solely to credit risk, other basic lending risks and profit

margin.

•

For loans in special purpose entities, whether there is a non-recourse feature. The assessment is based on specific index thresholds as well

as on the evaluation of the adequacy of equity and of the collaterals that are not related to the asset being financed.

•

Whether in case of prepayment or extension the compensation received is considered fair.

•

Whether in loans with ESG (Environmental, Social, Governance) criteria, the change in credit spread based on the satisfaction of those ESG

criteria is borrower specific and whether it relates to the change in credit risk and/or change in profit margin.

The application of different judgments could affect the amount of financial assets measured at fair value through profit or loss.

Significant judgements relating to the selection of methodologies and models for expected credit losses calculation (note 47.1)

The Group, in the context of the application of its accounting policies for the measurement of the expected credit losses makes judgments in

order to identify:

•

the criteria that indicate a significant increase in credit risk,

•

the selection of appropriate methodologies for expected credit loss estimation (expected credit loss calculation on an individual or on a

collective basis),

•

the selection and development of appropriate models used to calculate the exposure at default (EAD) by financial instrument category,

the probability of default (PD), the estimated expected credit loss at the time of default (LGD) as well as the selection of appropriate

parameters and economic forecasts used in them,

•

the selection of appropriate macroeconomic parameters affecting the expected credit risk loss,

•

the selection of the parameters used in the models to determine the expected life and the date of initial recognition of revolving

exposures,

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

274 | ANNUAL FINANCIAL REPORT

•

the grouping of financial assets based on similar credit risk characteristics,

Applying different judgments could significantly affect the financial instruments classified in stage 2 and/ or significantly differentiate expected

credit loss calculations.

Income Tax (notes 17 and 43)

The recognition of assets and liabilities for current and deferred tax is affected, inter alia, 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 Group 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 Group.

Classification of non-current assets as held for sale (note 52)

The Group classifies non-current assets or disposal groups that are expected to be recovered principally through a sale transaction, along with

the related liabilities, as held-for-sale when the asset is available for immediate sale in its present condition and its sale is highly probable to be

completed within one year. The assessment of whether the above criteria are met requires judgment mainly as to whether the sale is likely to

be completed within one year from the classification of the non-current assets or disposal group as held for sale. In the context of this

assessment in which any previous experience from corresponding transactions is also considered, the Group takes into account elements such

as any requirement for approvals (both regulatory and those given by the General Meeting and the Committees of the Group), the existence of

offers (binding or not) and the status of the signed agreements with investors as well as of any conditions included in them. In addition, current

economic conditions are taken into account which may affect the time of completion of sales transactions. In the event that the sale is not

completed within one year from the classification of the non-current assets or disposal group as held for sale, judgment is exercised in order to

assess whether the cause of the delay is outside the Group's control as well as whether the Group continues to be committed to the program

for their disposal and the sale is considered likely to occur.

Assessment of the existence of control, joint control or significant influence over companies (note 44)

The Group exercises judgment in order to determine whether it has control, joint control or significant influence over companies either through

its participation in their share capital or through other agreements.

The main cases in which judgments were applied concern:

•

Special purpose entities established in the context of loan securitization transactions or synthetic securitization transactions and in which

the Group assesses the existence of control taking into account the ability to make decisions over their main activities, as well as the

degree of its exposure to the variability of their returns.

•

In associated companies in which the Group holds less than 20% of the share capital, it is assessed whether significant influence exists

through the Group's participation in their Board of Directors and consequently through its participation in the policy-making process, as

well as whether, based on the shareholders' agreement, there is the possibility of exercising a veto on significant decisions.

Pending legal cases (note 43)

The Group, in the context of the preparation of its financial statements, exercises judgment in order to assess the possibility of a negative

outcome of its pending legal cases. In this judgement, the substantial circumstances of each case, the legislation and the regulatory framework,

the relevant jurisprudence as well as the judicial course of the case are taken into account. As a result of this assessment, when the probability

of a negative outcome exceeds 50% and the determination of the financial outflow that will be required is considered reliable, the Group

proceeds with the recognition of a provision in the financial statements.

Key sources of estimation uncertainty

Key sources of estimation uncertainty used by the Group 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.

Fair value of assets and liabilities (notes 26, 30, 47.4, 52)

For assets and liabilities traded in active markets, the determination of their fair value is based on quoted, market prices. In all other cases the

determination of fair value is based on valuation techniques that use observable market data to the greatest extent possible. In cases where

there is no observable market data, the fair value is determined using data that are based on internal estimates and assumptions i.e.

determination of expected cash flows, discount rates, prepayment probabilities or counterparty default. Fair value measurement of receivables

arising from sale transactions is based on significant unobservable inputs such as the expected cash flows from the management of the

underlying receivables portfolio and the business plan of the companies sold.

Estimates included in the calculation of expected credit losses of financial instruments (notes 11, 47.1)

The measurement of expected credit losses requires the use of complex models and significant estimates of future economic conditions and

credit behavior, taking into account the events that have occurred until reporting date. The significant estimates relate to:

•

the determination of the alternative macroeconomic scenarios and the cumulative probabilities associated with these scenarios,

•

the probability of default during a specific time period based on historical data, assumptions and estimates for the future,

•

the determination of the expected cash flows and the flows from the liquidation of collaterals for financial instruments,

•

the determination of the adjustments to the models for the calculation of the parameters of expected credit loss when credit risk models

cannot incorporate certain risk factors in periods of uncertainty and

•

the integration of loan portfolio sales scenarios taking into account on the one hand any factors that may hinder the realization of the sale

and on the other hand the level of satisfaction of the conditions for the completion of the sale.

Extention of protection program against the increase in interest rates for consistent borrowers of floating rate mortgages (note 11)

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275 | ANNUAL FINANCIAL REPORT

During the second quarter of the current year the Group estimated that the extension for one year of the protection program against the

increase in interest rates for consistent borrowers of floating rate mortgages constitutes in essence an adjustment of the base interest rates to

the current market interest rates for similar loans; thereby contributing to customer retention. Therefore, the modification of the cash flows of

the loans in question due to the extension of the protection was accounted for through a recalculation of their effective interest rate.

Impairment losses on investments in associates and joint ventures and on non - financial assets (notes 26, 28)

The Group, at each reporting date, assesses for impairment right-of-use assets, goodwill and other intangible assets, as well as its investments

in associates and joint ventures and at least on an annual basis property, plant and equipment and investment property. 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

Employee defined benefit obligations (note 35)

Defined benefit obligations are estimated based on actuarial valuations, which are mainly conducted on an annual basis, that incorporate

assumptions regarding discount rates, future changes in salaries and pensions, as well as the return on any plan assets. Any change in these

assumptions will affect the amount of obligations recognized.

Provisions (note 37)

The amounts recognized by the Group in its financial statements as provisions are derived from the best estimate of the possible outflow

required to settle the present obligation. This estimate is determined by Management after taking into account factors such as experience from

relevant transactions, the degree of complexity of each case, the actions taken to settle it as well as expert reports when considered necessary.

In case the amount recognized as a provision is affected by a variety of factors, its calculation is based on the weighting of all possible results.

At each reporting date, provisions are revised to reflect current best estimates of the obligation.

Recoverability of deferred tax assets (notes 17 and 29)

The Group recognizes deferred tax assets to the extent that it is probable that it will have sufficient future taxable profit available, against

which, deductible temporary differences and tax losses carried forward can be utilized. The estimation of future taxable profits is based on

forecasts for the development of the accounting results, as these are formulated in accordance with the business plan of the Group. In

particular, the business plan includes actions aimed at enhancing profitability through:

•

the reduction of the amount of non-performing exposures,

•

the improvement in operational efficiency and reduction of operating costs,

•

interest income increase through asset development, with a particular focus on business loans and

•

the increase in income from fees and commissions

The main categories of deferred tax assets which have been recognized by the Group relate to losses from the Greek government bonds

exchange program (PSI) and the December 2012 Greek government bond buyback program and to deductible temporary differences arising

from loans’ impairment.

Deferred tax assets associated with tax losses incurred by the PSI and the participation of the Bank in the December 2012 Greek government

bond buyback program were recognized as a “debit difference” according to Law 4046/14.2.2012, Law 4110/23.1.2013 and a respective legal

opinion. According to Law 4110/23.1.2013 the “debit difference” is deductible for tax purposes, gradually in equal installments, within 30 years,

a fact which, according to the Group’s estimation, provides a sufficient time period for its gradual utilization against taxable profits.

Regarding the temporary differences arising from loans’ impairment, there are no time constraints concerning their recovery, as is the case for

the other deferred tax assets categories. The Group assessed their recoverability based on estimates for future taxable profits, as these are

forecasted on the basis of the aforementioned business plan. In order to assess deferred tax asset recoverability, the Group’s business plan was

extended for a limited number of years during which estimates were made regarding the production of new loans and the evolution of the

operating results.

In addition, tax losses resulting from the write-down of debts and the sale of loans, as specifically mentioned in note 17, are recognized as a

debit difference. It is noted that the debit difference is recognized gradually and equally over a period of 20 years, a fact which in accordance

with Group’s estimations provides sufficient time for offsetting against taxable profits. In addition, in accordance with the amendment of article

27 of L. 4172/2013, the amount of the annual deduction of the debit difference due to credit risk that is not offset against the taxable profits of

the year is transferred in order to be deducted in subsequent tax years within the twenty-year period. If at the end of the twenty-year

depreciation period there are balances that have not been offset, they constitute a loss that can be carried forward in order to be offset with

future taxable profits within five years.

The Group, based on the above, estimates that the total deferred tax assets recognized and that relate to temporary differences and to tax

losses carried forward is recoverable.

In addition, and regardless of the assessment of the recoverability of deferred tax assets that is carried out based on what is mentioned above,

Law 4303/2014 provides that in case that the after tax accounting result for the period is a loss, deferred tax assets arising from the PSI debit

difference and from the accumulated provisions and other general losses due to credit risk are eligible to be converted into a final and settled

claim against the Greek State, as described in detail in note 17.

The main uncertainties concerning the estimations for the recoverability of the deferred tax assets relate to the achievement of the goals set in

the Group’s business plan, which is affected by the general macroeconomic environment in Greece and internationally. These goals mainly

concern the reduction of non-performing exposures, the production of new loans as well as the evolution of operating results. At each balance

sheet date, the Group reassesses its estimation regarding the recoverability of deferred tax assets in conjunction with the development of the

factors that affect it.

The estimates and judgments applied by the Group 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 on an ongoing basis 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.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

276 | ANNUAL FINANCIAL REPORT

2. Restatement of financial statements

a. In the context of improving the presentation of Income Statement, the Group decided in 2024, to reclassify certain expenses and income

to better reflect their nature. Specifically, expenses and income have been reclassified as follows :

• From “General Administration Expenses” to “Gains/(Losses) on Financial Transactions”

• From “General Administration Expenses” to “Expenses Related to Credit Risk Management”

• From “Fee and Commission Income” to “Interest and Similar Income”

b. For a better presentation of current income tax liabilities, the Group reclassified the figures related to other taxes from line "Liabilities for

current income tax and other Taxes" to "Other liabilities" therefore the relevant line of the Balance Sheet was renamed to "Liabilities for

current income tax". This reclassification was applied retrospectively.

d. During the current period, the accounting treatment for the dividend coupon payment of the AT1 instrument was reassessed and was

considered that in substance it constitutes a distribution of profits and consequently the respective tax should be recognised in the

Income Statement at the time of payment. This treatment was applied retrospectively for the coupon payments made by the Bank in

August 2023 and February 2024. The above reassessment change in accounting treatment does not affect the book values of any Assets,

Liabilities or elements of Equity as at 31.12.2023. The statement of changes in equity has been restated to reflect the effect of the

reassessment.

e. On 12.7.2024 Alpha International Holdings Single Member S.A (“AIH”) and UniCredit S.p.A. signed the Share Sale and Purchase Agreement

relating to the sale of 90.1% of the issued share capital of Alpha Bank Romania S.A. As part of the agreement, it was determined that a

portfolio of loans would be excluded from the transaction and not transferred to UniCredit. For this reason the results for the reporting

and comparative period related to the loans thal will be excluded from the sale transaction are no longer presented as discontinued

operations.

f. During the third quarter of the current period, and in the context of the review of the estimates and judgments applied during the

preparation of the financial statements which takes place on an ongoing basis, the terms of the agreements governing derivatives cleared

in Central Counterparties through Clearing Members were reassessed and it was estimated that the IAS 32 offsetting criteria are met for

derivative assets and liabilities arising from those agreements as well as for the related cash collateral exchanged. The change in the

presentation of those financial instruments to be presented net in the balance sheet was applied retrospectively.

The restatements of the Balance Sheet, the Income Statement, the Statement of Comprehensive Income and the Statement of Cash Flows for

the comparative period are presented in the following tables. All subsequent notes have been restated accordingly.

Taking into account that the adjustments (b) and (e) do not have an impact on the Group's total equity, it was not deemed necessary to

present a restated Balance Sheet at the beginning of the comparative period.

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277 | ANNUAL FINANCIAL REPORT

Consolidated Balance Sheet as at 31.12.2023

31.12.2023 as Derivative Other 31.12.2023 as pubished offset taxes restated ASSETS Cash and balances with central banks 4,219 4,219 Due from financial institutions 1,722 (150) 1,572 Trading securities 33 33 Derivative financial assets 1,819 (1,092) 727 Loans and advances to customers 36,161 36,161 Investment securities - Measured at fair value through other comprehensive income 1,369 1,369 - Measured at amortized cost 14,490 14,490 - Measured at fair value through profit or loss 159 159 Investments in associates and joint ventures 100 100 Investment property 301 301 Property, plant and equipment 501 501 Goodwill and other intangible assets 467 467 Deferred tax assets 4,978 4,978 Other assets 945 945 67,264 (1,242) - 66,022 Assets classified as held for sale 6,399 6,399 Total Assets 73,663 (1,242) - 72,421 LIABILITIES Due to banks 7,093 (172) 6,921 Derivative financial liabilities 2,004 (1,070) 934 Due to customers 48,449 48,449 Debt securities in issue and other borrowed funds 2,920 2,920 Liabilities for current income tax and other taxes 27 (23) 4 Deferred tax liabilities 25 25 Employee defined benefit obligations 24 24 Other liabilities 896 23 919 Provisions 120 120 61,559 (1,242) - 60,316 Liabilities related to assets classified as held for sale 4,782 4,782 Total Liabilities 66,340 (1,242) - 65,098 EQUITY Equity attributable to holders of the Company Share capital 682 682 Share premium 4,783 4,783 Other Equity Instruments 400 400 Reserves (111) (111) Amounts directly recognized in equity and are associated with assets classified as held for sale (64) (64) Retained earnings 1,626 1,626 Less: Treasury shares (11) (11) 7,305 - - 7,305 Non-controlling interests 18 18 Total Equity 7,323 - - 7,323 Total Liabilities and Equity 73,663 (1,242) - 72,421

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

278 | ANNUAL FINANCIAL REPORT

Consolidated Income Statement 1.1-31.12.2023

From 1 January to AT1 31.12.2023 as Change in the instrument Discontinued 31.12.2023 as pubished presentation coupon Operations restated payment Interest and similar income 3,576 (1) 7 3,582 Interest expense and similar charges (1,923) (1,923) Net interest income 1,653 (1) - 7 1,659 - of which: net interest income based on the effective interest rate 1,728 1,728 Fee and commission income 432 1 433 Commission expense (59) (59) Net fee and commission income 373 1 - - 374 Dividend income 4 4 Gains less losses on derecognition of financial assets measured at (17) (17) amortised cost Gains less losses on financial transactions 70 70 Other income 39 39 Total income from banking operations 2,122 - 7 2,129 Staff costs (333) (333) General administrative expenses (327) 2 (325) Depreciation and amortization (157) (157) Total expenses (817) 2 - - (815) Impairment losses and provisions to cover credit risk (381) - (381) Expenses related to credit risk management (86) (2) (88) Impairment losses of fixed assets and participations (19) (19) Gains/(Losses) on disposal of fixed assets and participations 3 3 Provisions (46) (46) Transformation costs (4) (4) Share of profit/(loss) of associates and joint ventures 1 1 Profit/(loss) before income tax 773 - - 7 780 Income tax (233) 7 - (226) Net profit/(loss) from continuing operations for the period after income 540 - 7 7 554 tax Net profit/(loss) for the period after income tax from discontinued 71 (7) 64 operations Net profit/(loss) for the period 611 - 7 - 618 Net profit/(loss) attributable to: Equity holders of the Company 611 - 7 - 618 - from continuing operations 540 7 7 554 - from discontinued operations 71 (7) 64 Non-controlling interests - from continuing operations - Earnings/(losses) per share Basic (€ per share) 0.2531 0.2531 Basic (€ per share) from continuing operations 0.2228 0.0028 0.2256 Basic (€ per share) from discontinued operations 0.0303 (0.0028) 0.0275 Diluted (€ per share) 0.2528 0.2528 Diluted (€ per share) from continuing operations 0.2225 0.0028 0.2253 Diluted (€ per share) from discontinued operations 0.0303 (0.0028) 0.0275

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

279 | ANNUAL FINANCIAL REPORT

Consolidated Statement of Comprehensive Income 1.1 - 31.12.2023

From 1 January to AT1 instrument 31.12.2023 as Discontinued 31.12.2023 as coupon pubished Operations restated payment Net profit/(loss), after income tax, recognized in the Income Statement 611 7 - 618 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 19 19 comprehensive income Net change in cash flow hedge reserve 35 35 Foreign currency translation net of investment hedges of foreign operations Income tax (16) (16) Items that may be reclassified subsequently to the Income Statement from continuing 38 - - 38 operations Items that may be reclassified subsequently to the Income Statement from discontinued 32 - - 32 operations Items that will not be reclassified to the Income Statement Remeasurement of defined benefit liability/ (asset) (2) (2) Gains/(losses) from investments in equity securities measured at fair value through other 11 11 comprehensive income Income tax (3) (3) Items that will not be reclassified to the Income Statement from continuing operations 6 - - 6 Other comprehensive income, after income tax, for the period 76 76 Total comprehensive income for the year 687 7 - 694 Total comprehensive income for the year attributable to: Equity holders of the Company 687 7 694 - from continuing operations 584 7 7 598 - from discontinued operations 103 (7) 96 Non controlling interests

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

280 | ANNUAL FINANCIAL REPORT

Consolidated Statement of Cashflows

From 1 January to 31.12.2023 as Derivative Discontinued 31.12.2023 as pubished offset Operations restated Cash flows from continuing operating activities Profit/(loss) before income tax from continued operations 773 7 780 Adjustments of profit/(loss) before income tax for: Depreciation, impairment, write-offs and net result from disposal of property, plant 67 67 and equipment Amortization, impairment, write-offs of intangible assets 107 107 Impairment losses, provisions to cover credit risk and related expenses 528 528 Gains less losses on derecognition of financial assets measured at amortised cost 17 17 Fair value (gains)/losses on financial assets measured at fair value through profit or 45 45 loss (Gains)/losses from investing activities (512) (512) (Gains)/losses from financing activities 244 244 Share of (profit)/loss of associates and joint ventures (1) (1) 1,268 - 7 1,275 Net (increase)/decrease in assets relating to continuing operating activities: Due from financial institutions (214) 171 (42) Trading securities and derivative financial instruments 135 (45) 89 Loans and advances to customers (614) (7) (621) Other assets 128 128 Net increase/(decrease) in liabilities relating to continuing operating activities: Due to banks (7,016) (126) (7,142) Due to customers 1,181 1,181 Other liabilities (97) (97) Net cash flows from continuing operating activities before income tax (5,229) - - (5,229) Income tax paid - Net cash flows from continuing operating activities (5,229) - - (5,229) Net cash flows from discontinued operating activities (128) - - (128) Cash flows from continuing investing activities Proceeds from disposals of subsidiaries 369 369 Dividend Received 5 5 Investments in associates and joint ventures - Acquisitions of investment property, property, plant and equipment and intangible (150) (150) assets Disposals of investment property, property, plant and equipment and intangible assets 14 14 Interest received from investment securities 249 249 Purchases of Greek Government Treasury Bills (2,056) (2,056) Proceeds from disposal and redemption of Greek Government Treasury Bills 1,964 1,964 Purchases of investment securities (excluding Greek Government Treasury Bills) (4,544) (4,544) Disposals/maturities of investment securities (excluding Greek Government Treasury 1,366 1,366 Bills) Net cash flows from continuing investing activities (2,783) - - (2,783) Net cash flows from discontinued investing activities (117) - - (117) Cash flows from continuing financing activities Share Capital Increase and Amounts intended for Share Capital Increase 1 1 AT 1 issuance 394 394 Payments for AT1 issuance (24) (24) Proceeds from issue of debt securities and other borrowed funds 614 614 Repayments of debt securities in issue and other borrowed funds (533) (533) Interest paid on debt securities in issue and other borrowed funds (126) (126) Payments of lease liabilities (28) (28) Dividend payments (1) (1) Treasury Shares (8) (8) Net cash flows from continuing financing activities 290 - - 290 Net cash flows from discontinued financing activities 116 - - 116 Effect of foreign exchange changes on cash and cash equivalents 2 2 Net increase/(decrease) from continuing cash flows (7,722) - - (7,722) Changes in cash equivalent from discontinued operations (128) (128) Cash and cash equivalents at the beginning of the year from continuing operations 12,155 - - 12,155 Cash and cash equivalents at the end of the year from continuing operations 4,434 - - 4,434

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

281 | ANNUAL FINANCIAL REPORT

INCOME STATEMENT

3. Net interest income

From 1 January to 31.12.2024 31.12.2023 Interest and similar income Due from financial institutions 199 268 Loans and advances to customers measured at amortized cost 1,945 1,886 Loans and advances to customers measured at fair value through profit or loss 25 23 Trading securities 1 - Investment securities measured at fair value through other comprehensive income 39 35 Investment securities measured at fair value through profit or loss 1 1 Investment securities measured at amortized cost 402 272 Derivative financial instruments 1,761 1,052 Finance lease receivables 14 16 Negative interest from interest bearing liabilities 7 25 Other 14 4 Total 4,408 3,582 Interest expense and similar charges Due to banks (298) (322) Due to customers (374) (252) Debt securities in issue and other borrowed funds (191) (146) Lease liabilities (2) (3) Derivative financial instruments (1,843) (1,124) Negative interest from interest bearing assets (7) (27) Other (48) (49) Total (2,763) (1,923) Net interest income 1,645 1,659 During the current year, net interest income decrease is mainly due increased cost of funding due to changes in ECB rates, repos and new MREL

issuances, as well as the gradual increase in term deposits interest rates and volume. This was partially counterbalanced by the increased

interest income from debt securities following acquisitions.

The following table presents interest income and interest expense calculated using the effective interest rate method, by financial asset

category:

4. Net fee and commission income

The increase in net fee and commisson income is mainly due higher volume of mutual funds transactions and new asset management products

as well as higher advisory and transaction fees. It is noted that the commision income from loans derives from loans that are not measured in

fair value through profit or loss.

From 1 January to 31.12.2024 31.12.2023 Financial assets measured at amortised cost 2,520 2,375 Financial assets measured at fair value through other comprehensive income 39 35 Financial assets measured at fair value through profit or loss 27 19 Financial liabilities measured at amortised cost (856) (695) Total 1,730 1,734

Net fee and commission income From 1 January to 31.12.2024 31.12.2023 Loans 68 70 Letters of guarantee 53 53 Imports-exports 6 6 Credit cards 50 47 Fund transfers 93 83 Mutual funds 88 61 Advisory fees and securities transaction fees 5 2 Brokerage services 9 9 Foreign exchange fees 2 3 Insurance brokerage 20 18 Other 26 22 Total 420 374

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

282 | ANNUAL FINANCIAL REPORT

Fee and commissions

The table below presents, per operating segment, the income from contracts, that fall within the scope of IFRS 15:

From 1 January to 31.12.2024 Wealth Non Performing Retail Wholesale International Total Group Management Assets Fee and commission income Loans 6 61 1 1 69 Letters of guarantee 3 46 1 3 53 Imports-exports 2 4 6 Credit cards 91 2 93 Fund transfers 68 16 8 1 93 Mutual funds 88 88 Advisory fees and securities transaction fees 4 4 Brokerage services 12 12 Foreign exchange fees 1 1 2 Insurance brokerage 19 1 20 Other 11 5 16 8 40 Total 201 136 116 22 5 480 From 1 January to 31.12.2023 Wealth Non Performing Retail Wholesale International Total Group Management Assets Fee and commission income Loans 5 59 1 6 71 Letters of guarantee 2 46 1 3 52 Imports-exports 2 4 6 Credit cards 88 3 91 Fund transfers 59 16 7 1 83 Mutual funds 61 61 Advisory fees and securities transaction fees 2 2 Brokerage services 11 11 Foreign exchange fees 1 1 2 Insurance brokerage 17 1 18 Other 9 6 13 8 36 Total 183 133 85 22 10 433

5. Dividend income

From 1 January to 31.12.2024 31.12.2023 Equity securities of investing portfolio measured at fair value through other Comprehensive Income (note 24) 2 2 Equity securities of investing portfolio measured at fair value through profit or loss 4 2 Total 6 4

6. Gains less losses on derecognition of financial assets measured at amortised cost

The tables below present gains less losses for the year 2024 and 2023 from derecognition of financial assets measured at amortised cost as

well as their carrying amount before derecognition.

From 1 January to 31.12.2024 (Losses) from Gains from Gains less losses from Carrying Amount derecognition derecognition derecognition Early repayments - Loans and advances to customers2,035 (5) 4 (1) - Securities79 3 3 Sales - Securities706 26 26 Substantial modifications - Loans and advances to customers579 (1) 4 3 Total 3,399 (6) 37 31

“Gains less losses on derecognition of financial assets measured at amortized cost” for 2024 mainly relates to gains:

• € 18 from sale of Greek state bonds

• € 8 from sale of Other state bonds

• € 3 from early repayment of Corporate bonds

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

283 | ANNUAL FINANCIAL REPORT

From 1 January to 31.12.2023 as restated (Losses) from Gains from Gains less losses from Carrying Amount derecognition derecognition derecognition Early repayments - Loans and advances to customers 2,619 (4) 6 2 Sales - Loans and advances to customers 246 (2) (2) - Securities 149 (2) (2) Substantial modifications - Loans and advances to customers 1,088 (5) 3 (2) - Securities 517 (13) (13) Total 4,619 (26) 9 (17)

The comparative figures were mainly affected by a loss of € 13 recognized by the Bank due the participation the exchange of Greek state bonds.

Ιn July 2023, the Greek state issued a new 15-year bond with a fixed coupon rate of 4.375% and maturity on 18.7.2038. The issuance was

accompanied with a Switch and Tender offer of 100% and 93.6% of the bonds maturing on 2.4.2024 and 15.2.2025 respectively at a repurchase

price of 100.15%. The Bank participated in the exchange for bonds with aggregate nominal value of € 535 (€ 498 securities measured at

amortized cost portfolio and € 37 from securities measured at fair value through other comprehensive income).

7. Gains less losses on financial transactions

From 1 January to 31.12.2024 31.12.2023 Foreign exchange differences 25 26 Trading securities: - Bonds 5 5 - Equity securities 4 3 Financial assets measured at fair value through profit or loss - Loans (9) 16 - Equity securities 18 16 - Bonds (3) 3 - Other securities - 3 - Receivables from contingent consideration as a result of sale transactions 4 14 Financial assets measured at fair value through other comprehensive income - Bonds and treasury bills 6 3 Derivative financial instruments 40 (15) Other financial instruments (10) (4) Total 80 70

Gains less losses on financial transactions” for the year 2024 has been mainly affected by the following:

• Gains of € 18 relating to the valuation of new IRS derivatives with corporate clients which are included in “Derivative financial

instruments”

• Gains of € 18 relating to the valuation of equity shares which are included in “Equity Securities” of financial assets measured at fair

value through profit and loss

• Loss of € 11 from the withdrawal of TIER 2 bonds issues that took place on 13.6.2024 which is included in “Other financial

instruments”

The results «Receivables from contingent consideration as a result of sale transactions» for 2023 relate to the earnout received from “Cepal

Services and Holding S.A.”.

8. Other Income

The table below presents, per operating segment, the income from contracts, that fall within the scope of IFRS 15:

From 1 January to 31.12.2024 Wealth Non Performing Corporate Total Retail Wholesale International Management Assets Center/Elimination Center Group Other 4 3 2 6 15 Total 4 3 2 6 15

From 1 January to 31.12.2024 31.12.2023 From operating lease income 12 19 - From which subleases 1 2 Insurance claims 7 Other 21 20 Total 40 39

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

284 | ANNUAL FINANCIAL REPORT

From 1 January to 31.12.2023 Wealth Non Performing Corporate Total Retail Wholesale International Management Assets Center/Elimination Center Group Other 3 1 3 2 7 16 Total 3 1 3 2 7 16

9. Staff costs

The total number of Group’s employees as at 31.12.2024 was 6,045 (31.12.2023: 8,161) out of which 5,513 (31.12.2023: 5,678) are employed

in Greece and 532 (31.12.2023: 2,483) are employed abroad. The decrease in the amount of people employed abroad is mainly to the sale of

the 90.1% of Alpha Bank Romania S.A.

The “Salaries and Wages” line item shows an increase compared to the previous year, mainly due to the implementation of the 2022-2024

Collective Labor Agreements of OTOE Banks and the special salary scale increases that took place primarily in 2024.

In addition, “Wages and salaries” include costs relating to staff incentive schemes as a reward on the Bank’s employees’ according to the

performance remuneration program. The programs include awards in cash, for which an amount of € 28 was recognised in 2024 (2023: € 16),

as well as stock awards to employees the terms of which are presented below.

Stock awards to employees

The Group has programs for granting free shares of the Company to the members of Management and employees of the Compnay and its

affiliated companies. According to the terms of the programs, a percentage of the grant is vested during the initial vesting period, while the

remaining amount is vested in equal annual installments over a period of four or five years. It is also noted that the entitlement to receive free

shares requires continued employment with the Company on the share allocation date.

In the context of the above mentioned Plan the following shares were awarded during the year:

- 1,493,761 shares awarded on 29.4.2024 with weighted average fair value of € 1.7164

- 972,629 shares awarded on 2.8.2024 with weighted average fair value of € 1.6564

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, the Bank recognised in Staff costs an amount of € 5 (31.12.2023: € 3) against a credit in an equity

reserve.

Awarding of stock options to employees

The Group has stock option programs for granting company shares to members of Management and employees of the Company and its

affiliated companies. According to the terms of the program, whithin the first year from the date the compensation is granted, beneficiaries

may exercise 60% of their total rights, while the remaining amount is vested in equal annual installments over a period of three or four years.

Rights that are not exercised expire. Additionally, if a beneficiary ceases to be an employee ot exeutive of the Group (with certain exceptions,

such as retirement or incapacity to work), they lose the right 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 in September 2023 and 481,608 options in January 2024 with an exercise price of € 0.30 .

Changes in the number of existing stock options for the years 2024 and 2023 are presented in the tables below:

2024 2023 Number of Weighted average exercise Number of Weighted average exercise Options price for all stock options Options price for all stock options Balance 1.1 2,310,021 0.294 5,826,778 0.296 Changes 1.1 – 31.12 Stock Options exercised during the year (1,279,623) 0.294 (3,489,887) 0.298 Stock Options expired during the year (43,556) 0.290 (26,870) 0.290 Balance 31.12 986,842 0.295 2,310,021 0.294 The Parent Company’s share price at the time options were exercised in January 2023 and in September 2023 was € 1.14 and € 1.38

respectively and the price at the time options were exercised in January 2024 and in September 2024 was € 1.60 and € 1.51 respectively.

The average duration of the active stock options is 5.0 months (31.12.2023: 8.3 months) out of which 481,626 stock options with an exercise

price of € 0.30 και 504,746 with an exercise price of € 0.29.

From 1 January to 31.12.2024 31.12.2023 Wages and salaries 267 243 Social security contributions 63 58 Group employee defined benefit obligation (1) Employee indemnity provision due to retirement based on Law 2112/1920 3 3 Other benefits and charges 37 30 Total 370 333

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

285 | ANNUAL FINANCIAL REPORT

Defined contribution plans

All employees of the Group are insured for their:

▪ main pension by the Electronic National Social Security Entity (e-E.F.K.A.)

▪ supplementary pension by the Electronic National Social Security Entity (e-E.F.K.A.). For employees starting employment after

1.1.2022 and employees who opted for it, the supplementary pension fund is the Hellenic Auxiliary Pensions Defined Contributions

Fund (T.E.K.A.)

▪ healthcare coverage by the National Organization of Health Care (EOPYY) and welfare benefits in kind by the relevant Sector of the

former T.A.Y.T.E.K.O. or the former E.T.A.A., both of which have been incorporated, since 1.1.2017, into to the Electronic National

Social Security Entity (e-E.F.K.A.).

In addition, for the Bank’s employees, the following also apply:

a. Supplementary Pension

Especially for employees of the former Ionian and Laiki Bank of Greece the supplementary pension fund is T.A.P.I.L.T.A.T., a multi-employer

fund. The Bank has obtained legal opinions that indicate that it has no obligation if this fund does not have sufficient assets to cover employee

benefits. Therefore, the Bank considers that the fund is a defined contribution plan and has accounted for it as such.

b. Pre-retirement Benefit

Employees hired by the former Alpha Credit Bank and the former Emporiki Bank who are eligible for pre-retirement benefits, according to the

terms and conditions of retirement of the respective insurance entities (T.A.P.T.P. and T.E.A.P.E.T.E.) are insured at the Single Insurance of

Bank Employees Fund (E.T.A.T.) as per Law 3371/2005, which was incorporated into the Single Social Security Entity (E.F.K.A.) as of 1.1.2017, as

per Law 4387/2016 and was renamed to Electronic National Social Security Entity (e-E.F.K.A.) as of 1.3.2020, as per Law 4670/2020.

c. Lump Sum Benefit

Employees of the former Ionian and Laiki Bank of Greece and the former Emporiki Bank are insured for the lump sum benefit in the “Bank

Employee and Companies Common Benefit Plan” (T.A.Y.T.E.K.O.) which is a defined contribution plan with contributions paid only by

employees. In accordance with Law 4387/2016, the relevant Sectors of the “Bank Employee and Companies Common Benefit Fund”

(T.A.Y.T.E.K.O.) consist part of the E.T.E.A.E.P. (Joint Supplementary Insurance and Lump Sum Benefits Fund).

d. IORP Alpha Services and Holdings Group Personnel

The IORP of Alpha Services and Holdings Group was established in March 2023 is a post-employment benefit plan for the benefit of the

employees of the Group of Alpha Services and Holdings, and regards those employees with indefinite duration labor contracts or those having

salaried mandate contracts relationship.

Employee defined benefit obligations

The analysis of Defined Benefit Plans is disclosed in note 35.

10. General Administrative expenses

The presentation of the General administrative expenses has been amended compared to the annual financial statements of 31.12.2023, in

order to provide better understanding of the evolution of the respective expenses. General administrative expenses decrease is mainly driven

by the absence of Contributions to the Resolution Fund for the year 2024.

From 1 January to 31.12.2024 31.12.2023 Building costs 28 31 Card schemes costs 11 10 IT expenses and Maintenance of IT equipment 66 59 Marketing and advertising expenses 25 22 Operational costs 31 31 Taxes and Duties (VAT, real estate tax etc.) 79 71 Third party fees 68 69 Regulatory fees and other related expenses 9 31 Other - 1 Total 317 325

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

286 | ANNUAL FINANCIAL REPORT

11. Impairment losses and provisions to cover credit risk

The following table presents the impairment losses and provisions to cover credit risk on loans and advances to customers and other financial

instruments, financial guarantee contracts, other assets, recoveries:

The calculation of expected credit losses incorporates a sale scenario with 100% probability for the loan portfolios that are classified as Held for

Sale. “Impairment losses/(gains)” on loans for 2024 include the below charges related to portfolios that have been classified as “Assets Held for

Sale” (note 52):

a. losses of € 137 mil. for non-performing mortgage and wholesale loans with GBV € 565 mil. as at 31.12.2024 (GAIA II perimeter),

b. losses of € 38 mil. for non-performing mortgage loans with GBV € 464 mil. as at 31.12.2024 (GAIA I perimeter),

c. losses of € 24 of Cypriot Non-Performing loans with a total GBV of € 135 as at 31.12.2024.

“Losses from modifications of contractual terms of loans and advances to customers” in 2023, also include the Bank’s initiative to cap the interest

rates of specific perimeter. Specifically, the Bank announced on 11.4.2023 that from 2.5.2023 and for a period of 12 months will reward

performing mortgage loan customers with floating-rate mortgage loans (as well as with floating consumer loans collateralized with a mortgage) by

introducing a cap to the base rate, in order to protect borrowers against future increases in reference rates.

During the current period the Group estimated that the extension for one more year of the protection program against the increase in interest

rates for consistent borrowers of floating rate mortgages constitutes in essence an adjustment of the base interest rates to the current market

interest rates for similar loans; thereby contributing to customer retention. Therefore, the modification of the cash flows of the loans due to the

extension of the protection was accounted for as a recalculation of their effective interest rate.

The group has included additional provisions from post model adjustments (PMA) as described in note 47.1

Amounts related to loans and advances to customers for which there was modification of the contractual terms are categorized as stage 2 or 3

or loans Purchased or originated credit impaired (POCI), are presented in the tables below.

From 1 January to Loans modified during the year 31.12.2024 31.12.2023 Net carrying amount before the modification 2,734 3,011 Net gain or (loss) due to the modification (15) (26) The following table represents the carrying amount of loans and advances to customers that modified at a time that had a lifetime expected credit loss and for

which the allowance is measured based on 12-month expected credit losses at the end of the year.

From 1 January to Loans categorized at Stage 1 31.12.2024 31.12.2023 Carrying amount before allowance for expected credit losses at the end of the year 2,632 2,30512. Expenses relating to credit risk management

Loan servicing fees arise from the serving agreement of Non-Performing loans, while commission expense for credit protection includes the

commission amount paid by the Bank in the context of synthetic securitisation transactions, in order to receive protection against part of the

credit risk of a specific portfolio of performing corporate loans. At the end of the financial year 2024, the Bank completed a new synthetic

transaction for wholesale loan portfolio, named Eleven.

From 1 January to 31.12.2024 31.12.2023 as restated Impairment (gains) / losses on loans 355 361 Impairment (gains) / losses on advances to customers (2) 6 Provisions to cover credit risk on letters of guarantee, letters of credit and undrawn loan commitments (note (5) (2) 43) (Gains) / Losses from modifications of contractual terms of loans and advances to customers 16 33 Recoveries (10) (14) Impairment losses on other assets 4 Impairment losses and provisions to cover credit risk on loans and advances to customers (a) 358 384 Impairment (gains) / losses on debt securities and other securities measured at amortized cost 1 (3) Impairment (gains) / losses on debt securities and other securities measured at fair value through other 1 comprehensive income Impairment losses and provisions to cover credit risk on other financial instruments (b) 2 (3) Total (a) + (b) 360 381

From 1 January to 31.12.2024 31.12.2023 Loan servicing fees 47 52 Commission expenses for credit protection 46 36 Total 93 88

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

287 | ANNUAL FINANCIAL REPORT

13. Impairment losses on fixed assets and equity investments

14. Gains/(Losses) on disposal of fixed assets and equity investments

15. Provisions

Line “Provisions for voluntary separation schemes” within 2024 relates to the new Voluntary Separation Scheme (VSS) that the Executive

Committee approved on 20 December 2024 with a total cost of € 58 as part of the Bank’s strategic plan and € 4 for the subsidiaries.

As a result of the new scheme, provisions of € 7 that related to the previous 2023 targeted separation scheme were released, thus a net cost of

€ 55 was recognised in the income statement.

For 2023 Line “Provisions for voluntary separation schemes” includes a total cost of € 64 related to a Voluntary Separation Scheme (VSS)

program and a targeted separation program. Provisions of the previous 2021 VSS of € 25 were reversed.

16. Transformation costs

The line item “Transformation costs” includes the costs recognized amounting to € 14 (31.12.2023: € 4) that relates to projects and initiatives

carried out by the Group that lead to significant changes in its operational model, towards its transformation which is part of its Strategic Plan

2023-2025, with the aim of enhancing the organization's efficiency, optimizing the commercial model and further strengthening the

performance measurement and reward systems in all functions.

17. Income tax

Τhe income tax rate for legal entities is set to 22%, for the income of tax year 2021 and afterwards while the financial institutions the income

tax rate is 29%.

For the subsidiaries and branches operating in other countries, the applicable nominal tax rates for the year 2024 are as follows: Cyprus 12.5 Luxembourg 24.94 Bulgaria 10 Jersey 10 Serbia 15 United Kingdom 25* Romania 16 Ireland 12.5 * From 6 April 2023 the tax rate in the UK changed to 25% for companies with large profits (over £50,000) and 19% for companies with small profits (under £50,000)

The current tax amount for the 2024 financial year includes a reversal of a previously recognized provision of €22 due to a reassessment of the

probability of recovering receivables from withheld taxes.

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 31.12.2024 31.12.2023 Impairment losses/write-offs on property plant and equipment, investment property, intangible assets and 10 8 right-of-use assets Impairment losses on inventories 3 1 Impairment losses on non-financial assets or disposal groups held for sale (Note 52) 2 10 Total 15 19

From 1 January to 31.12.2024 31.12.2023 Gains/(losses) from disposal of equity investments (1) 1 Gains/(losses) from disposal of property, plant and equipment, investment property and intangible assets 1 2 Gains/(losses) from disposal of inventories 2 5 Gains/(losses) from disposal of non-financial assets or disposal groups held for sale (Note 52) 25 (5) Total 27 3

From 1 January to 31.12.2024 31.12.2023 Provisions for pending legal cases 6 Provisions for voluntary separations schemes 55 39 Other provisions 30 1 Total 8546

The income tax in the Income Statement is analyzed as follows: From 1 January to 31.12.2024 31.12.2023 Current tax 59 (7) Deferred tax 160 233 Total 219 226

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

288 | ANNUAL FINANCIAL REPORT

From 1 January to 31.12.2024 31.12.2023 Debit difference of Law 4046/2012 45 45 Debit difference of Law 4465/2017 170 (7) Write-offs, depreciation, impairment of plant, property and equipment and leases 23 (29) Loans (99) 184 Valuation of loans due to hedging 3 Defined benefit obligation and insurance funds (1) 1 Valuation of derivative financial instruments 44 (3) Valuation of liabilities to credit institutions and other borrowed funds due to fair value hedge (43) (29) Valuation/Impairment of investments (4) 4 Valuation/Impairment of debt securities and other securities 30 62 Tax losses carried forward 8 (2) Other temporary differences (13) 4 Total 160 233 Pursuant to article 24 par. 8 of Law 4172/2013, the new established credit institution Alpha Bank Societe Anonyme made use of the beneficial

provisions of the law and postponed the depreciation for tax purposes of its fixed assets during the first three fiscal years.

Based on Circular 1073/31.3.2015 of Independent Authority for Public Revenue, the deferral of tax depreciation does not include the

amortization of the debit difference of article 27 par. 2 of Law 4172/2013 (loss from the exchange of Greek government bonds) and of the

debit difference of article 27 par.3 of Law 4172/2013 (loss from final write-off or transfer of bad debts). As of 1.1.2024, the above period has

lapsed for the Bank, and tax depreciation on are calculated regularly.

A reconciliation between the effective and nominal tax rate is provided below:

The nominal tax rate is the average tax rate resulting from the income tax, based on the nominal tax rate, and the pre-tax results, for the

parent and for each of the Group’s subsidiaries.

In the line "Other tax adjustments", the Bank, after reassessing the possibility of recovering receivables from withheld taxes, has included the

reversal of € 22 provisions.

Income tax of other comprehensive income recognized directly in equity

From 1 January to 31.12.2024 31.12.2023 Before Income After Before Income After Income tax tax Income tax Income tax tax Income tax Amounts that may be reclassified to the Income Statement Net change in the reserve of debt securities measured at fair value through other 11 (2) 9 59 (14) 45 comprehensive income Net change in cash flow hedge reserve 31 (9) 22 35 (10) 25 Currency translation differences from financial statements and net investment hedging 36 11 47 - of foreign operations 78 - 78 94 (24) 70 Amounts that will not be reclassified to the Income Statement Net change in actuarial gains/(losses) of defined benefit obligations - (2) 1 (1) Gains/(Losses) from equity securities measured at fair value through other (12) 4 (8) 10 (3) 7 comprehensive income (12) 4 (8) 8 (2) 6 Total 66 4 70 102 (26) 76 The amounts in the above table also include the amounts related to discontinued operations.

From 1 January to 31.12.2024 31.12.2023 % % Profit / (Loss) before income tax 816 780 Income tax (nominal tax rate) 29.04 237 28.46 222 Increase / (Decrease) due to: Non-taxable income (0.61) (5) (0.90) (7) Non-deductible expenses 1.10 9 0.77 6 Recognition of deferred tax for tax losses carried forward from previous years - - (1.28) (10) Non-recognition of deferred tax for tax losses carried forward 0.74 6 3.97 31 Other tax differences (3.43) (28) (2.05) (16) Income tax (nominal tax rate) 26.84 219 28.97 226

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

289 | ANNUAL FINANCIAL REPORT

18. Earnings/(losses) per share

a. Basic

Basic earnings/(losses) per share are calculated by dividing the net profit/(losses) for the year, attributable to ordinary equity holders of the

Company, adjusted for the AT1 coupon payment, by the weighted average number of ordinary shares outstanding during the period, excluding

the weighted average number of own shares held, during the period.

In January 2025, stocks were repurchased and stock options were exercised as disclosed in note 57.

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.

From 1 January to 31.12.2024 31.12.2023 Adjusted Profit / (Loss) attributable to equity holders of the Company 654 618 Minus: Return on capital instruments “AT1” (48) (24) Adjusted Profit / (Loss) for the AT1 coupon payment 606 594 Weighted average number of outstanding ordinary shares 2,313,800,720 2,347,568,116 Basic earnings /(losses) per share (in €) 0.2619 0.2531 From 1 January to 31.12.2024 31.12.2023 Adjusted Profit / (Loss) from continued operations attributable to equity holders of the Company 597 554 Minus: Return on capital instruments “AT1” (48) (24) Adjusted Profit / (Loss) for the AT1 coupon payment 549 530 Weighted average number of outstanding ordinary shares 2,313,800,720 2,347,568,116 Basic earnings /(losses) per share (in €) 0.2374 0.2256 From 1 January to 31.12.2024 31.12.2023 as restated Profit / (Loss) from discontinued operations attributable to equity holders of the Company 57 64 Minus: Return on capital instruments “AT1” Adjusted Profit / (Loss) for the AT1 coupon payment 57 64 Weighted average number of outstanding ordinary shares 2,313,800,720 2,347,568,116 Basic earnings /(losses) per share (in €) 0.0245 0.0275

From 1 January to 31.12.2024 31.12.2023 Adjusted Profit / (Loss) attributable to equity holders of the Company 654 618 Minus: Return on capital instruments “AT1” (48) (24) Adjusted Profit / (Loss) for the AT1 coupon payment 606 594 Weighted average number of outstanding ordinary shares 2,313,800,720 2,347,568,116 Stock awards 2,033,796 25,544 Adjustment for options 924,452 3,321,633 Weighted average number of outstanding ordinary shares for diluted earnings per share 2,316,758,968 2,350,915,293 Diluted earnings /(losses) per share (in €) 0.2616 0.2528 From 1 January to 31.12.2024 31.12.2023 Adjusted Profit / (Loss) from continued operations attributable to equity holders of the Company 597 554 Minus: Return on capital instruments “AT1” (48) (24) Adjusted Profit / (Loss) for the AT1 coupon payment 549 530 Weighted average number of outstanding ordinary shares 2,313,800,720 2,347,568,116 Adjustment for stock awards 2,033,796 25,544 Adjustment for options 924,452 3,321,633 Weighted average number of outstanding ordinary shares for diluted earnings per share 2,316,758,968 2,350,915,293 Diluted earnings /(losses) per share (in €) 0.2371 0.2253

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

290 | ANNUAL FINANCIAL REPORT

From 1 January to 31.12.2024 31.12.2023 Profit / (Loss) from discontinued operations attributable to equity holders of the Company 57 64 Minus: Return on capital instruments “AT1” Adjusted Profit / (Loss) for the AT1 coupon payment 57 64 Weighted average number of outstanding ordinary shares 2,313,800,720 2,347,568,116 Adjustment for stock awards 2,033,796 25,544 Adjustment for options 924,452 3,321,633 Weighted average number of outstanding ordinary shares for diluted earnings per share 2,316,758,968 2,350,915,293 Diluted earnings /(losses) per share (in €) 0.0245 0.0275

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

291 | ANNUAL FINANCIAL REPORT

ASSETS

19. Cash and balances with Central Banks

Cash and cash equivalents (as presented in the Consolidated Statement of Cash Flows)

20. Due from financial institutions

The Bank since 2016 participates in the collection of financial means to the Single Resolution Fund (SRF) in cash and in the form of irrevocable

payment commitments (IPCs) backed by collateral at the disposal of the Fund. Payment commitments are accounted in accordance with IAS 37

as contingent liabilities, initially recognized as off balance sheet items, while subsequently assessed if the outflow of economic resources is

probable that would lead to the recognition of a relevant provision. The cash amount pledged as collateral is recognized as a pledged asset in

the Balance sheet. As of 31.12.2024 the outflow of resources was not considered probable, hence payment commitments are treated as

contingent liabilities. For the years 2016-2024 the notional amount of collateral provided for irrevocable payment commitments is € 30.

After the cancellation of the appeal filed by a French banking institution for the return of the collateral related to irrevocable payment

commitments, which was submitted following the revocation of its banking license, the Bank is awaiting the outcome of the appeal filed by the

French banking institution before the General Court of the European Union, . This will allow the Bank to assess whether the relevant

accounting treatment should be amended.

In the event of an unfavorable court decision and depending on the legal wording of the ruling, the maximum amount by which the Bank’s net

equity could be impacted would be € 30 with no effect on the Group’s capital ratios, as the total amount of irrevocable payment commitments

is deducted from supervisory capital.

21. Trading securities

The following table presents an analysis of the carrying amount of trading portfolio per type of security:

31.12.2024 31.12.2023 Cash 448 485 Cheques receivables 11 8 Balances with Central Banks 2,539 3,726 2,998 4,219 Less: Deposits pledged to Central Banks (504) (496) Total 2,494 3,723

31.12.2024 31.12.2023 Cash and balances with central banks 2,494 3,723 Securities purchased under agreements to resell (Reverse Repos) 216 124 Short-term placements with other banks 336 586 Total 3,046 4,433

31.12.2024 31.12.2023 Due from financial institutions 311 418 Reverse Repos 985 262 Pledged deposits 1,070 962 Less: Allowance for expected credit losses (70) (70) Total 2,296 1,572

31.12.2024 31.12.2023 Bonds: - Greek Government4 4 - Other Sovereign7 - Other issuers6 5 Treasury Bills: - Greek Government11 Equity securities: - Listed 25 24 Total 53 33

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

292 | ANNUAL FINANCIAL REPORT

22. Derivative financial instruments (assets and liabilities)

Hedging accounting

a. Fair value hedges

The Group uses interest rate swaps to hedge its exposure to changes in the fair values due to changes in market rates of fixed interest rate: a)

Bonds, b) specific corporate loan c) bond issued and d) first demand deposits.

More specifically, with regards to deposits, it is noted that the Group applied interest rate hedging accounting on a deposit portfolio, making

use of the provisions on hedge accounting adopted by the European Union (EU Carve-out).

Duration, nominal amount, interest rate and currency rate of hedging instruments of 31.12.2024 and 31.12.2023 are summarized as follows:

31.12.2024 31.12.2023 Hedging Relationship Nominal amount Average fixed Nominal amount of the Average fixed Duration of the derivative interest derivative interest 500 3.85% <1 year Senior Preferred Bond issued by the Bank 1,750 2.98% 1,350 2.77% 1 – 5 years 500 (0.27)% 500 (0.27)% >5 yearsTier II Bond issued by the Alpha Holdings and Services 1,131 1.24% 1,000 (0.21)% 1 – 5 years First Demand Deposits 7,500 3.15% 1,000 3.49% 1 – 5 years Bonds at amortized cost (AC) 4,850 2.73% 3,430 2.77% >5 yearsCorporate loans 236 2.37% 238 2.37% >5 yearsSenior securitisation bonds, classified as loans at >5 years450 2.50% amortised cost Securities measured at fair value through OCI 4 2.59% >5 years

31.12.2024 31.12.2023 Contractual Fair Value Contractual Fair Value Nominal Nominal Assets Liabilities Assets Liabilities Amount Amount Derivatives held for trading purposes a. Foreign exchange derivativesForeign exchange forwards 696 14 12 628 8 6 Foreign exchange swaps 1,043 1 10 851 14 3 Cross currency swaps 404 16 13 355 7 8 Currency options 1 14 Total non-listed 2,144 31 35 1,848 29 17 b. Interest rate derivativesInterest rate swaps 55,773 1,636 1,587 36,420 1,656 1,649 Interest rate options (caps and floors) 6,563 25 21 3,705 29 26 Total non-listed 62,336 1,661 1,608 40,125 1,685 1,675 Futures 430 1 492 1 Total listed 430 1 - 492 1 - c. Commodity derivativesCommodity swaps 111 4 4 108 7 6 Total non-listed 111 4 4 108 7 6 d. Index derivativesIndex swaps 39 39 OTC options 627 24 25 508 16 17 Total non-listed 666 24 25 547 16 17 Futures 39 26 1 Total listed 39 - - 26 - 1 e. Other derivativesGDP linked security 697 2 695 1 Total-listed 697 2 695 1 Derivatives for hedging a. Foreign exchange derivativesForeign exchange swaps 264 1 82 1 Cross currency swaps 153 2 372 1 12 Total non-listed 417 - 3 454 1 13 b. Interest rate derivativesInterest rate swaps 16,772 234 294 8,368 79 275 Total non-listed 16,772 234 294 8,368 79 275 Grand Total before offset 83,612 1,957 1,969 52,663 1,819 2,004 Amounts used for offset within the Balance Sheet - (1,329) (1,176) - (1,092) (1,070) Grand Total after offset 83,612 628 793 52,663 727 934

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

293 | ANNUAL FINANCIAL REPORT

The balance sheet and the income statement amounts relating to fair value hedging instruments and the hedge effectiveness are analyzed as follows:

2024 Hedging relationship Carrying amount of hedging Financial line item in the Gain/(loss) from fair value change of Financial line item in the Ineffectiveness gain/(loss) instrument balance sheet where the hedging instrument used for Income statement that Derivative Type recognized in the income hedging instrument is calculating the hegde effectiveness included hedge Assets Liabilities statement for 2024 included for 2024 ineffectiveness Interest rate risk Bonds at amortized cost (AC) 36 230 (65) 9 Corporate Loans 1 (2) Senior Bonds issues 43 27 23 Tier II Bonds issues 8 16 33 1 First Demand Deposits 147 5 Derivative Financial 64 (1) Gains less losses on financial Interest rate swap Senior securitisation bonds, Instruments transactions (4) classified as loans at amortised 4 cost Securities measured at fair 1 value through OCI 2023 Carrying amount of hedging instrument Financial line item in the Gain/(loss) from fair value change of Ineffectiveness gain/(loss) Financial line item in the Income balance sheet where the hedging instrument used for Hedging relationship Derivative Type recognized in the income statement that included hedge Assets Liabilities hedging instrument is calculating the hegde effectiveness statement for 2023 ineffectiveness included for 2023 Interest rate risk Bonds at amortized cost (AC) 40 153 (158) (8) Corporate Loans (11) Derivative Financial Gains less losses on financial Senior Bonds issues Interest rate swap 21 47 48 (1) Instruments transactions Tier II Bonds issues 54 37 First Demand Deposits 18 13 1

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

294 | ANNUAL FINANCIAL REPORT

The amounts related to balance sheet items designated as hedged items are analyzed as follows:

2024 Accumulated amount of fair value hedge Change in fair value of Carrying Amount adjustments on the hedged item Financial line item in the balance sheet where the hedged item used for Hedging relationship hedged item is included calculating the hedge Assets Liabilities Assets Liabilities effectiveness Interest rate risk Bonds at amortized cost (AC) 5,789 162 Investment securities measured at amortized cost 74 Corporate Loan 244 1 Loans and advances to customers 2 Senior Bond issues 1,879 (6) (23) Debt securities in issue and other borrowed funds Tier II Bonds issues 1,124 (6) (32) First Demand Deposits 7,520 77 Due to Customers (65) Galaxy Senior Bonds, classified as Loans at Senior securitisation bonds, classified as loans at amortised cost 526 4 4 amortised cost Securities measured at fair value through OCI 5 Securities measured at fair value through OCI 2023 Accumulated amount of fair value hedge Change in fair value of hedged Carrying Amount Financial line item in the balance sheet where the hedged Hedging relationship adjustments on the hedged item item used for calculating the item is included Assets Liabilities Assets Liabilities hedge effectiveness Interest rate risk Bonds at amortized cost (AC) 4,558 95 Investment securities measured at amortized cost 149 Corporate Loan 247 Loans and advances to customers 11 Senior Bond issues 1,847 (29) (49) Debt securities in issue and other borrowed funds Tier II Bonds issues 956 (49) (38) First Demand Deposits 1,013 13 Due to Customers (13)

b. Cash flow hedges

At 31.12.2024 the following cashflow hedge relationships are in effect:Risk Category Duration 1 - 5 years Interest rate risk Loans with floating rate at the amount of € 350 Nominal amount of the derivative 350 Average fixed interest rate 0.02%

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

295 | ANNUAL FINANCIAL REPORT

The balance sheet and the income statement amounts relating to open cash flow hedging relationships and the amortization of the reserve in the current period that was formed at the date of termination of

the cashflow hedge for term deposits are analyzed as follows:

31.12.2024 Carrying Change in fair value of hedged item used Change in fair value of hedging Amounts reclassified from cash flow hedging Income statement line affected Derivative Amount Hedging Relationship for calculating the hedge effectiveness in instrument recognized in cash reserve to the income statement in 2024 by the terminated hedging Type 2024 flow hedging reserve in 2024 from terminated hedging relationships relationships Liabilities Interest rate risk Loans with floating rate at the amount of Interest Rate 10 11 11 € 350 Net interest income Swap Term deposits and renewals (21) The amounts that have been recognized in the cashflow hedge reserve at 31.12.2024 are analyzed as follows:

31.12.2024 Line item in the balance sheet Cash flow hedging reserve (before tax) for Cash flow hedging reserve (before tax) for terminated Cash flow hedging reserve where the hedged item is included active hedging relationships hedging relationships (before tax) Interest rate risk Loans with floating rate at the amount of € 350 Loans and advances to customers (10) (10) Term deposits and renewals Due to customers (232) (232) As at 31.12.2023 the following cashflow hedge relationships were in effect

Risk Category Duration 1 - 5 years Interest rate risk Loans with floating rate at the amount of € 350 million Nominal amount of the derivative 350 Average fixed interest rate 0.02%

The balance sheet and the income statement amount relating to open cash flows hedging relationships as at 31.12.2023 and the amortization of the reserve in the corresponding period that was formed at the

date of termination of the cashflow hedge for term deposits during the previous period are analyzed as follows:

31.12.2023 Carrying Amount Change in fair value of hedging item Amounts reclassified from cash flow hedging Income statement line Derivative Change in fair value of hedged item used for Hedging Relationship recognized in cash flow hedging reserve reserve to the income statement in 2023 from affected by the terminated Type Liabilities calculating the hedge effectiveness in 2023 in 2023 terminated hedging relationships hedging relationships Interest rate risk Loans with floating rate at 21 14 14 the amount of € 350 mil. Interest Rate Net interest income Term deposits and Swap (21) renewals

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

296 | ANNUAL FINANCIAL REPORT

The amounts that have been recognized in the cashflow hedge reserve at 31.12.2023 are analyzed as follows:

31.12.2023 Line item in the balance sheet Cash flow hedging reserve (before tax) for Cash flow hedging reserve (before tax) for Cash flow hedging reserve (before tax) where the hedged item is included active hedging relationships terminated hedging relationships Interest rate risk Loans with floating rate at the amount of € 350 mil. Loans and advances to customers (21) (21) Term deposits and renewals Due to customers (253) (253)

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

297 | ANNUAL FINANCIAL REPORT

c. Hedging of net investment in foreign subsidiaries

The Group hedges part of the net investment in RON through foreign exchange swap derivatives. In addition, the Group hedges part of the net

investment in GBP in the subsidiary Alpha Bank London through forward foreign exchange derivative transactions that are renewed.

The hedging instruments as at 31.12.2024 and 31.12.2023 are summarized as follows:

31.12.2024 31.12.2023 Currency Nominal amount in Euro Currency Nominal amount in Euro Investment in Alpha Bank London Duration < 1 year Duration < 1 year FX Swaps - EUR/GBP GBP 59 GBP 56 Exchange rate GBP/EUR 0.83 0.87 Investment in subsidiaries (RON) Duration < 1 year Duration < 1 year Fx Derivatives RON 35 RON 412 Exchange rate RON/EUR 4.97 4.98 Investment in Subsidiaries (RON) 1-5 years Fx Derivatives RON 10 Exchange rate RON/EUR 4.97 Investment in Associates (RON) Duration < 1 year Fx Swaps and Cross Currency Interest Rate Swaps RON 303 Exchange rate RON/EUR 4.97 Investment in Associates (RON) 1-5 years Fx Swaps and Cross Currency Interest Rate Swaps RON 10 Exchange rate RON/EUR 4.97 The balance sheet and the income statement amounts relating to hedging of net investment in foreign subsidiaries and the effectiveness of

the hedge are analyzed as follows:

Assets

Liabilities

Assets

Liabilities

31.12.2024 Line item in the Change in fair value of hedging Change in the fair value of the Change in the fair value of the balance sheet where instrument for the hedging instrument recognized Hedging instrument hedging instrument recognized in the hedge item is measurement of the hedge in the income statement in the the reserve for the year 2024 included effectiveness for the year 2024 year 2024 CCIRS - EUR/GBP (3) (3) Derivatives Fx swaps & CCIRS 1 Fx swaps & CCIRS 2 31.12.2023 Line item in the Change in fair value of hedging Change in the fair value of the Change in the fair value of the balance sheet where instrument for the hedging instrument recognized Hedging instrument hedging instrument recognized in the hedge item is measurement of the hedge in the income statement in the the reserve for the year 2023 included effectiveness for the year 2023 year 2023 FX Swaps - EUR/GBP (1) (1) Derivatives Fx swaps 13 2 2

The amounts related to hedged items as of 31.12.2024 and 31.12.2023 are analyzed as follows: 31.12.2024 31.12.2023 Change in fair value Balance of foreign Change in fair value Foreign Foreign Balance of foreign exchange for the exchange differences for the Exchange Exchange differences reserve due to measurement of reserve due to measurement of differences differences discontinued hedging the hedge discontinued hedging the hedge reserve reserve relationships effectiveness relationships effectiveness Investment in Alpha Bank 3 (12) 1 (13) London Investment in 2 (2) (32) subsidiaries (RON) An amount of € 34 was reclassified to the profit and loss of the year from the foreign exchange reserve in 2024 due to the sale of a 90.1% stake

in Alpha Bank Romania within the framework of the agreement with Unicredit.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

298 | ANNUAL FINANCIAL REPORT

23. Loans and advances to customers

The balances of “Advances to customers measured at fair value through profit or loss” and “Advances to customers measured at amortized

cost” mainly include the deferred considerations arising from the completion of NPE portfolio sale transactions.

As at 31.12.2024 the gross balance of “Advances to customers measured at amortised cost” amounted to € 329 (31.12.2023: € 233) and the

allowance for expected credit losses amounted to € 38 (31.12.2023: € 46).

Loans measured at amortised cost

completed during 2021, targeting to non-performing exposure reduction.

In addition, the Group holds a portfolio of loans that have been securitized through special purpose entities controlled by the Group. As per the

contractual terms and the structure of the above transactions it is evident that the Group retains in all cases the risks and rewards arising from

the securitized portfolios.

The Group assesses loan sales from the holding business model with the aim of collecting contractual flows and confirms that the sales made

do not affect this business model.

It is mentioned that the Group possess loans that have been classified as “Assets Held for Sale”, as explained in note 52.

31.12.2024 31.12.2023Loans measured at amortised cost 38,440 35,722 Leasing 198 194 Less: Allowance for expected credit losses (601) (842) Total 38,037 35,074 Advances to customers measured at amortised cost 291 187 Advances to customers measured at fair value through profit or loss 595 528 Loans measured at fair value through profit or loss 127 372 Loans and advances to customers 39,050 36,161

31.12.2024 31.12.2023 Individuals Mortgages - Non-securitized5,165 5,115 - Securitized1,719 2,215 Consumer: - Non-securitized768 688 - Securitized435 555 Credit cards: - Non-securitized368 341 - Securitized494 520 Other 5 4 Total loans to individuals 8,954 9,438 Corporate: Corporate loans: - Non-securitized23,172 19,016 - Securitized580 1,380 Leasing: - Non-securitized198 52 - Securitized142 Factoring 831 726 Senior Notes 4,903 5,162 Total corporate loans 29,684 26,478 Total 38,638 35,916 Less: Allowance for expected credit losses (601) (842) Total loans measured at amortised cost 38,037 35,074In “Loans portfolio measured at amortized cost” the Group has recognized the senior notes of Galaxy and Cosmos transactions which were

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

299 | ANNUAL FINANCIAL REPORT

The movement of allowance for expected credit losses on loans, that are measured at amortized cost, is presented below:

Allowance for expected credit losses

Balance 1.1.2023 1,095 Changes for the year 1.1. - 31.12.2023 Impairment losses for the year 315 Transfer of allowance for expected credit losses from / (to) Assets held for sale (307) Derecognition due to substantial modifications in loans’ contractual terms (1) Change in present value of the impairment losses 4 Foreign exchange differences (1) Disposal of impaired loans (1) Loans written-off during the year (265) Other movements 3 Balance 31.12.2023 842 Changes for the year 1.1 - 31.12.2024 Impairment losses for the year 297 Transfer of allowance for expected credit losses from / (to) Assets held for sale (397) Change in present value of the impairment losses 8 Foreign exchange differences (2) Loans written-off during the year (148) Other movements 1 Balance 31.12.2024 601

“Impairment losses for the year” 2024 presented in the table above, differ from the amount presented in line “Impairment losses/(gains) on

loans” of note 8 mainly due to:

a. A loss of € 63 related to impairment losses that have been recognized during the year with regards to loans that had been

transferred to assets held for sale on 31.12.2023 or following their classification as held for sale within the reporting period.

b. A gain of € 3 related to fair value adjustment of the contractual balance of loans which were impaired at their acquisition or

origination (POCI) is not included. This adjustment does not impact the accumulated impairments since it is included in the gross

carrying value of the loans.

Finance lease receivable is analyzed by duration as follows:

The net amount of finance lease receivables are analyzed as follows, based on their duration:

During 2024 the Bank sold loans amounting € 313 (2023: € 126) which were held within the “hold to sell” business model.

31.12.2024 31.12.2023 Up to 1 year 34 71 From 1 year to 5 years 139 123 Over 5 years 73 38 246 232 Non accrued finance lease income (48) (38) Total 198 194

31.12.2024 31.12.2023 Up to 1 year 28 60 From 1 year to 5 years 124 103 Over 5 years 46 31 Total 198 194

Loans measured at fair value through profit or loss 31.12.2024 31.12.2023 Corporate: Corporate loans - Non-securitized126 370 Galaxy and Cosmos securitization bonds 1 2 Total corporate loans 127 372 Total loans to customers measured at fair value through profit or loss 127 372

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

300 | ANNUAL FINANCIAL REPORT

24. Investment securities

An analysis of investment securities is provided in the following tables per classification category, per type of security.

Investment portfolio equity securities measured at fair value through other comprehensive income

The Group has made the irrevocable election on initial recognition to measure at fair value through other comprehensive income equity

instruments that have the following characteristics:

a) Shares in companies of the financial sector (credit institutions and interbank companies),

b) Investments in private equity (shares of venture capital or private equity),

c) Equity shares received in exchange for debt forgiveness in the context of debt restructurings and

d) Shares held in long term investment horizon.

The following table presents the equity shares of investment portfolio measured at fair value through other comprehensive income as of

31.12.2024 and as of 31.12.2023.

Fair Value Dividend income from 1.1 to Fair Value Dividend income from 31.12.2024 31.12.2024 31.12.2023 1.1. to 31.12.2023 Investments in financial industry entities 6 1 17 1 Investments in private equity 16 13 Shares acquired through debt swap agreements 1 3 Long term equity holdings 17 1 19 1 Total 40 2 52 2

The movement of the balance of Investments in financial industry entities for 2024 includes losses due to the absorption of Pancretan Bank by

Attica Bank that combined with the share capital increase of the latter that diluted the value of the existing shareholder. At the date of

derecognition of the Pancretan shares, their fair value amounted to €1 and the Group recognized cumulative losses of €3 in retained earnings.

b. Investment securities measured at amortized cost

31.12.2024 31.12.2023 Before Impairment Amortized Before Impairment Amortized Cost impairment Cost impairment Greek Government - Bonds 7,997 (8) 7,989 6,988 (7) 6,981 - Treasury bills34 34 Other Governments - Bonds 4,354 (3) 4,351 4,029 (2) 4,027 Other issuers - Listed 4,088 (9) 4,079 3,455 (10) 3,445 - Non-Listed1 1 3 3 Total 16,440 (20) 16,420 14,509 (19) 14,490

The Group evaluates sales from the hold to collect business model aiming to collect the contratual cash flows and confirms that the sales made

do not affect this business model.

31.12.2024 31.12.2023 Investment Securities measured at fair value through other comprehensive income 1,009 1,369 Investment Securities measured at fair value through profit or loss 167 159 Investment Securities measured at amortized cost 16,420 14,490 Total 17,596 16,018

a. Investment securities measured at fair value through other comprehensive income31.12.2024 31.12.2023 Greek Government - Bonds 233 233 - Treasury bills539 907 Other Governments - Bonds 143 113 Other issuers - Listed 54 64 Equity securities - Listed 17 28 - Non listed23 24 Total 1,009 1,369

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

301 | ANNUAL FINANCIAL REPORT

25. Investments in associates and joint ventures

31.12.2024 31.12.2023 Opening Balances 100 99 New associates / Joint ventures 414 1 Dividends (8) (Returns) / Share Capital Increases 63 (1) Share of profits/(losses) and other comprehensive income 1 1 Total 570 100 The companies over which the Group exercises significant influence or joint control are presented in detail in note 44. The table below

presents the book value of each associate and joint venture which the Group consolidates using the Equity method. Group’s share on equity From 1 January to 31.12.2024 31.12.2023 a. Associates Bank Information Systems S.A. 1 Nexi Payments Greece S.A. 32 34 Alpha Investment Property Elaionas S.A 58 (5) Cepal Holdings S.A. 38 40 Perigenis Commercial Property S.A. 15 15 Toorbee Travel Services Limited 1 1 Skyline Properties M.S.A. 83 Alpha Bank Romania S.A. 54 UniCredit Bank S.A. 275 Total (a) 556 86 b. Joint ventures APE Commercial Property Α.Ε. 4 4 Alpha ΤΑΝΕΟ A.K.E.S. 4 4 Panarae Saturn LP 2 2 Alpha Investment Property Commercial Stores S.A. 4 4 Total (b) 14 14 Total (a+b) 570 100

Other information for associates and joint ventures and significant restrictions

With the exception of Group’s participation in Olganos S.A. which is fully impaired and the Group has ceased recognizing its participation to

losses amount of € 1, there are no other cases where the Group has seized such recognition of losses.

With respect to any contingent liabilities of the Group related to its participation in associates or joint ventures or significant unrecognized

commitments of the Group that could lead to a future outflow of cash or other resources, the only case concerns the contractual texts of the

Skyline Properties M.S.A transaction, which stipulate that for a period of 3 years after the closing of the Skyline transaction, if Skyline

Properties M.S.A. has not completed the sale of the properties whose development strategy is "sale", then Skyline Properties M.S.A. will have

the right to sell to the Group the remaining properties of this strategy, which, however, may not cumulatively exceed € 15 in terms of prices at

which the initial recognition of these properties from the Group to Skyline Properties M.S.A took place. These sales will be made at prices that

will incorporate a surcharge of 20% compared to the prices at which the initial recognition of these properties from the Group to Skyline

Properties M.S.A took place.

There are no significant restrictions for the associates or joint ventures to transfer capital in the Group or to repay the loans that have been

granted by the Group apart from the restrictions imposed by the regulatory framework in which supervised associates operate in terms of

their capital adequacy and the restrictions that apply by Law 4548/2018 for Greek companies in connection with the minimum required share

capital and equity and the ability to distribute dividends.

Investments in significant associates and joint ventures

The Group considers as significant the associates presented in the table below, by taking into account the activities that are considered to be

of strategic importance as well as the carrying amount of the Group’s participation in the companies and of the loans and receivables that are

part of the Group’s net investment in the companies, if any. There is no joint venture of the Group that has been assessed as significant.

Significant Associate Operation Country Alpha Bank Romania S.A. Bank Romania

c. Investment securities measured at fair value through profit or loss31.12.2024 31.12.2023 Other issuers: - Listed 10 10 - Non listed4 Equities securities - Listed 67 64 - Non listed70 48 Other variable yield securities 20 33 Total 167 159

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

302 | ANNUAL FINANCIAL REPORT

Significant Associate Operation Country UniCredit Bank S.A. Bank Romania Skyline Real Estate S.M.S.A. Real Estate Management Greece Cepal Holdings S.A. Management of Claims from Loans and Credits Greece Alpha Investment Property Elaionas S.A. Real Estate Management Greece NEXI Payments Greece S.A. Other Monetary Intermediation Services Greece Associates on the above table are not listed in any market and thus there is no reference for their fair value.

Below there is a summary of the condensed financial information of the above mentioned companies. Cepal Alpha Investment Nexi Alpha Bank Skyline Unicredit Condensed Statement of Total Comprehensive Income 31.12.2024Holdings Property Elaionas Payments Romania GroupBank S.A.S.A.S.A.Greece S.A.S.A.Interest and similar income15246Fee and commission income141317Other income20325Profit/(losses) before income tax28(4)(8)-30(47)Profit/(losses) for the year23(4)(14)-26(41)Total comprehensive income after income tax23(4)(14)-26(41)Amount attributed to the participation of the Group to profits/(losses) 5 (2) (1) 3 (4) of the associate Since 20.12.024 Skyline Properties S.M.S.A. is an associate and thus it had no contribution to the Consolidated Income Statement of 2024.

Alpha Alpha Cepal Nexi Investment Skyline Unicredit Bank Condensed Balance Sheet 31.12.2024 Holdings Payments Property Group Bank S.A. Romania S.A. Greece S.A. Elaionas S.A. S.A. ASSETS Cash and balances with central banks 45 106 3,922 450 Due from banks 37 499 Derivative financial assets 33 Loans and advances to customers 7,712 3,129 Investment securities 2,668 354 Other assets 352 116 325 242 217 87 Total Assets 352 116 370 348 14,590 4,520 LIABILITIES Due to banks 490 104 Derivative financial liabilities 32 Due to customers 10,618 3,575 Debt securities in issue and other borrowed funds 1,327 307 Liabilities for current income tax 10 Other liabilities 118 73 119 370 87 Total Liabilities 118 - 73 119 12,848 4,073 EQUITY 234 116 297 229 1,743 446 Total Liabilities and Equity 352 116 370 348 14,590 4,520 Group participation (%) 20.00% 50.00% 9.99% 35.00% 9.90% 9.90% Equity shareholding 47 58 30 80 173 44 Valuation adjustments at initial recognition/impairments (9) 2 4 102 10 Carrying amount of participation 38 58 32 84 275 54 Loan that is part of the net investment Net investment 38 58 32 84 275 54

Within the reporting period, the group received a dividend of € 8 from the associate company Cepal Holdings S.A.

Alpha Nexi Alpha Cepal Unicredit Investment Payments Skyline Bank Condensed Statement of Total Comprehensive Income 31.12.2023Holdings Bank Property Greece GroupRomania S.A.S.A.Elaionas S.A.S.A.S.A.Interest and similar incomeFee and commission income124Other income2062Profit/(losses) before income tax19(6)4---Profit/(losses) for the year15(6)(5)---Total comprehensive income after income tax15(6)(1)---Amount attributed to the participation of the Group to profits/(losses) of the 3 (3) - associate

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

303 | ANNUAL FINANCIAL REPORT

Alpha UnicreAlpha Cepal Nexi Investment Skyline dit Bank Condensed Balance Sheet 31.12.2023 Holdings Payments Property Group Bank Romania S.A. Greece S.A. Elaionas S.A. S.A. S.A. ASSETS Cash and balances with central banks 25 Due from banks Derivative financial assets Loans and advances to customers Investment securities Other assets 365 106 467 Total Assets 365 106 492 - - - LIABILITIES Due to banks Derivative financial liabilities Due to customers Debt securities in issue and other borrowed funds Liabilities for current income tax Other liabilities 119 115 181 Total Liabilities 119 115 181 - - - EQUITY 246 (9) 311 - - - Total Liabilities and Equity 365 106 492 - - - Group participation (%) 20.00% 50.00% 9.99% - - - Equity shareholding 49 (5) 31 Valuation adjustments at initial recognition/impairments (9) (1) 2 Carrying amount of participation 40 (5) 33 Loan that is part of the net investment Net investment 40 (5) 33 - - -

26. Investment property

Land – Buildings Rights-of-use on Land and Buildings Total Balance 1.1.2023 Acquisition Cost 271 8 279 Accumulated depreciation and impairment losses (31) (3) (34) 1.1.2023 - 31.12.2023 Net book value 1.1.2023 240 5 245 Additions 7 7 Reclassification from/(to) "Property, Plant and Equipment" 6 6 Reclassification from/(to) “Other assets” 62 62 Reclassification from/(to) "Assets held for sale" 5 5 Disposals / Write-offs / Terminations/Reassessments (11) (1) (12) Disposal of subsidiaries (1) (1) Depreciation charge for the year (4) (1) (5) (Impairment) / Reversal of Impairment for the year (6) (6) Net book value 31.12.2023 298 3 301 Balance 31.12.2023 Acquisition Cost 334 7 341 Accumulated depreciation and impairment losses (36) (4) (40) 1.1.2024 - 31.12.2024 Net book value 1.1.2024 298 3 301 Additions 18 18 Additions from expenses capitalization 1 1 Reclassification from/(to) "Assets held for sale" 8 8 Disposals / Write-offs / Terminations/Reassessments (1) 1 - Disposal of subsidiaries (26) (26) Depreciation charge for the year (9) (1) (10) (Impairment) / Reversal of Impairment for the year (2) (2) Net book value 31.12.2024 287 3 290 Balance 31.12.2024 Acquisition Cost 329 7 336 Accumulated depreciation and impairment losses (42) (4) (46)The fair value of investments in land and buildings as at 31.12.2024 amounts to € 317 (31.12.2023: € 312) as estimated by independent

charted surveyors. In 2024 an impairment loss amounting to € 2 (31.12.2023: € 6), was recognised, in order for the carrying amount of

investment property not to exceed the recoverable amount, which is estimated as the fair value less cost to sell. The impairment amount was

recognized in “Impairment losses on fixed assets and participations” in the Income Statement.

The recoverable amount of investment property, which was impaired during the current year, amounted to € 8 (31.12.2023: € 59). The fair

value of the investment property is calculated in accordance with the methods mentioned in note 1.2.7 and are classified, in terms of fair value

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

304 | ANNUAL FINANCIAL REPORT

hierarchy, in Level 3 since assumptions and inputs relating to properties of relevant characteristics are used for the determination of fair value

and therefore encompass a wide range of unobservable market inputs. The capitalization rate used ranges between 6.3% and 8%.

The recoverable amount of right-of-use assets on buildings is equal to the discounted value of the rental receivables from subleases. The

Group, as a lessor of buildings owned by third parties, recognizes in the results of the period rental income.

27. Property plant and equipment

Land and Rights-of-use on Equipment Total Buildings fixed assets Balance 1.1.2023 Acquisition Cost 674 516 181 1,371 Accumulated depreciation and impairment losses (296) (442) (104) (842) 1.1.2023 - 31.12.2023 Net book value 1.1.2023 378 74 77 529 Additions 10 15 23 48 Disposals / Write-offs / Terminations / Reassessments / Destructions 40 40 Reclassification to "Property, Plant and Equipment" (3) (3) Reclassification to "Assets held for sale" (10) (14) (27) (51) Depreciation charge for the year (11) (19) (32) (62) Net Book value 31.12.2023 364 56 81 501 Balance 31.12.2023 Acquisition Cost 560 493 176 1,229 Accumulated depreciation and impairment losses (197) (437) (94) (728) 1.1.2024 - 31.12.2024 Net book value 1.1.2024 363 56 82 501 Additions 16 9 18 43 Disposals / Write-offs / Terminations / Reassessments/ Destructions (4) (1) 17 12 Reclassification from/(to) "Other Assets (1) (1) Reclassification from/(to) "Assets held for sale" 21 21 Depreciation charge for the year (10) (14) (18) (42) Net Book value 31.12.2024 385 50 99 534 Balance 31.12.2024 Acquisition Cost 591 495 207 1,293 Accumulated depreciation and impairment losses (206) (445) (108) (759) Item «Disposals / Write-offs / Terminations / Reassessments» of Rights-of-use on fixed assets includes rent adjustments and contract time.

28. Goodwill and other intangible assets

Software Other intangible Total Balance 1.1.2023 Acquisition Cost 990 126 1,116 Accumulated depreciation and impairment losses (516) (126) (642) 1.1.2023 - 31.12.2023 Net book value 1.1.2023 474 - 474 Additions 128 128 Reclassification from / (to) "Assets held for sale" (11) (11) Disposals / Write-offs (1) (1) Amortization charge for the year (106) (106) Impairment losses for the year (17) (17) Net book value 31.12.2023 467 - 467 Balance 31.12.2023 Acquisition Cost 1,074 126 1,200 Accumulated depreciation and impairment losses (607) (126) (733) 1.1.2024 - 31.12.2024 Net book value 1.1.2024 467 - 467 Additions 109 109 Disposals / Write-offs (2) (2) Amortization charge for the year (127) (127) Impairment losses for the year (9) (9) Net Book value 31.12.2024 438 - 438 Balance 31.12.2024 Acquisition Cost 1,104 126 1,230 Accumulated depreciation and impairment losses (666) (126) (792)

Software additions of current year relate mainly to purchase of licenses and software implementations of the Bank.

Future receipts from operating leases are as follows: 31.12.2024 31.12.2023 - Up to 1 year 9 10 -From 1 year to 5 years18 18 -Over 5 years5 6 Total 32 34

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

305 | ANNUAL FINANCIAL REPORT

Software additions of the year ending 31 December 2024 include an amount of € 12 (31.12.2023: € 14) which concern to internally produced

computer applications. The amortization charge for the year corresponding to these applications amount to € 19 (31.12.2023: € 6).

Following the test of impairment for the year ended 31 December 2024 an amount of € 9 was recognised, out of which € 7 relate to intangible

assets of the Bank with zero recoverable amount since no future benefits are expected from their use, while € 2 relates to Group software for

the support of the operations of Alpha Bank Romania and has been classified as “Discontinued Operations”.

Following the annual review of the useful life of Intangible assets, useful lives have been adjusted accordingly and an additional amortization

of € 5 was recognised within the year.

29. Deferred tax assets and liabilities

31.12.2023 31.12.2023 Assets 4,815 4,978 Liabilities (18) (25) Total 4,797 4,953 Deferred tax assets and liabilities are analyzed as follows:

1.1 - 31.12.2024 Recognised in Balance Balance Income 1.1.2024 31.12.2024 Equity Statement Debit difference of Law 4046/2012 802 (45) 757 Debit difference of Law 4465/2017 2,942 (170) 2,772 Write-offs, depreciation and impairment of fixed assets and leases 106 (23) 83 Loan portfolio 717 99 816 Valuation of loans due to hedging - - Employee defined benefit and insurance funds 5 1 6 Valuation of derivatives financial instruments / Valuation cash flow hedge reserve 47 (44) (9) (6) Valuation of liabilities to credit institutions and other borrowed funds due to fair value hedge (33) 43 10 Valuation / Impairment of investments 143 4 147 Valuation / Impairment of debt securities and other securities 150 (30) 2 122 Tax losses carried forward 10 (8) 2 Other temporary differences 81 13 94 Currency translation differences from financial statements and net investment hedging of foreign (17) 11 (6) operations Total 4,953 (160) 4 4,797 1.1 - 31.12.2023 Recognised in Balance Transfer to Balance Income 1.1.2023 Held for Sale 31.12.2023 Equity Statement Debit difference of Law 4046/2012 847 (45) 802 Debit difference of Law 4465/2017 2,935 7 2,942 Write-offs, depreciation and impairment of fixed assets and leases 77 29 106 Loan portfolio 901 (184) 717 Valuation of loans due to hedging 3 (3) - Employee defined benefit and insurance funds 5 (1) 1 5 Valuation of derivatives financial instruments / Valuation cash flow hedge reserve 54 3 (10) 47 Valuation of liabilities to credit institutions and other borrowed funds due to fair value hedge (62) 29 (33) Valuation / Impairment of investments 147 (4) 143 Valuation / Impairment of debt securities and other securities 230 (62) (18) 150 Tax losses carried forward 8 2 10 Other temporary differences 83 3 6 (11) 81 Currency translation differences from financial statements and net investment hedging of foreign (17) (17) operations Total 5,211 (226) (21) (11) 4,953 It is noted that the table for 2023 includes an amount of € 6 related to discontinued operations taxes.

As of 31.12.2024, the amount of deferred tax assets which are in the scope of Law 4465/2017 and include the amount of the debit difference

of Law 4046/2012 (PSI), amount to € 2.42 bil. (31.12.2023: € 2.58 bil.).

As at 31.12.2024, the Group has not recognized deferred tax asset related to tax losses amounting to € 612. The amount of € 490 concerns

deferred tax asset not recognized on tax losses of Alpha Services and Holdings S.A. that were created in previous years mainly from the sale of

the 51% of the mezzanine and junior notes of Galaxy securitisation.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

306 | ANNUAL FINANCIAL REPORT

Deferred tax assets that have not been recognized as at 31.12.2024 deriving from relevant tax losses are presented in the following table by year

of maturity. Expiration year for setting off tax losses 2025 2026 2027 2028 2029 Total Deferred tax assets 14 262 274 54 8 612

Moreover, the Group as at 31.12.2024 has not recognized deferred tax assets on temporary differences of amount € 2. The year for the

reversal of the above temporary differences cannot be reliably determined.

30. Other assets

31.12.2024 31.12.2023 Tax advances and withholding taxes 215 179 Deposit and Investment Guarantee Fund 37 236 Property obtained from auctions and other inventories 238 222 Prepaid expenses 25 19 Accrued income 44 33 Other 249 256 Total 808 945On 2 December 2024 the “Deposit and Investment Guarantee Fund” paid back to the Bank the 3nd and final installment of supplementary

deposit leg, amounting to € 201, following the amendment of L. 4370/2016 according to the provisions of L. 4972/2022. The previous

installments of € 198 and € 197 were paid on 1 December 2023 and 2 December 2022 respectively. The carrying amount of the shareholding

of the Bank in the Guarantee Fund Deposit Scheme as of 31.12.2024 amounted to € 0 (31.12.2023: € 200).

“Tax advances and withholding taxes” is presented in the table above net of provisions of € 21 as at 31.12.2024 (31.12.2023: € 52).

As at 31.12.2024 the Group valued “Property obtained from auctions and other inventories” which have been classified as Other Assets, at the

lower between their carrying amount and fair value less costs to sell. For cases where the net realizable value of the properties was less that

their carrying value, an impairment loss of has recognised an impairment loss of € 3 (31.12.2023: € 1) has been recognised. The impairment

amount was recognized in “Impairment losses on fixed assets and participations” in the Income Statement. The recoverable amount of land

and buildings that were impaired during the year amounted to € 4 (31.12.2023: €2).

Within 2024 the Group transferred assets with a carrying amount of € 12 from “Assets Held for Sale” to “Other Assets” and specifically to

“Property obtained from auctions and other inventories” as they did not meet the definition of assets held for sale and there was a change in

their use.

“Accrued income” includes a contact asset of an amount of € 10 (31.12.2023: € 7) 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 31.12.2024. The Group’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 2024 is the

recognition of commission income from insurance brokerage fees amounting to € 3 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.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

307 | ANNUAL FINANCIAL REPORT

LIABILITIES

31. Due to Banks

31.12.2024 31.12.2023 Deposits: - Current accounts312 228 Central Banks 2,602 5,134 Other credit institutions 150 9 Cash collateral for derivative margin account and repurchase agreements 348 472 Securities sold under agreement to resell (Repos) 2,770 662 Borrowing funds 350 416 Deposits on demand: - Other credit institutions1 Total 6,533 6,921 The decrease in line “Central Banks” is due to net repayments of € 2.5 bil. made within the reporting period of 2024 for the funding through

ECB. “Borrowing funds” relate to the liabilities of the Group to the European Investment Bank. “Securities sold under agreement to resell

(Repos)” increased compared to 31.12.2023, using government and corporate bonds as collateral aimed at diversifying funding sources in

parallel with the reduction of TLTRO III funding from ECB.

32. Due to customers

31.12.2024 31.12.2023 Deposits: - Current account22,403 21,377 - Saving accounts13,496 13,948 - Term deposits14,862 12,940 Changes in the fair value of deposits in portfolio hedge of interest rate risk 78 13 Deposits on demand 31 43 50,870 48,321 Cheques payable 162 128 Total 51,032 48,449 For interest rate risk management purposes the Bank has initiated, through derivative contracts, fair value hedge accounting for a portfolio of

savings accounts of nominal value of € 7.52 bil. As at 31.12.2024, "Due to Customers" increased from the valuation of deposits at fair value in

terms of the hedged risk by an amount of € 78.

33. Debt securities in issue and other borrowed funds

i. Covered bonds

The following table presents detailed information for the covered Bonds issues:

Nominal Value Issuer Currency Interest Rate Maturity 31.12.2024 31.12.2023 Alpha Bank S.A. € 3m Εuribor+0.50%, minimum 0% 23.1.2028 1,000 1,000 Alpha Bank S.A. € 3m Εuribor+0.50%, minimum 0% 23.1.2028 1,000 1,000 Alpha Bank S.A. € 3m Εuribor+0.50%, minimum 0% 23.1.2028 400 400 Total 2,400 2,400 On 23.10.2024 the Bank proceeded with the extension of the final maturity date of the above issuances from 23.1.2025 to 23.1.2028.

As of 31.12.2024 there are no covered bonds issued by the group and held by third parties.

ii. Senior debt

The Bank issued on 12.2.2024 under the Euro Medium Term Note Programme a preferred senior note of € 400 nominal value with maturity

date 12.5.2030 and call date 12.5.2029, bearing a fixed annual coupon equal to 5% up to the call date, which is reset thereafter to a new rate

effective up to maturity date calculated as the annual swap rate plus a margin of 2.432%.

A senior preferred note with a nominal value of € 400 and final maturity on 1.11.2025 was fully redeemed on the call date 1.11.2024. Balance 1.1.2024 1,964 Changes for the year 1.1 - 31.12.2024 New issues 396 Repurchases (1) Maturities / Repayments (520) Hedging adjustments 23 Financial (gains)/losses 1 Accrued interest 133 Balance 31.12.2024 1,996

Detailed information on common bond issues is presented in the table below. The following issues have been made by the Bank and are

denominated in Euro currency

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

308 | ANNUAL FINANCIAL REPORT

rdInterest Nominal Value of bonds Held by the Group Nominal Value of bonds Held by 3 parties Maturity Rate 31.12.2024 31.12.2023 31.12.2024 31.12.2023 2.50% 23.3.2028 2 2 498 498 7.00% 1.11.2025 400 7.50% 16.6.2027 2 2 448 448 6.75% 13.2.2029 5 5 65 65 6.875% 27.6.2029 5 5 495 495 6.5% 22.11.2029 1 1 49 49 5% 12.5.2030 1 399 16 15 1,954 1,955 iii. Liabilities from the securitization of loans and receivables

Liabilities arising from the securitization of consumer, loans and credit cards are not included in “Debt securities in issue and other borrowed

funds”, as the corresponding securities of a nominal amount equal to € 467 (31.12.2023: € 1,442), are held by the Group. During the period the

securitization transactions of corporate loans and lease receivables that had been respectively carried out via the special purpose entities Epihiro

Plc and Irida Plc were terminated.

Detailed information for the above liabilities are presented in the following table:

Nominal Value Issuer Currency Interest Rate Maturity 31.12.2024 31.12.2023 Epihiro Plc LDN - Class A Euro 6m Euribor +0.3%, minimum 0% 20.1.2035 400 Epihiro Plc LDN - Class B Euro 6m Euribor, minimum 0% 20.1.2035 100 Pisti 2010-1 Plc LDN - Class A Euro 2.50% 24.2.2026 294 294 Pisti 2010-1 Plc LDN - Class B Euro 1m Euribor, minimum 0% 24.2.2026 173 173 Irida Plc LDN - Class A Euro 3m Euribor +0.3%, minimum 0% 3.1.2039 261 Irida Plc LDN - Class B Euro 3m Euribor, minimum 0% 3.1.2039 214 Total 467 1,442 iv. Liabilities from the securitization of non-performing loans

The Bank has carried out a securitization transaction of an NPL portfolio managed by Cepal, the amount of which may vary on a continuous basis

depending on whether specific eligibility criteria are met. In particular, the loans were transferred to the special purpose company Gemini Core

Securitisation Designated Activity Company based in Ireland, which issued a bond that was purchased entirely by the Bank. The bond is €

denominated, has a nominal value of € 4,841 as at 31.12.2024 (31.12.2023: € 5,151), it bears an interest rate of 3m Euribor +0.4%, minimum 0%

and it matures at 27.6.2050. As the bond is held by the Bank, the liability from the said securitization is not included in the account “Debt

securities in issue and other borrowed funds”.

v. Subordinated debt (Lower Tier II, Upper Tier II)

Balance 1.1.2024 956 Changes for the year 1.1 - 31.12.2024 New issues 494 Repurchases (11) Maturities / Repayments (415) Hedging adjustments 32 Financial (gains)/losses 10 Interest expense 58 Balance 31.12.2024 1,124

On 3.6.2024 , Alpha Services and Holdings S.A. invited holders of its outstanding € 500 Dated Subordinated Fixed Rate Reset Tier 2 Notes to

tender their Notes for cash at a price of 99.75 per cent. As at 13.6.2024, a principal amount of € 369 of the Notes were validly tendered, while a

principal amount of € 131 remained o Balance Sheet. As a result, € 11 losses were recognised in “Gains less losses on financial transactions”

(note 7). Under the Euro Medium Term Note Programme of € 15 bil., Alpha Services and Holdings issued on 13.6.2024 a new subordinated bond

with a nominal amount of € 500 maturing on 13.9.2034, callable at 5.25 years and with a fixed annual coupon of 6.00%, which is adjusted to a

new coupon interest rate applicable from the call date until maturity, determined on the then prevailing swap rate plus a margin of 3.27%.

Detailed information for the above issuances is presented in the following table. All of the below have been issued by Alpha Services and

Holdings S.A. and are denominated in Euro currency. rdInterest Nominal value Held by the Group Nominal value Held by 3 parties Maturity Rate 31.12.2024 31.12.2023 31.12.2024 31.12.2023 4.25% 13.2.2030 14 131 486 5.50% 11.6.2031 10 10 490 490 6.00% 13.9.2034 11 489 21 24 1,110 976 vi. Credit Linked Debt

Under the Alpha Bank-Credit Linked Note Issuance Programme and the Eleven synthetic securitization transaction the Bank issued on

23.12.2024 a new credit linked bond with a nominal amount of € 87.6 and maturity date 30.6.2039, callable on 23.1.2029 and with a floating

coupon of Euribor 3M plus a tranche fee rate of 9%.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

309 | ANNUAL FINANCIAL REPORT

Balance 1.1.2024 - Changes for the period 1.1 - 31.12.2024 New issues 88 Balance 31.12.2024 88

Detailed information on subordinated debt issuances is presented in the following table:

Nominal Value Issuer Currency Interest Rate Maturity 31.12.2024 31.12.2023 Alpha Bank S.A. € 3m Εuribor 30.6.2039 88 - Total 88 - Total of debt securities in issue and other borrowed funds as at 31.12.2024 3,208 The following table presents the changes of debt securities and other borrowed funds by separately disclosing the cash and non-cash items:

Cash Flows Non Cash Flows Desecuritizations Cash flows from financing activities 1.1.2024 New issues Foreign exchange Change of Fair Accrued interest Other 31.12.2024 Maturities differences Value Repayments Senior debt securities (ii) 1,964 (125) 133 23 1 1,996 Subordinated debt (v) 956 68 58 32 10 1,124 Credit linked debt (vi) - 88 88 Cash Flows Non Cash Flows Cash flows from financing activities 1.1.2023 Desecuritizations New issues Accrued interest Change of Fair Value Other 31.12.2023 Maturities Repayments Senior debt securities (ii) 1,295 523 99 48 1,965 Subordinated debt (v) 918 (48) 48 37 955 Credit linked debt (vi) 710 (520) 11 (201) -

34. Liabilities for current income tax

Current Income Tax Liabilities as at 31.12.2024 amount to € 69, increased compared to 31.12.2023 (€ 4), since for the comparative period no

tax liability had arisen due to the off-set of 2023 taxable profits against carried forward tax losses in accordance with L.4172/2013 art. 27

par.3a.

35. Employee defined benefit obligations

The total amounts recognized, in the financial statements for defined benefit obligations are presented in the tables below:

Balance Sheet - Liabilities 31.12.2024 31.12.2023 Employee's indemnity provision due to retirement in accordance with Law 2112/1920 17 17 Plans for Diners (pension and health care) 7 7 Total Liabilities 24 24 Income Statement Expense / (Income) From 1 January to 31.12.2024 31.12.2023 Employee's indemnity provision due to retirement in accordance with Law 2112/1920 3 3 Other provision for retirement benefits (1) Total Liabilities 3 2 Balance Sheet and Income Statement amounts are analyzed per fund and type of benefit as follows:

a. Employee indemnity due to retirement in accordance with Law 2112/1920

The contracts of the regular employees of Alpha Services and Holdings S.A. and Alpha Bank S.A. 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 income statement are as follows: From 1 January to 31.12.2024 31.12.2023 Current service cost 2 2 Net interest cost resulted from net asset/liability 1 Settlement / Curtailment / Termination (gain)/loss 1 Total (included in staff costs) 3 3

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

310 | ANNUAL FINANCIAL REPORT

The movement in the present value of defined benefit obligation is as follows:

2024 2023 Opening Balance 17 17 Current service cost 2 2 Interest cost 1 Benefits paid (3) (3) (Gain)/Loss from Settlement / Curtailment / Termination 1 Reclassification to voluntary separation scheme provision (1) Actuarial (gain)/loss-financial assumptions 1 Closing Balance 17 17

The amounts recognized directly in equity during the year are analyzed as follows:

31.12.2024 31.12.2023 Change in liability gain/(loss) due to changes in financial and demographic assumptions (1) Total actuarial gain/(loss) recognized directly in Equity - (1)

The movement in the present value of defined benefit obligation is as follows:

2024 2023 Opening Balance 17 17 Benefits paid (3) (3) Loss/(Gain) recognized in Income Statement 3 3 Loss/(Gain) recognized in equity 1 Reclassification to voluntary separation scheme provision (1) Closing Balance 17 17

b. Supplementary Pension Fund and Healthcare of Diners

The Bank guarantees from 30.9.2014, date of acquisition of Diners Club Greece S.A., the Supplementary Pension Fund and Health Care Plan of

the Company, which is managed by an independent insurance company.

On 2.6.2015, the merger through absorption of the company was completed. These plans cover the pensioners and those who have retired and

have the right to receive supplementary pension in the future.

The contribution to Diners' supplementary pension scheme is not expected to be significant in 2025.

The amounts included in the balance sheet are analyzed as follows:

31.12.2024 31.12.2023 Present value of defined obligation 8 8 Fair value of plan assets (1) (1) Liability 7 7

The movement in the present value of defined benefit obligation is as follows:

2024 2023 Opening Balance 8 7 Actuarial (gain)/loss-demographic assumptions 1 Closing Balance 8 8 The movement in the fair value of assets for the plan is analyzed as follows:

2024 2023 Opening Balance 1 1 Benefits paid Closing Balance 1 1

The amounts recognized directly in Equity during the year are analyzed as follows: 31.12.2024 31.12.2023 Change in liability due to financial and demographic assumptions - gains/(loss) (1) Total actuarial gain/(loss) recognized in equity - (1)

The movement in the obligation/(asset) is as follows: 2024 2023 Opening Balance 7 6 (Gain)/loss recognized in Equity 1 Closing Balance 7 7

The results of the abovementioned valuations are based on the assumptions of the actuarial studies.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

311 | ANNUAL FINANCIAL REPORT

The principal actuarial assumptions used for the abovementioned defined benefit plans are as follows: 31.12.2024 31.12.2023 Discount rate 3.14% - 3.44% 3.16% - 3.31% Inflation rate 2.00% 2.15% Return on plan assets Future salary growth 2.25% 2.40% Future pension growth 0.00% 0.00%

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: 31.12.2024 31.12.2023 Bank employee's indemnity provision due to retirement in accordance with Law 2112/1920 6.9 7.2 Plans for Diners (pension and health care) 13.9 14.3

The table below presents the sensitivity analysis of the financial assumptions with regards to the obligation of the above programs: % change Percentage variation in liability (%) Increase in discount rate by 0.5% (4.1) Decrease in discount rate by 0.5% 4.5 Increase in future salary growth rate by 0.5% 1.9 Decrease in future salary growth rate by 0.5% (1.8)

36. Other Liabilities

31.12.2024 31.12.2023 Liabilities to third parties 27 71 Brokerage services 31 28 Deferred income 23 18 Accrued expenses 140 115 Liabilities to merchants for the use of credit cards 207 185 Leases liabilities 124 110 Other taxes 28 23 Other 315 369 Total 895 919There are no property leases which include a variable lease term while variable leases have been included in the expenses relating to other

types of leases. However, variable lease terms, which concern other lease categories, were recorded in expenses.

The following table includes the movement in lease liabilities, with distinctive presentation of cash flows, a presented in the Cash flows

Statement from financing activities and the non cash flow movements.

Non-cash flows Transfer to Held for 1.1.2024 Cash flows 31.12.2024 New leases Other changes Sale Lease liabilities 110 (18) 16 9 7 124 Non-cash flows Transfer to Held for 1.1.2023 Cash flows 31.12.2023 New leases Other changes Sale Lease liabilities 111 (27) 14 40 (28) 110

37. Provisions

Separation Scheme

provisions

Provisions to cover credit risk Provisions for Voluntary Other (from undrawn loan commitments Letters of Total pending legal cases Guarantee and Letters of Credit) Balance 1.1.2023 32 41 31 64 168 Changes for the year 1.1 - 31.12.2023 Provisions / (Reversals) 6 (1) 40 45 Provisions used (9) (54) (11) (74) Transfers / Reclassifications 1 (10) (9) Transfer from/to liabilities related to assets (10) (1) (11) classified as Held for Sale Balance 31.12.2023 29 30 18 42 119 Changes for the year 1.1 - 31.12.2024 Provisions / (Reversals) (5) 55 60 110 Provisions used (9) (1) (32) (26) (68) Balance 31.12.2024 20 24 41 76 161

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

312 | ANNUAL FINANCIAL REPORT

Voluntary Separation Scheme

With in, 2024, the Executive Committee approved a new VSS program with an estimated cost of € 58 mil. for the Bank and € 4 mil. for the

subsidiaries. As a result of the new scheme, provisions that were related to the previous 2023 targeted separation program totaling € 7 were

released, which are presented in line ‘’Provisions / (Reversals)’’ of the above table, resulting in a net cost of € 55 mil. for the period.

In 2023, line “Provisions/(Reversals) of Voluntary Separation Scheme regards the net cost as a result of the 2023 VSS and targeted separation

scheme of cost € 64 and the reversal of € 25 of 2021 VSS.

Other provisions

In December 2024, the Hellenic Government declared that four systemic banks will grant an amount of € 100 for the renovation and

construction of school buildings within the framework of the "Marietta Giannakou" program. Given that the announcement creates a

constructive obligation for the Bank to participate, a provision of an amount of € 25 mil. was recognized as at 31.12.2024 in line ‘’Provisions /

(Reversals)’’. Executive Committee formally approved the commitment in January 2025. In the context of the completion of Alpha Bank

Romania, the Group recognized a provision of € 29 mil. with regards to the transaction’s outcome of contractual commitments which is shown

in the line ‘’Provisions / (Reversals)’’ During the year 2024, the Group’s subsidiary Alpha Bank Cyprus recognized a provision related to

Employee’s Provident Funds for retirement.

Line ‘’Provisions used’’ of ‘’Other provisions’’ for the period ended 31.12.2024 mainly related to provisions used within the reporting period of:

a. € 9.7 for administrative dispute with the Competition Commission

b. € 4.4 for the outcome of contractual commitment in the context of sale transactions

c. € 3.5 related to the provision for the tax levy on credit institutions of Alpha Bank Cyprus

d. The remaining amount of € 8.5 related to the settlement of other provisions.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

313 | ANNUAL FINANCIAL REPORT

EQUITY

38. Share Capital

Changes for the period from 1.1. to 31.12.2024 Shares from Share Opening Balance as at Share Capital paid as at Capital Increase through Balance as at 31.12.2024 1.1.2024 31.12.2024 the stock option exercise Number of ordinary registered shares 2,351,697,671 1,279,623 2,352,977,294 682

The Company’s share capital as of 31.12.2024 amounts to € 682 (31.12.2023: € 682) divided into 2,352,977,294 (31.12.2023: 2,351,697,671)

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 exercised:

• In January 2024, 1,142,026 option rights vested and exercised from the beneficiaries, in accordance with Performance Incentive

Program for the years of 2019 and 2020. From the above rights, 660,418 were exercised at an issue price of € 0.29 and the

remaining 481,608 rights were exercised at an issue price of € 0.30.

As a result of the above, 1,142,026 ordinary, registered, voting shares were issued, with a nominal value of € 0.29 each.

• In September 2024 137,597 option rights vested and exercised from the beneficiaries, in accordance with Performance Incentive

Program for the years of 2021.

As a result of the above, 137,597 ordinary, registered, voting shares with nominal value of € 0.29 were issued.

Treasury shares

The Company decided at its shareholders Ordinary General Meeting dated 27.7.2023, the establishment of a Share Buyback Program for the

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 January and September 2024, an amount of 1,890,504 and an amount of 1,799,829 treasury, ordinary, registered, voting shares of the

Company, with a value of € 3 and a value of € 3 respectively were made available free of charge to the Beneficiaries.

The Annual General Meeting of the Shareholders dated 24.7.2024 decided the amendment of the Share Buyback Program for acquisition of

own existing common, registered dematerialized shares, with voting rights, pursuant to provisions of article 49 of law 4548/2018, in order to

complete the Share Buyback program of € 61 as described on note 42. Towards this, an amount of 32,900,866 treasury shares have been

purchased by the Company, as of 31.12.2024 with a total cost of € 52.

Subsidiary company Alpha Finance performs transactions with the shares of the company Alpha Services and Holdings S.A. in the context of

market making. As at 31.12.2024 the carrying amount of the treasury shares was € 61. Below are described the transactions of treasury shares

of the Group. Number of shares Carrying amount Balance 1.1.2023 1,343,335 1 Purchases 21,833,960 31 Sales (15,935,826) (22) Gain/(Losses) from sales 1 Balance 31.12.2023 7,241,469 11 Purchases 74,533,313 117 Sales (38,906,960) (62) Share award rights to employees (3,690,333) (6) Gain/(Losses) from sales 1 Balance 31.12.2024 39,177,489 61

39. Share premium

Balance as at 1.1.2024 4,783 Increase in share premium through the stock options rights exercise 1 Balance as at 31.12.2024 4,784 Share premium as at 31.12.2024 amounted to € 4,784 (31.12.2023: € 4,783). The increase in share premium due to exercise of stock options is

mainly due to the fair value measurement of the stock options on the awarding date that were exercised during the year.

40. Other Equity Instruments

Balance 1.1.2024 400 Issuance of AT1 Notes 300 Balance 31.12.2024 700 On 1 February 2023, the Company issued additional Tier 1 instruments ("AT1 Notes") amounting to € 400 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%. Additionally, on 3

September 2024, the Company issued additional Tier 1 instruments (AT1 Notes) amounting to € 300. The bonds are perpetual, with an

adjustment clause, a maturity of 6 years and a yield of 7.5%.

“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

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314 | ANNUAL FINANCIAL REPORT

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.

In February and August 2024, the Company made two interest payments for the AT1 Notes issued in February 2023, amounting to € 24 each.

41. Reserves

Reserves are analyzed as follows:

a. Statutory reserve

2024 2023 Opening Balance 1.1 103 79 Changes for the year 1.1 - 31.12 Appropriation of reserves 36 24 Sale of subsidiary (42) Balance 31.12 97 103 According to article 158 of Law 4548/2018, (for which a corresponding paragraph exists in article 26 of the Banks’ Articles of association) at

least one-twentieth (1/20) is deducted annually from the annual net profit for the formation of the statutory reserve. This requirement ceases

to be mandatory once the reserve reaches the one-third (1/3) of the share capital. Based on the provisions of the aforementioned article this

reserve can be utilized exclusively before any dividend distribution in order to offset prior year accumulates losses.

For the remaining companies of the Group the statutory reserve is formed according to the local regulations.

b. Reserve of investment securities measured at fair value through other comprehensive income

2024 2023 Opening Balance 1.1 (3) (71) Changes for the year 1.1 - 31.12 Valuation of debt securities measured at fair value through other comprehensive income, after income tax 4 46 Reclassification of reserves related to assets held for sale 22 Reclassification to income statement of reserve of debt securities measured at fair value through other comprehensive (4) income, after income tax Balance 31.12 (3) (3) The movements for the year of the reserve for investment securities measured at fair value through other comprehensive income, that relate

to the valuation of the investment securities and the transfer of the related reserve to Income Statement, amounts (before income tax) to a

credit amount of € 6 and a debit amount of € 6 (1.1-31.12.2023: credit amount of € 61 and debit amount of € -, respectively).

c. Cash flow hedge reserve recognised directly in Equity

2024 2023 Opening Balance 1.1 (194) (219) Changes for the year 1.1 - 31.12 New hedging after income tax 7 10 Amortization of hedging relationships expired after income tax 15 15 Balance 31.12 (172) (194)

d. Exchange differences on translating and hedging the net investment in foreign operations

2024 2023 Opening Balance 1.1 (21) (65) Changes for the year 1.1 - 31.12 Change of Foreign Exchange differences on translating and hedging the net investment in foreign operations 3 Reclassification of reserves measured at fair value through other comprehensive income related to assets held for sale 44 Balance 31.12 (18) (21)

e. Valuation Reserve for stock options rights to employees

2024 2023 Opening Balance 1.1 1 3 Changes for the year 1.1 - 31.12 Exercise of rights (1) (3) Reserve valuation for stock options right to employees 1 1 Balance 31.12 1 1 Details for the stock options exercised during 2024 are included in note 9.

f. Valuation reserve for share award rights to employees

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315 | ANNUAL FINANCIAL REPORT

2024 2023 Opening Balance 1.1 (64) - Changes for the year 1.1 - 31.12 Change of Foreign Exchange differences on translating and hedging the net investment in foreign operations 45 (45) Reserve of portfolio held for sale 8 (22) Valuation of shares classified as held for sale (3) 3 Balance 31.12 (14) (64) It is noted that the amount of € 45 refers to the recycling of Other Comprehensive Income reserves to the statement of profit and loss due to the

sale of Alpha Bank Romania.

42. Retained Earnings

Taking into account that there are distributable profits for the fiscal year 2023 according to article 159 L.4548/2018, the Annual General Meeting

of the Shareholders dated 24.7.2024 decided the distribution of dividend. In particular, the Annual General Meeting of the Shareholders approved:

1. the distribution of € 61 in the form of a dividend payment in cash, of € 0.026 per share and

2. The amendment of the Share Buyback Program for acquisition by the Company of own existing common, registered dematerialized

shares, with voting rights, pursuant to provisions of article 49 of law 4548/2018, in order to complete the Share Buyback program of €

61.

On 5.6.2024 the European Central Bank (ECB) granted its permission in relation to the dividend cash distribution and the cancelation of the own

shares to be acquired. The overall distribution amount is equal to 20% of the group consolidated 2023 net profit after tax in accordance with the

Dividend Policy.

2024 2023 Opening Balance 1.1 3 - Changes for the year 1.1 - 31.12 Exercise of rights (6) Reserve valuation for stock award right to employees 5 3 Balance 31.12 2 3 Total reserves (a+b+c+d+e+f) (93) (111) g. Reserves related to Assets held for sale

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316 | ANNUAL FINANCIAL REPORT

ADDITIONAL INFORMATION

43. Contingent liabilities and commitments

a. Legal issues

There are certain legal claims against the Group, deriving from the ordinary course of business. In the context of managing the operational risk

events and based on the applied accounting policies, the Group has established internal controls and processes to monitor all legal claims and

similar actions by third parties to assess the probability of a negative outcome and the potential loss. For cases where there is a significant

probability of a negative outcome, and the result may be reliably estimated, the Group recognizes a provision that is included in the Balance

Sheet under “Provisions”. As of 31.12.2024 the amount of the provision stood at € 20 (31.12.2023: € 29).

For those cases, that according to their progress and the assessment of the legal department as at 31.12.2024, a negative outcome is not

probable or the possible loss cannot be estimated reliably due to the complexity of the cases and their duration, the Group has not established

a provision. As of 31.12.2024 the legal claims against the Group for the above cases amount to € 423 (31.12.2023: € 425) and € 34 (31.12.2023:

€ 62), respectively.

According to the legal department’s estimation, the ultimate settlement of the claims and lawsuits is not expected to have a material effect on

the financial position or the operations of the Group.

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 2018 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 2023 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 2024 is

in progress.

Alpha Bank S.A. emerged from the hive-down of the banking sector and started its operation on 16.4.2021 and the first fiscal year is from

1.7.2020 to 31.12.2021. Alpha Bank S.A. has received a tax compliance report for its first tax year from 1.7.2020 to 31.12.2021 and for tax

years 2022 and 2023, according to the article 65A of Law 4174/2013, with no qualification. Tax audit in connection with the tax compliance

report of 2024 is in progress.

The Bank’s branch in Luxembourg started its operation on June 2020 and has not been tax audited since its operation.

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.

Information regarding the unaudited tax years of the Group subsidiaries is provided in Note 44.

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 these annual financial statements, most of the jurisdictions where the Group operates have already incorporated these changes

into their domestic legislation with the exception of Serbia which has not enacted legislation to incorporate these rules of Pillar II into its

national law yet. As far as Greece is concerned, Law 5100/2024 published in the Official Gazette on 5 April 2024, incorporated the EU Council

Directive into Greek legislation and it closely follows the provisions of the EU Pillar Two Directive. The law includes detailed provisions on safe

harbors, including a Transitional Country-by-Country (CbC) reporting Safe Harbor, a Transitional Undertaxed Profits Rule Safe Harbor, as well as

a permanent Qualifying Domestic Minimum Top-Up Tax Safe Harbor. The Group has already taken every necessary action to re-assess the

potential impact of those rules on the Group. In particular, the assessment under the safe harbor rules for the 2024 fiscal year has been

completed, and the results showed that the Group meets the relevant criteria in all jurisdictions where it operates, therefore no liability arises

for payment of top-up tax. 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 Group, as part of its normal course of business, enters into contractual commitments, with its customers. Due to its nature, these

commitments are monitored in off balance sheet accounts and relate to letters of credit, letters of guarantee and liabilities from undrawn loan

commitments as well as guarantees given for bonds issued and other guarantees to subsidiary companies.

Letters of credit are used to facilitate trading activities and relate to the financing of contractual agreements for the transfer of goods locally or

abroad, through direct payment to the third party on behalf of the Group’s customers. Letters of credit, as well as letters of guarantee, are

commitments under specific terms and are issued by the Group for the purpose of ensuring that its customers will fulfill the terms of their

contractual obligations.

In addition, contingent liabilities for the Group arise from undrawn loan commitments that can be utilized only if certain requirements are

fulfilled by counterparties.

The outstanding balances are as follows: 31.12.2024 31.12.2023* Letters of credit 128 48 Letters of guarantee and other guarantees 5,608 5,107 Undrawn loan commitments 4,554 5,278

*The above balances also include Alpha Bank Romania SA figures

The Group measures the expected credit losses for all the undrawn loan commitments and letters of credit/letters of guarantee €

24(31.12.2023: € 40), which are presented in “Provisions”.

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317 | ANNUAL FINANCIAL REPORT

d. Pledged asset

Pledged assets are analyzed as follows: 31.12.2024 31.12.2023 Comment Reserve deposits relating to a) deposits that the Bank of Greece requires from all financial institutions established in Greece to maintain in BoG, corresponding to 1% of their total Cash and balances with Central 505 496 customer deposit as also to b) deposits of foreign banking subsidiaries which are Banksmaintained in accordance with the requirements set by the respective Central Banks in their countries. 203 198 Guarantees provided, mainly, on behalf of the Greek Government. Placements provided as guarantee for derivative and other repurchase agreements (repos). 548 648 It should be noted that investments for the guarantee of derivatives transactions are presented after the offset as described in note. 2 Placements provided for Letter of Credit or Guarantee Letters that the Bank issues for Due from financial institutions232 34 facilitating customer imports. Placements provided to the Resolution Fund as irrevocable payment commitment as part of 30 30 the 2016 up to 2023 contribution. This commitment must be fully covered by collateral exclusively in cash, as decided by the Single Resolution Board. 57 52 Placements used as collateral for the issuance of bonds held by the Group. 4,723 5,245 Loans pledged to central banks for liquidity purposes. 515 980 Corporate loans, finance lease receivables and credit cards securitized for the issuance of Special Purpose Entities’ corporate bond held by the Bank. Mortgage loans used as collateral for Covered Bond Issuance Program II. The nominal value Loans and advances to customersof the aforementioned bonds amounted to € 2,400 (31.12.2023: € 2,400) out of which the 2,619 2,596 Bank owns € 190 (31.12.2023: € 2,159) and has been pledged to Central Banks for liquidity purposes and € 2,210 (31.12.2023: € 240) has been pledged as collateral in repo transactions. Galaxy senior bonds classified as loans at amortised cost pledged as collateral in repo 352 302 transactions Greek Government Bonds pledged as collateral to the European Central Bank for liquidity 87 purposes. Bonds issued by other governments pledged as collateral to the Central Banks for liquidity 474 747 purposes. 38 124 Greek Government Bonds pledged as a collateral in repo transactions Investments securities Greek Treasury Bills pledged as collateral in the context of derivative transactions with the 253 395 Greek State. 117 Other Government Bonds have been pledged as collateral in repo transactions. Greek Government Bonds have been pledged as collateral in the context of derivative 3 transactions with customers. Other corporate bonds have been pledged as collateral ic Credit Linked Note Issuance 121 Programme 577 213 Corporate bonds pledged as collateral in repo transactions. Total 11,367 12,147

Additionally,

i. The Group has also received Greek Governments Bonds of nominal value of € 4 (31.12.2023: € 8) and fair value of € 4

(31.12.2023: € 8) as collateral in the context of derivative transactions with customers.

ii. The Group has received bonds with a nominal value of € 994 (31.12.2023 € 269) and a fair value of € 981 (31.12.2023: € 265) as

collateral in the context of reverse repo transactions, which are not included in its assets. Out of these bonds, a covered bond

issued by the Bank with nominal amount € 0 (31.12.2023: € 81) and fair value € 0 (31.12.2023 :€ 81) has been pledged to the

European Central Bank for liquidity purposes.

e. Other information

In December 2024, following announcements by the Prime Minister and the Ministry of National Economy and Finance, systemic banks have

committed to invest € 100 for the establishment of the Fund for the Acquisition and Leasing of Real Estate. This Fund is specifically designed to

address the needs of vulnerable debtors who are facing bankruptcy or enforcement actions. Under the terms of the Fund, the debtor's primary

residence will be acquired following a formal transfer request. Subsequently, the property will be leased back to the debtor. The leaseback

period will extend to a maximum of 12 years, during which time the debtor will have the opportunity to exercise the right to repurchase the

property either during the lease or at its expiration.

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44. Group Consolidated Companies

The consolidated financial statements, apart from the parent company Alpha Financial Services and Holdings S.A., include the following entities:

a. Subsidiaries Group’s ownership Name Country interest % Audited year by tax authorities up and including: 31.12.2024 31.12.2023 Banks *1 Alpha Bank S.A.Greece 100.00 100.00 The company has not been audited by the tax authorities since commencement of its operation 2 Alpha Bank London Ltd Un. Kingdom 100.00 100.00 2022 - voluntary settlement of tax obligation 3 Alpha Bank Cyprus Ltd Cyprus 100.00 100.00 2017 - tax audit in progress for the years 2018-2021 4 Alpha Bank Romania S.A. Romania - 99.92 The company was sold within the year Financing companies 1 Alpha Leasing S.A.* Greece 100.00 100.00 2010 - The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 2 Alpha Leasing Romania IFN S.A. Romania 100.00 100.00 2014 3 ABC Factors S.A.* Greece 100.00 100.00 The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 4 Alpha Erevna Agoras S.M.S.A. Greece 100.00 Tax unaudited since commencement of its operation in 2024 Investment Banking 1 Alpha Finance A.E.P.E.Y. * Greece 100.00 100.00 2018 The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to 2 Alpha Ventures S.A.* Greece 100.00 100.00 voluntary settlement for the tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to 3 Alpha S.A. Ventures Capital Management - AKES* Greece 100.00 100.00 voluntary settlement for the tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 4 Emporiki Ventures Capital Developed Markets Ltd Cyprus 100.00 100.00 2017 - Tax audit is in progress for the year 2018 5 Emporiki Ventures Capital Emerging Markets Ltd Cyprus 100.00 100.00 2017 - Tax audit is in progress for the year 2018 Asset Management The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to 1 Alpha Asset Management A.E.D.A.Κ.* Greece 100.00 100.00 voluntary settlement for the tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 2 ABL Independent Financial Advisers Ltd Un. Kingdom 100.00 100.00 2022 - voluntary settlement of tax obligation Insurance 1 Alpha Insurance Brokers S.R.L. Romania 100.00 100.00 Tax unaudited since commencement of its operation in 2006 The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to 2 Alphalife A.A.E.Z.* Greece 100.00 100.00 voluntary settlement for the tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 Real Estate and Hotel 1 Alpha Real Estate Services S.A.* Greece 93.17 93.17 2009 - The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 2 Alpha Real Estate Management and Investments S.A.* Greece 100.00 100.00 2009 - The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 3 Alpha Real Estate Bulgaria E.O.O.D. Bulgaria 93.17 93.17 Tax unaudited since commencement of its operation in 2007 4 Chardash Trading E.O.O.D. Bulgaria 100.00 Company was sold within the year 5 Alpha Real Estate Services S.R.L. Romania 93.17 93.17 Tax unaudited since commencement of its operation in 1998

* These companies received tax certificate for the years up to and including 2023 without any qualification.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

319 | ANNUAL FINANCIAL REPORT

Group’s ownership Name Country interest % Audited year by tax authorities up and including: 31.12.2024 31.12.2023 Tax unaudited since commencement of its operation in 2012. The years up to and including 2018 are considered as audited in 6 Alpha Investment Property Attikis S.A* Greece 100.00 100.00 accordance with the circular POL. 1208/2017 7 Stockfort Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2010 - Tax audit is in progress for the year 2018 8 Romfelt Real Estate S.A. Romania 99.99 99.99 Tax unaudited since commencement of its acquisition in 2015 9 AGI-RRE Poseidon S.R.L. Romania 100.00 100.00 Tax unaudited since commencement of its operation in 2012 10 Alpha Real Estate Services LLC Cyprus 93.17 93.17 2017 - Commencement of operation 2010 - Tax audit is in progress for the year 2018 11 AGI-BRE Participations 2BG E.O.O.D. Bulgaria 100.00 Company was sold within the year The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to *12 APE Fixed Assets S.A. Greece 72.20 72.20 voluntary settlement for the tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 13 Asmita Gardens S.R.L. Romania 100.00 100.00 Tax unaudited since commencement of its acquisition in 2015 14 Cubic Center Development S.A. Romania 100.00 100.00 2020 - Commencement of operation 2010 15 AGI-SRE Participations 1 D.O.O. Serbia 100.00 100.00 Tax unaudited since commencement of its operation in 2016 Tax unaudited since commencement of its operation in 2017, the years up to and including 2018 are considered as audited in 16 AIP Athens Commercial Assets I M.S.A. * Greece 100.00 100.00 accordance with the circular POL. 1208/2017 17 AGI-Cypre Property 2 Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2018 18 AGI-Cypre Property 5 Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2018 19 AGI-Cypre Property 7 Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2018 20 AGI-Cypre Property 8 Ltd Cyprus 100.00 100.00 Commencement of operation 2018 - Tax audit is in progress for the year 2018 21 AGI-Cypre Property 15 Ltd Cyprus 100.00 100.00 Commencement of operation 2018 - Tax audit is in progress for the year 2018 22 AGI-Cypre Property 17 Ltd Cyprus 100.00 100.00 Commencement of operation 2018 - Tax audit is in progress for the year 2018 23 ABC RE P2 Ltd Cyprus 100.00 100.00 Commencement of operation 2018 - Tax audit is in progress for the year 2018 24 ABC RE P3 Ltd Cyprus 100.00 100.00 Commencement of operation 2018 - Tax audit is in progress for the year 2018 25 ABC RE L2 Ltd Cyprus 100.00 100.00 Commencement of operation 2018 - Tax audit is in progress for the year 2018 26 AGI-Cypre Property 21 Ltd Cyprus 100.00 100.00 Commencement of operation 2018 - Tax audit is in progress for the year 2018 27 AGI-Cypre Property 24 Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2018 28 ABC RE L3 Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2018 29 ABC RE P&F Limassol Ltd Cyprus 100.00 100.00 Commencement of operation 2018 - Tax audit is in progress for the year 2018 30 AGI-Cypre Property 25 Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 31 ABC RE RES Larnaca Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2019 32 AGI Cypre Property 27 Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2019 33 ABC RE L5 Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 34 AGI-Cypre Property 30 Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 **35 AIP Industrial Assets Athens S.M.S.A.Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 36 AGI-Cypre Property 33 Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 37 AGI-Cypre Property 34 Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 38 Alpha Group Real Estate Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 39 ABC RE P&F Pafos Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2019 40 ABC RE P&F Nicosia Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 41 ABC RE RES Nicosia Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2019 42 AIP Industrial Assets Rog S.M.S.A.** Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 43 AIP Attica Residential Assets I S.M.S.A.** Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019

* These companies received tax certificate for the years up to and including 2023 without any qualification.

** These companies received tax certificate for the years up to and including 2022 without any qualification.

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320 | ANNUAL FINANCIAL REPORT

Group’s ownership Name Country interest % Audited year by tax authorities up and including: 31.12.2024 31.12.2023 44 AIP Thessaloniki Residential Assets S.M.S.A.** Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 *45 AIP Cretan Residential Assets S.M.S.A. Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 46 AIP Aegean Residential Assets S.M.S.A*** Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 47 AIP Ionian Residential Assets S.M.S.A.*** Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 **48 AIP Attica Residential Assets III S.M.S.A.Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 49 AIP Attica Residential Assets II S.M.S.A.** Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 ***50 AIP Land II S.M.S.A Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2019 51 AGI-Cypre Property 37 Ltd Cyprus 100.00 100.00 2022 - Commencement of operation 2019 52 AGI-Cypre Property 38 Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 53 Krigeo Holdings Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2019 54 AGI-Cypre Property 40 Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2020 55 ABC RE RES Ammochostos Ltd Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2020 56 Sapava Limited Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2020 57 AGI-Cypre Property 47 Limited Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2020 58 AGI-Cypre Property 48 Limited Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2020 59 Alpha Credit Property 1 Limited Cyprus 100.00 100.00 2022 - Commencement of operation 2020 60 Office Park I SRL Romania 100.00 Company was liquidated within the year 61 Acarta Construct SRL Romania 100.00 100.00 2013 62 AGI-Cypre Property 52 Limited Cyprus 100.00 100.00 2022 - Commencement of operation 2021 63 S.C. Carmel Residential Srl Romania 100.00 100.00 Tax unaudited since commencement of its operation in 2013 64 AGI-Cypre Property 56 Limited Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2022 65 AIP Commercial Assets ΙΙ S.M.S.A Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2022 66 AIP Attica Retail Assets IV S.M.S.A. Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2022 67 AIP Commercial Assets III S.M.S.A. Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2023 68 ABINVEST II S.M.S.A. Greece 100.00 Tax unaudited since commencement of its operation in 2024 Special purpose and holding entities 1 Alpha Group Investments Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2006 - Tax audit is in progress for the year 2018 2 Ionian Equity Participations Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2006 - Tax audit is in progress for the year 2018 3 AGI-BRE Participations 1 Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2009 - Tax audit is in progress for the year 2018 4 AGI-RRE Participations 1 Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2009 - Tax audit is in progress for the year 2018 5 Nigrinus Limited Cyprus 100.00 100.00 Tax unaudited since commencement of its operation in 2022 6 Epihiro Plc Un. Kingdom 2022 - voluntary settlement of tax obligation 7 Irida Plc Un. Kingdom 2022 - voluntary settlement of tax obligation 8 Pisti 2010-1 Plc Un. Kingdom 2022 - voluntary settlement of tax obligation 9 Alpha Quantum DAC Ireland Tax unaudited since commencement of its operation in 2019 10 AGI-RRE Poseidon Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2012 - Tax audit is in progress for the year 2018 11 AGI-RRE Hera Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2012 - Tax audit is in progress for the year 2018 **12 Alpha Holdings S.Μ.S.A.Greece 100.00 100.00 The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 13 AGI-BRE Participations 2 Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2011 - Tax audit is in progress for the year 2018 14 AGI-BRE Participations 3 Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2011 - Tax audit is in progress for the year 2018

* These companies received tax certificate for the years up to and including 2023 without any qualification.

** These companies received tax certificate for the years up to and including 2022 without any qualification.

*** These companies received tax certificate for the years up to and including 2021 without any qualification.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

321 | ANNUAL FINANCIAL REPORT

Group’s ownership Name Country interest % Audited year by tax authorities up and including: 31.12.2024 31.12.2023 15 AGI-BRE Participations 4 Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2010 - Tax audit is in progress for the year 2018 16 AGI-RRE Ares Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2010 - Tax audit is in progress for the year 2018 17 AGI-RRE Artemis Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2012 - Tax audit is in progress for the year 2018 18 AGI-BRE Participations 5 Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2012 - Tax audit is in progress for the year 2018 19 AGI-RRE Cleopatra Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2013 - Tax audit is in progress for the year 2018 20 AGI-RRE Hermes Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2013 - Tax audit is in progress for the year 2018 21 AGI-RRE Arsinoe Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2013 - Tax audit is in progress for the year 2018 22 AGI-SRE Ariadni Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2013 - Tax audit is in progress for the year 2018 23 Zerelda Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2012 - Tax audit is in progress for the year 2018 24 AGI-Cypre Evagoras Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2014 - Tax audit is in progress for the year 2018 25 AGI-Cypre Tersefanou Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2014 - Tax audit is in progress for the year 2018 26 AGI-Cypre Ermis Ltd Cyprus 100.00 100.00 2016 - Commencement of operation 2014 - Tax audit is in progress for the years 2017-2021 27 AGI-SRE Participations 1 Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2016 - Tax audit is in progress for the years 2018 28 Alpha Credit Acquisition Company Ltd Cyprus 100.00 100.00 2021 - Commencement of operation 2019 *29 Alpha International Holdings Μ.S.A.Greece 100.00 100.00 Tax unaudited since commencement of its operation in 2020 30 Gemini Core Securitisation Designated Activity Company Ireland Company was sold within the year 31 AGI-BRE Bistrica EOOD Bulgaria 100.00 Company was sold within the year 32 AGI-BRE Vasil Levski EOOD Bulgaria 100.00 Company was sold within the year 33 AGI-BRE Ekzarh Yosif EOOD Bulgaria 100.00 Company was sold within the year 34 Alpha Investment Property Neas Kifissias S.A. Greece 100.00 The company was sold within the year 35 Alpha Investment Property Kallirois S.A. Greece 100.00 The company was sold within the year 36 Alpha Investment Property Livadias S.A. Greece 100.00 The company was sold within the year 37 Alpha Investment Property Neas Erythreas S.A. Greece 100.00 The company was sold within the year 38 Alpha Investment Property Kallitheas S.A. Greece 100.00 The company was sold within the year 39 Alpha Investment Property Irakleiou S.A. Greece 100.00 The company was sold within the year 40 AIP Commercial Assets City Centres S.M.S.A. Greece 100.00 The company was sold within the year 41 AIP Thessaloniki Commercial Assets S.M.S.A. Greece 100.00 The company was sold within the year 42 AIP Commercial Assets Rog S.M.S.A. Greece 100.00 The company was sold within the year 43 AIP Attica Retail Assets I S.M.S.A. Greece 100.00 The company was sold within the year 44 AIP Retail Assets Rog S.M.S.A. Greece 100.00 The company was sold within the year 45 Skyline Properties M.S.A. Greece 100.00 The company was sold within the year 46 Athens Commercial Assets I M.S.A. Greece 100.00 The company was sold within the year 47 Athens Commercial Assets II M.S.A. Greece 100.00 The company was sold within the year 48 A.G. Star Gisama Investments LTD Cyprus 100.00 Tax unaudited since commencement of its operation in 2024 Other companies 1 Alpha Bank London Nominees Ltd Un. Kingdom 100.00 100.00 The company is not subject to a tax audit 2 Alpha Trustees Ltd Cyprus 100.00 100.00 2017 - Commencement of operation 2002 - Tax audit is in progress for the year 2018 The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to ***3 Kafe Alpha S.A.Greece 100.00 100.00 voluntary settlement for the tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017

* These companies received tax certificate for the years up to and including 2023 without any qualification.

*** These companies received tax certificate for the years up to and including 2021 without any qualification.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

322 | ANNUAL FINANCIAL REPORT

Group’s ownership Name Country interest % Audited year by tax authorities up and including: 31.12.2024 31.12.2023 The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to 4 Alpha Supporting Services S.A.*** Greece 100.00 100.00 voluntary settlement for the tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to 5 Real Car Rental S.A.*** Greece 100.00 100.00 voluntary settlement for the Tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the circular POL. 1208/2017 The company has been audited by the tax authorities up to and including 2009 in accordance with Law 3888/2010 which relates to Commercial Management and Liquidation of Assets-6 Greece 100.00 100.00 voluntary settlement for the tax unaudited years. The years up to and including 2018 are considered as audited in accordance with the Liabilities S.A.** circular POL. 1208/2017 **The years up to and including 2018 are considered as audited in accordance with the circular POL.1208/2017 - partial tax audit is in 7 Alpha Bank Debt Notification Services S.A.Greece 100.00 100.00 progress for the years 2020-2021

b. Joint ventures

Group’s ownership interest % Name Country 31.12.2024 31.12.2023 1 APE Commercial Property S.A. Greece 72.20 72.20 2 APE Investment Property S.A. Greece 71.08 71.08 3 Alpha TANEO KES Greece 51.00 51.00 4 Rosequeens Properties Ltd Cyrprus 33.33 33.33 5 Panarae Saturn LP Jersey 61.58 61.58 6 Alpha Investment Property Commercial Stores S.A. Greece 70.00 70.00 7 Iside spv Srl Italyc. Associates

Group’s ownership interest % Name Country 31.12.2024 31.12.2023 1 ΑEDEP Thessalias and Stereas Ellados Greece 50.00 50.00 2 ALC Novelle Investments Ltd Cyrprus 33.33 33.33 3 Banking Information Systems S.A. Greece 23.77 23.77 4 Propindex AEDA Greece 35.58 35.58 5 Olganos S.A. Greece 30.69 30.44 6 Alpha Investment Property Elaiona S.A Greece 50.00 50.00 7 Zero Energy Buildings Energy Services S.A. Greece 43.87 43.87 8 Perigenis Commercial Assets S.A. Greece 32.00 32.00 9 Cepal Holdings S.A. Greece 20.00 20.00 10 Aurora SME I DAC Ireland 11 Alpha Compass DAC Ireland

** These companies received tax certificate for the years up to and including 2022 without any qualification.

*** These companies received tax certificate for the years up to and including 2021 without any qualification.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

323 | ANNUAL FINANCIAL REPORT

Group’s ownership interest % Name Country 31.12.2024 31.12.2023 12 Nexi Payments Hellas S.A. Greece 9.99 9.99 13 Alpha Blue Finance Designated Activity Company Ireland 14 Toorbee Travel Services Limited Hong Kong 12.45 12.45 15 Reoco Solar S.A. Greece 26.46 16 Unicredit Bank S.A. Romania 9.90 17 Alpha Bank Romania S.A. Romania 9.90 18 Skyline Properties M.S.A. Greece 35.00

The Group has joint control over Iside spv Srl and significant influence over Aurora SME I DAC, Alpha Compass DAC and Alpha Blue Finance Designated Activity Company, which are classified as Joint ventures and

Associates respectively. However, since the Group does not hold equity instruments issued by the above entities, accounting with the equity method is not applicable.

Following the completion of the 90.1% stake of the subsidiary Alpha Bank Romania on November 4, 2024, the Group retained 9.9% of the share capital of Alpha Bank Romania S.A, which is now classified as an

associate and acquired the 9.9% of the share capital of Unicredit S.p.A. Alpha Bank Romania S.A. and Unicredit S.p.A. are classified as associates, even though the ownership percentage is less than 20%, the

Group exerts significant influence over these companies through its subsidiary Alpha International Holdings S.A., as the latter has representation on the Board of Directors and, therefore, participates in making

important corporate decisions. At the same time, it has a veto right concerning critical corporate matters.

Moreover, after the completion of Skyline Real Estate Single Member S.A. (“Skyline’’) transaction, the Group retained 35% of its share capital, and is now treated as an associate and is consolidated using the

Equity method.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

324 | ANNUAL FINANCIAL REPORT

Group subsidiaries with non-controlling interest

The table as below provides information in relation with the Group subsidiaries with non controlling interest: Non-controlling interests % Non-controlling interests Name Country 31.12.2024 31.12.2023 31.12.2024 31.12.2023 1. APE Fixed Assets S.A. Greece 27.8 27.8 11 11 2. Alpha Real Estate Services S.A. Greece 6.83 6.83 5 7 3. Alpha Real Estate Bulgaria EOOD Bulgaria 6.83 6.83 4. Alpha Bank Romania S.A. Romania 0.08 5. Romfelt Real Estate S.A. Romania 0.01 0.01 6. Alpha Real Estate Services Srl Romania 6.83 6.83 7. Alpha Real Estate Services LLC Cyprus 6.83 6.83 Total 16 18 The percentage of voting rights held by third parties in subsidiaries does not differ with their participation in their share capital.

With respect to the above mentioned subsidiaries, significant non-controlling interests as at 31.12.2024 exist in Alpha Real Estate Services S.A.

and in APE Fixed Assets S.A.

A condensed set of financial information of Alpha Real Estate Services S.A. and APE Fixed Assets S.A. where Intra-group balances and

transactions have not been eliminated is presented below.

Condensed Statement of Total Comprehensive Income

Alpha Real Estate Services S.A. APE Fixed Assets S.A. From 1 January to From 1 January to 31.12.2024 31.12.2023 31.12.2024 31.12.2023 Total income 23 18 Total expenses (15) (14) Profit/(loss) for the year after income tax 8 4 - - Total comprehensive income for the year, after income tax 8 4 - -

Condensed Balance Sheet

Alpha Real Estate Services S.A. APE Fixed Assets S.A. 31.12.2024 31.12.2023 31.12.2024 31.12.2023 Total non-current assets 6 22 39 39 Total current assets 70 81 Total short-term liabilities 9 8 Total long-term liabilities 1 Total Equity 67 94 39 39

Condensed Cash flow statement

Alpha Real Estate Services S.A. APE Fixed Assets S.A. From 1 January to From 1 January to 31.12.2024 31.12.2023 31.12.2024 31.12.2023 Total inflows/(outflows) from operating activities 18 (65) Total inflows/(outflows) from investing activities 17 20 Total inflows/(outflows) from financing activities (34) (4) Total inflows/(outflows) for the year 1 (49) - - Cash and cash equivalents at the beginning of the year 2 51 - - Cash and cash equivalents at the end of the year 3 2 - -

The company Alpha Real Estate Services S.A. announced on 31.7.2024 the distribution of a dividend of a total amount of € 4. The payment was

completed within the month of December 2024 (31.12.2023: € 4).

Significant Restrictions

The Group’s significant restrictions regarding the use of assets or the settlement of liabilities, are those imposed by the regulatory framework

in which its subsidiaries operate and concerns mainly those that are subject to supervision for their capital adequacy. In particular, the

regulatory authorities request, where appropriate and depending on the nature of the company, the compliance with specific thresholds, for

example maintaining minimum capital adequacy ratios, holding a predetermined level of highly liquid assets, minimizing their exposure to

other Group companies and complying with specified ratios. The total assets and liabilities of the subsidiaries operating in the banking,

insurance and other mainly financial sectors with significant restrictions amount to € 74,459 mil. (31.12.2023: € 77,753 mil.) and € 66,338 mil.

(31.12.2023 € 69,185 mil.) respectively.

In addition, all Greek subsidiaries are subject to the restrictions imposed by the regulatory framework (Codified Law 4548/2018 or any other

specific legislation depending on the nature of their operations) regarding the minimum threshold of the share capital and net assets as well as

the ability to distribute dividends and to transfer equity shares.

There are no options of protection rights held by third parties in the share capital of subsidiaries that could otherwise limit the Group’s ability

to utilize those assets or settle the Group’s liabilities.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

325 | ANNUAL FINANCIAL REPORT

Consolidated structured entities

The Group as at 31.12.2024 consolidates the structured entities Pisti 2010-1 Plc and Gemini Core Securitisation Dac that serve securitization

transactions of loan portfolios originated by the Group. The Pisti securitization was established for liquidity purposes through the issuance of

notes, while the securitization of Gemini Core Securitisation Dac was established to serve the management of non performing loans. The

Group exercises control over these structured entities as it has authority over their activities and significant exposure to their returns. The

nominal value of notes issued per structured entity, all of which are held by the Group, is presented in note 33.

With regards to the Pisti transaction, depending on the eligibility criteria applicable to the securitized portfolio, the Group repurchases

securitized loans on a case-by-case basis, without however having a relevant contractual obligation. In addition, the Group securitizes new

loans in order to meet specific quantitative criteria related to the amount of the notes issued. The Group’s intention is to continue the above

practice. The Group has no contractual obligation to grant additional financing to Pisti 2010-1 Plc.

With regards to the Gemini non-performing loans securitization transaction, repurchases and new securitizations are carried out to ensure that

the eligibility criteria are met. Repurchases and new securitizations are not settled in cash but adjust the value of the bond issued by the

special purpose entity. The Group has no contractual obligation to provide additional financing to the above entity, but has undertaken the

commitment to issue letters of guarantee for Gemini Core Securitisation Dac up to a total limit of €30 as at 31.12.24, in exchange for the

collection of a commission. In case of forfeiture of any guarantee the amount paid becomes immediately due and, along with the commission,

is repaid through the deposit accounts the structured entity holds with the Bank in the context of the securitization transaction.

During 2024 the corporate loans and finance lease receivables securitization transactions that had been respectively set up via Epihiro Plc and

Irida Plc were revoked with the repurchase of the total of the securitized portfolios by the Group.

Changes of ownership interest in subsidiaries which did not result in loss of control

During 2024 and 2023 there was no change in the shareholder structure of the Group’s subsidiaries.

Loss of control in subsidiary due to sale or liquidation

• On 18.6.2024 Groups’ subsidiary company Office Park I was liquidated, while no profit or loss was recognized. At the time of liquidation the

subsidiary held a cash of € 10.

• On 27.6.2024 Group’s subsidiary company Alpha Group Real Estate Ltd, proceeded to the sale of its subsidiary AGI BRE Participations 2BG

EOOD for a cash consideration of € 3, resulting into a loss of 1 recognised in line “Gains/(Losses) on disposal of fixed assets and equity

investments”.

• On 19.8.2024 Groups’ subsidiary company Chardash Trading E.O.O.D. was sold for a cash consideration of € 17, resulting into a loss of € 1

recognised in line Gains/(Losses) on disposal of fixed assets and equity investments”. At the time of sale the subsidiary held a cash of € 0.

• On 4.11.2024 Alpha International Holdings SMSA transferred the 90,1% of Alpha Bank Romania to Unicredit S.p.A. Thus Alpha International

Holdings SMSA has remained a shareholder of Alpha Bank Romania S.A. with a percentage of 9.9% (Note 52). From the derecognition of

the net assets of the entity, a gain of € 7 was recognized in line ‘’Gains/(Losses) on disposal of fixed assets and equity investments”. This

gain includes a gain of € 8 as a result of remeasuring the 9.9% stake retained at its fair value. . At the time of sale the subsidiary held a cash

of € 501. Alpha Bank Romania S.A. 4.11.2024 Cash and balances with central banks 501 Due from banks 304 Loans and advances to customers 3,118 Investment securities - Measured at fair value through other comprehensive income 90 - Measured at fair value through profit or loss 7 - Measured at amortised cost 253 Property, plant and equipment 46 Investment property 6 Goodwill and other intangible assets 15 Deferred tax assets 4 Other assets 18 Total Assets 4,362 Due to banks 67 Due to customers 3,427 Debt securities in issue and other borrowed funds 284 Liabilities for current income tax 6 Other liabilities 62 Provisions 12 Equity 504 Total Liabilities and Equity 4,362 • On 19.12.2024 Groups’ subsidiary company AGI-BRE Vasil Levski EOOD , was sold for a cash consideration of € 2 while no profit was

recognized from the sale. At the time of sale the subsidiary held a cash of € 0.

• On 19.12.2024 Groups’ subsidiary company AGI-BRE Ekzarh Yosif EOOD, was sold for a cash consideration of € 1 while no profit was

recognized from the sale. At the time of sale the subsidiary held a cash of € 0.

• On 19.12.2024 Groups’ subsidiary company AGI-BRE Bistrica EOOD, was sold while no cash consideration or profit or loss was recognized

from the sale. At the time of sale the subsidiary held a cash of € 0.

• On 19.12.2024 Groups’ subsidiary company Pernik Logistics Park EOOD, was sold while there was no impact on the Group’s net assets and

Profit or Loss for the year.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

326 | ANNUAL FINANCIAL REPORT

AGI BRE Chardash AGI-BRE Vasil AGI-BRE Ekzarh Office Park Ι Participations Trading Levski EOOD Yosif EOOD 2BG EOOD E.O.O.D Due from banks 10 - - - - Investment property - 3 17 2 1 Total Assets 10 3 17 2 1 Total Liabilities - - - - - Net Assets 10 3 17 2 1

• On 20.12.2024, the sale transaction of Skyline and its subsidiaries was completed, transferring 65% of its shares to the joint venture

Dimand S.A. - Premia Properties S.A., thus retaining a 35% stake in Skyline (Note 52). From the derecognition of the net assets of the

entity, a gain of €23 was recognized in line ‘’Gains/(Losses) on disposal of fixed assets and equity investments”, of which €29 as a result

of remeasuring the 35% stake retained at its fair value.

Subsidiary companies for which the Group had lost control as at 31.12.2024: ΑΑ Company ΑΑ Company 1 Alpha Investment Property Neas Kifissias S.A. 8 AIP Thessaloniki Commercial Assets S.M.S.A. 2 Alpha Investment Property Kallirois S.A. 9 AIP Commercial Assets Rog S.M.S.A. 3 Alpha Investment Property Livadias S.A. 10 AIP Attica Retail Assets I S.M.S.A. 4 Alpha Investment Property Neas Erythreas S.A. 11 AIP Retail Assets Rog S.M.S.A. 5 Alpha Investment Property Kallitheas S.A. 12 Skyline Properties M.S.A. 6 Alpha Investment Property Irakleiou S.A. 13 Athens Commercial Assets I M.S.A. 7 AIP Commercial Assets City Centres S.M.S.A. 14 Athens Commercial Assets II M.S.A. At the date of completion of the transaction, the Assets and Liabilities of Skyline Properties M.S.A. as well as of the 13 other entities sold are

presented aggregated on the below table:

20.12.2024 Due from Financial Institutions 106 Investment property 132 Other assets 24 Total Assets 262 Liabilities from current income tax 1 Other Liabilities 104 Equity 157 Total Liabilities and Equity 262Exposure to non-consolidated structured entities

a. Mutual funds under Group Management

The Group, through its subsidiary Alpha Asset Management AEDAK, manages 66 (31.12.2023: € 58) mutual funds which meet the definition of

structured entities and at each reporting date, it assesses whether it controls any of these according with the provisions of IFRS 10.

The Group, acting as the manager of the mutual funds has the ability to direct the activities which significantly affect the level of their return

by selecting the investments made by the funds within the framework of permitted investments as described in the regulation of each fund. As

a result, the Group has power over the mutual funds under management but within a clearly defined decision making framework. Moreover

the Group is exposed to variable returns through its involvement in the mutual funds as it receives fees for the purchase, redemption and

management of the funds under normal market levels for similar services. The Group also holds direct investments in some of the funds under

management, the level of which is assessed to be determined whether it leads to a significant variability in its returns compared to the

variability of the respective total rate of return of the mutual fund. Due to these factors, the Group assessed that, for all mutual funds under

management, it exercises, for the benefit of unit holders, the decision making rights assigned to it acting as an agent without controlling the

mutual funds.

The following table presents the total assets of the mutual funds under management but not controlled by the Group by category of

investment. During the year 2024, the commission income from the management fees of these Mutual Funds amounted to € 54 (31.12.2023:

€ 36).

Total Assets 31.12.2024 31.12.2023 Category of Mutual Funds Bond Funds 2,740 1,590 Money Market Funds 35 45 Equity Funds 927 817 Balanced Funds 1,272 997 Total 4,974 3,449

The direct investment of the Group in the above mutual funds was classified, in the portfolio of investment securities measured at fair value

through profit or loss. The carrying amount of the investment in mutual funds as at 31.12.2024 amounts to € 556 (31.12.2023: € 426). The

change in the fair value of the aforementioned mutual funds during the year 2024 resulted in a gain of € 33 (year 2023: gain of € 25). It is noted

that there is no contractual obligation for the Group to provide financial support to any of the mutual funds under management nor does it

guarantee their rate of return.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

327 | ANNUAL FINANCIAL REPORT

b. Securitisation non-consolidated structured entities

The Group holds 100% of the senior notes and 5% of the mezzanine and junior notes that were issued by the structured entities Orion

Securitization DAC, Galaxy II Funding DAC, Galaxy IV Funding DAC and Cosmos Securitization DAC in the context of non-performing loan

securitization transactions in previous years. The Group does not exercise control over the activities of the above entities. The following table

presents the carrying amount of notes that the Group holds and the related results.

Profit or Loss 31.12.2024 Carrying Amount Gain Less Losses on 31.12.2024 Interest Income Impairment Losses Financial Transactions Loans and Advances to Customers measured at Amortised Cost Notes issued by special purpose entities 4,902 27 4 Loans and Advances to Customers measured at fair value through profit or loss Notes issued by special purpose entities 1 Profit or Loss 31.12.2023 Carrying Amount Gain Less Losses on 31.12.2023 Interest Income Impairment Losses Financial Transactions Loans and Advances to Customers measured at Amortised Cost Notes issued by special purpose entities 5,161 28 Loans and Advances to Customers measured at fair value through profit or loss Notes issued by special purpose entities 2 1

The total nominal value of notes issued from the above entities as at 31.12.2024 amounts to € 13.6 bil. (31.12.2023:13.8 bil.).

The Group has granted loans with a carrying amount of € 99 as at 31.12.2024 (31.12.2023: € 104.) to the special purpose entities Orion

Securitization DAC, Galaxy II Funding DAC, Galaxy IV Funding DAC and Cosmos Securitization DAC for the purpose of financing their reserves.

The net income recognized by the Group from the above loans in 2024 amounted to gain of € 1 (2023: € 1). As at 31.12.2024 the cash deposits

of the above entities with the Group amount to € 222 (31.12.2023: € 199)

In connection with the Group’s commitments resulting from these securitization transactions, it should be noted that the transferred

securitized portfolios included letters of guarantee. In case of forfeiture of any of them, the payment to the third party (to whom the letter of

guarantee is addressed) is made from special deposit accounts, with reserved balances, held by the aforementioned special purpose entities

with the Group.

Moreover, the Group has committed to issue letters of guarantee for the above securitization companies up to the total amount of € 350.,

through a relevant loan facility limit, for which a commission is received. In case of forfeiture of any guarantee, the amount paid becomes

immediately due and the capital amount is repaid through the securitization current accounts, while the amount of interest and other

commissions is repaid through the reserves of the securitization company and in case these are not sufficient, it takes a high order priority of

payment and is repaid on the coupon payment dates of the bonds.

It is noted that the Group has committed to provide financing, on behalf of the aforementioned securitization entities, to the special purpose

entities set up for the acquisition of properties or shareholdings (REOCOs), through the signing of bond loan agreements. In the event that a

relevant loan is required to be granted under these contracts, this is transferred directly to the securitization company that holds the

securitized portfolio, with an advance payment of the transfer consideration, from a relevant reserve that is held by the securitization

company. In the event that the consideration is not paid in advance, the Group is not obliged to proceed with the loan disbursement and

therefore the Group’s exposure to credit risk from the above transaction is zero. It is noted that the legal transfer of said claims has already

taken place at the time of the securitization in the form of a transfer of future claims under the specific bond loans. The above companies have

deposits with the Group of € 31 mil. as at 31.12.2024 (31.12.23 € 40 mil.).

The aforementioned carrying amounts of bonds and loans, together with the commitments of the Group to provide loans and guarantees,

constitute the maximum possible exposure of the Group to the special purpose entities, established in the context of the Galaxy and Cosmos

transactions.

The Group, in the context of loan portfolios’ synthetic securitization transactions, has entered into financial guarantee contracts with the

special purpose entities Aurora SME I DAC, Alpha Compass DAC and Alpha Blue Finance DAC for the acquisition of credit protection for a part

of credit losses of the securitized portfolios. The above special purpose entities have issued bonds that were covered by third parties not

affiliated with the Group, and the proceeds from their issuance are collateral for the Group’s compensation in case of forfeiture of the

guarantee. The Group has significant influence over these entities since, although their activities are predetermined, it reserves the right to

make decisions on specific core activities that mainly relate with the management of the collateral and its investment in eligible securities

according to predetermined criteria. Since there is no Group exposure to the equity instruments of the above entities, the equity method is

not applicable. The Group pays a commission to the special purpose entities for the provision of the guarantee and has also undertaken to

cover their expenses. The related expenses recognize in 2024 amounted to € 45. (2023: € 31). The nominal value of the bonds issued by these

entities amounted to € 376 (31.12.2023 € 426).

The Group participates, jointly with another lender, in the financing of the special purpose entity Iside Spv Srl, which was established for the

purpose of financing a real estate investment company in the context of the Italian Securitization Law. Based on this law, the financing

provided to the special purpose entity is collateralized with mortgages of the ultimate debtor, while the repayment of the financing reflects

the repayment schedule of the loan granted by the special purpose entity to the ultimate debtor. As the company’s main activity is related to

its issued bonds, for which decisions are taken jointly with the other lender, the Group has joint control over the special purpose entity. The

amount of said financing as of 31.12.2024 € 49 (31.12.2023: € 56)., while the net results recognized in the Group accounts from said financing

amount to a gain € 4 (2023: € 5).

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

328 | ANNUAL FINANCIAL REPORT

c. Other Special structured entities

In addition, the Group has investments in special purpose entities through its participation in venture capital mutual funds which it does not

manage as well as in companies subject to the issuance of securities secured by its assets (asset-backed securities). The following table

analyzes the said participations of the Group. As an indication of the size of the non-consolidated structured entities the total assets of the

funds based on most recent available balance sheet and the total nominal value of asset-backed securities are given.

Carrying Amount Total Assets / Nominal Value 31.12.2024 31.12.2023 31.12.2024 31.12.2023 Structured Entity category Investment securities measured at fair value through OCI Venture capital mutual funds 13 10 467 324 Asset- backed securities 1 124 159 Investment securities at fair value through profit or loss Asset- backed securities 10 10 29 29 Investments in associates and joint ventures Venture capital mutual funds 1 1 3 2 The Group is committed to participating in additional investments in the aforementioned mutual funds up to a total amount of €13

(31.12.2023: €17). This commitment, together with the carrying value of the investment, represents the Group's maximum exposure to these

investments.

From its shares in asset-backed securities, the Group recognized interest income of € 1 for the 2024 financial year (31.12.2023: €1) and no

gains or losses (31.12.2023: € 0) were recognized in the Statement of profit or loss.

The Group has no contractual obligation to provide financial support to the entities that issued these securities. The maximum potential

exposure of the Group to losses from asset-backed securities is consistent with their carrying value.

45. Disclosures Law 4261/5.5.2014

Article 81 of Law 4261/5.5.2014 transposed into Greek legislation the Article 89 of Directive 2013/36/EU of the European Parliament and of

the Council of 26 June 2013, according to which, it is enacted for first time the obligation to disclose information on a consolidated basis by

Member State and third country in which the Group has a head office as follows: company name or company names, nature of operations,

geographic location, turnover, results before tax, income tax, public subsidies received and the number of full time employees.

The quantitative information required is set out below by geographical area. Note 44 presents in detail the subsidiaries included in each

geographical area as well as the nature of the activity of each company.

United Greece Cyprus Romania Bulgaria Kingdom Turnover 5,724 45 244 321 - Profit Before Taxes 1,286 (2) 45 27 (2) Income tax Expense (240) (1) (9) (7) - Number of employees 5,524 75 411 34 1

It is noted that neither the Company nor the Group companies have received amounts related to public subsidies.

Article 82 of Law 4261/5.5.2014 transposed into Greek Law article 90 of Directive 2013/36/EU of the European Parliament and of the Council

of 26 June 2013, which establishes for the first time the requirement to disclose total return on assets. The total return on the assets of the

Group for the year 2024 amounts to 0.91%.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

329 | ANNUAL FINANCIAL REPORT

46. Segment Reporting

a. Operating Segments

The Executive Committee is the chief operating decision maker and monitors internal reporting on the Group operating segments’

performance based on which segments’ results against targets are evaluated and allocation of resources is decided.

1.1 – 31.12.2024 Non Corporate Wealth International Retail Wholesale Performing Center/Elimination Group Management Activities Assets Center Net interest income 621 737 15 131 27 114 1,645 Net fee and commission income 150 132 114 19 5 420 Other income 17 40 7 5 12 76 157 Total income 788 909 136 155 44 190 2,222 Of which income between operating segment 20 93 12 (125) Total expenses (411) (183) (57) (79) (65) (71) (866) Impairment losses and provisions to cover credit risk and (23) (43) (2) (384) (452) other related expenses Impairment losses on other financial instruments (1) (1) Impairment losses on fixed assets and equity investments (4) (11) (15) Gains/(Losses) on disposal of fixed assets and equity 25 2 27 investments Provisions and transformation costs (47) (17) (5) (5) (2) (23) (99) Share of profit/(loss) of associates and joint ventures - - Profit/(loss) before income tax 307 666 74 69 (386) 86 816 Income tax (219) Net profit/(loss) from continuing operations for the year 597 after income tax Net profit/(loss) for the year after income tax from 24 33 57 discontinued operations Net profit/(loss) for the year 654 Assets 31.12.2024 12,981 31,714 159 4,828 2,700 19,693 72,075 Liabilities 31.12.2024 35,708 10,786 2,025 4,161 406 10,800 63,886 Capital expenditure 83 25 4 7 24 9 152 Depreciation and Amortization (101) (41) (10) (6) (13) (8) (179) Investments in associates and joint ventures 329 241 570 Profit before income tax of the operating segment named “Corporate Center/Elimination Center” of a total amount of € 86 include income

from eliminations between operating segments amounting in total of € 0.07 mil. 1.1 – 31.12.2023 Non Corporate Wealth International Retail Wholesale Performing Center/Elimination Group Management Activities Assets Center Net interest income 635 699 20 129 64 112 1,659 Net fee and commission income 135 127 83 19 10 374 Other income 15 53 3 12 14 (1) 96 Total income 785 879 106 160 88 111 2,129 Of which income between operating segment 17 89 13 (14) (105) Total expenses (395) (162) (47) (67) (79) (65) (815) Impairment losses and provisions to cover credit risk and (42) (42) (10) (379) 2 (471) other related expenses Impairment losses on other financial instruments 2 2 Impairment losses on fixed assets and equity investments (9) (10) (19) Gains/(Losses) on disposal of fixed assets and equity (1) 1 3 3 investments Provisions and transformation costs (42) (21) (7) (2) 24 (2) (50) Share of profit/(loss) of associates and joint ventures Profit/(loss) before income tax 306 654 52 80 (354) 41 780 Income tax (226) Net profit/(loss) from continuing operations for the year 306 654 52 80 (354) 41 554 after income tax Net profit/(loss) for the year after income tax from 14 50 64 discontinued operations Net profit/(loss) for the year 618 Assets 31.12.2023 13,196 29,278 222 8,334 3,602 17,789 72,421 Liabilities 31.12.2023 34,735 9,439 1,908 7,363 478 11,175 65,098 Capital expenditure 81 25 4 10 16 22 158 Depreciation and Amortization (87) (34) (8) (6) (13) (9) (157) Investments in associates and joint ventures 100 100

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Profit before income tax of the operating segment named “Corporate Center/Elimination Center” of a total amount of € 112 include income

from eliminations between operating segments amounting in total of € 1.

i. Retail

All Individuals (retail banking customers), self-employed professionals, small and very small companies operating in Greece. This operating

segment offers all types of deposit products (saving accounts, current accounts, term deposits etc.), debit and credit cards, credit facilities

(mortgages, consumer, business loans, leasing products, factoring services, letters of guarantee/letters of credit etc.). In addition, it includes

insurance and bancassurance products.

ii. Wholesale

All medium-sized and large companies including shipping corporations and enterprises which cooperate with the Wholesale Banking and

Investment Banking Divisions. This operating segment offers working capital facilities, corporate loans, leasing products, factoring services,

letters of guarantee/letters of credit etc. It also offers investment banking services including corporate finance. It also includes the execution

of trading activities in the interbank market (FX, bonds, derivatives, money market, etc.).

iii. Wealth Management

Wealth management services offered to all client segments through the Private Banking units, the subsidiaries Alpha Finance and Alpha Asset

Management A.E.D.A.K. as well as revenues from the sale and management of mutual funds.

iv. International

All products and services offered through the international network in Cyprus, Romania and United Kingdom.

v. Non-performing assets

This operating segment includes the management of non-performing assets in Group, as well as any company established to manage these

assets and related real estate. In addition, participations and shares from loan recoveries are included.

vi. Corporate Center

Includes activities under the management of the Chief Investment Officer related to the Group’s liquidity, funding, capital, structural interest

rate and foreign exchange risks, as well as investments in non-commercial assets (incl. securities at amortised cost and investment property).

This segment also includes other Group operations not allocated to specific operating segments, as well as intersegment eliminations.

b. Geographical segments

The breakdown by geographical segment is defined by the country of the business operations of the Group company.

1.1 - 31.12.2024 Greece Other countries Group Net interest income 1,513 132 1,645 Net fee and commission income 401 19 420 Other income 147 10 157 Total income 2,061 161 2,222 Total expenses (777) (89) (866) Impairment losses and provisions to cover credit risk and related expenses (427) (25) (452) Impairment losses on other financial instruments (1) (1) Impairment losses on fixed assets and equity investments (14) (1) (15) Gains/(Losses) on disposal of fixed assets and equity investments 27 27 Provisions and transformation costs (94) (5) (99) Share of profit/(loss) of associates and joint ventures - Profit/(loss) before income tax 775 41 816 Income tax (219) Net profit/(loss) from continuing operations for the year after income tax 597 Net profit/(loss) for the year after income tax from discontinued operations 24 33 57 Net profit/(loss) for the year 654 Non current assets 31.12.2024 1,116 145 1,261 1.1 - 31.12.2023 Greece Other countries Group Net interest income 1,525 134 1,659 Net fee and commission income 355 19 374 Other income 78 18 96 Total income 1,958 171 2,129 Total expenses (727) (88) (815) Impairment losses and provisions to cover credit risk and related expenses (408) (63) (471) Impairment losses on other financial instruments 2 2 Impairment losses on fixed assets and equity investments (11) (8) (19) Gains/(Losses) on disposal of fixed assets and equity investments 8 (5) 3 Provisions and transformation costs (73) 23 (50) Share of profit/(loss) of associates and joint ventures - Profit/(loss) before income tax 750 30 780 Income tax (226) Net profit/(loss) from continuing operations for the period after income tax 553,0 Net profit/(loss) for the period after income tax from discontinued operations 14 50 64

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Net profit/(loss) for the period 617 Non current assets 31.12.2023 1,123 145 1,269

47. Risk Management

The Group has designed and implements a framework for managing the risks it faces, taking into account the best banking practices and

regulatory requirements. In accordance with common European legislation and the current system of common banking rules, principles and

standards, this system is constantly evolving to ensure that the Group's corporate governance is effective.

1. RISK MANAGEMENT FRAMEWORK

1.1 Risk Management Governance

The Board of Directors (BoD) supervises the overall operations of the Risk Management Funcition. The BoD has established a Board Risk

Management Committee (RMC), which convenes, on a monthly basis and reports to the Board of Directors. The Committee recommends to

the Board of Directors the risk undertaking and capital management strategy, checks its implementation and evaluates its adequacy and

effectiveness.

The risk management framework and its effectiveness are reassessed on a regular basis, in order to ensure compliance with best practices as

well as the supervisory and regulatory requirements.

For a more comprehensive and effective identification and monitoring of all types of risks, Management Committees have been established

(Assets and Liabilities Management Committee, Non - Financial Risks and Internal Control Committee, Credit Risk Committee,

Group

Sustainability Committee and Reputational Risk Committee).

1.2 Risk management Unit

The Group Chief Risk Officer supervises the Group’s Risk Management Function. Under the responsibility of the Risk Management Function

regular and ad hoc reports are submitted to the Management Committees, the Risk Management Committee and the Group’s Board of

Directors. These reports cover the management of all types of risks. As far as credit risk is concerned the reporting covers the following areas:

• The risk profile of portfolios by rating grade.

• The transition among rating grades (migration matrix).

• The estimation of the relevant risk parameters by rating grade, group of clients, etc.

• The trends of basic rating criteria.

• The changes in the rating process, the criteria or in each specific parameter.

• The concentration risk (by risk type, sector, country, collateral, portfolio etc.).

• The evolution of Loan exposures, +90 days past due loans, Non-Performing exposures and the monitoring of KPIs on a Group basis.

• The Cost of Risk.

• The IFRS 9 Staging transition of exposures per asset class.

• The maximum risk appetite (credit risk appetite) per country, sector, currency, Business Unit, limit breaches and mitigation plans.

1.3 Organizational Structure

The following Risk Management Business Areas operate under the supervision of the Group Chief Risk Officer in the Group, that have the

responsibility for the immediate implementation of risk management framework in accordance with the guidelines of the Risk Management

Committee.

• Chief Risk Control Officer

- Credit Risk and Enterprise Risk Modelling

- Credit Control

- Climate, ESG and Enterprise Risk Management

- Non-Financial Risks Control

- Market Risk Control

• Chief Credit Officer

- Wholesale Credit

- Retail Credit

• Risk Models and Data Validation

47.1 Credit Risk

For credit risk Management purposes, lending facilities are separated into Wholesale and Retail as described below.

1. WHOLESALE BANKING CREDIT FACILITIES

Wholesale Banking credit facilities are provided to companies with a turnover > € 10 million or with a credit limit > € 1 million.

1.1 Credit Risk approval process

The Group, following best international practices and taking into account the prevailing institutional framework set by legislation, regulations,

ministerial decrees/decisions etc., has designed a robust credit risk framework, where the main principles, guidelines, procedures followed and

the responsibilities of involved Business Areas and Relationship Managers are clearly defined, based on the four eyes principle.

In this context, all credit proposals are prepared by the Product Business Areas, are reviewed by the competent Credit Business Areas and are

assessed by the competent Credit Committee based on the total credit exposure, the obligor’s credit risk rating, the provided collaterals and

the Environmental, Social and Governance Risk (ESG) rating at obligor, transaction and overall level.

The limits of the Wholesale Banking Credit Committees are determined in accordance with the Total Credit Risk, which is defined as the aggregate

of all credit facilities to a single company or group of related companies including any financing provided to their owners which can be approved by

the Group.

Credit Committees decide on:

•

Approval of the terms of new loans, renegotiations or restructuring of existing credit facilities.

•

Approval of the loan pricing, considering the overall profitability of a client’s relationship based on the Risk Adjusted Return on Risk

Adjusted Capital - RARORAC (historical RARORAC – RARORAC based on the outcome of the proposed suggestion).

•

Credit Limit Expiration/Renewal date (depending on the customer’s credit risk zone) and any deviations from the rule.

•

Amendment on the collateral structure.

•

Decision for actions in case of activation of early warning triggers.

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•

Financial Difficulty assessment.

•

Unlikeliness to Pay (UTP) assessment.

•

Credit Rating grading.

•

Environmental, Social and Governance (ESG) risk rating at obligor, transaction, and overall level.

1.2 Credit Risk Measurement and Internal Ratings

The assessment of the borrowers’ creditworthiness and their scaling into credit risk categories is performed through rating systems.

The objective of the credit risk rating systems, for Wholesale Banking Customers, is the estimation of the probability that the borrowers will not

meet their contractual obligations to the Group and the estimation of the Expected Credit Loss.

The rating of the Group’s borrowers with the use of credit risk rating systems constitutes a basic tool for:

•

The decision-making process of Credit Committees for the approval/ renewal of credit limits and the implementation of the

appropriate pricing policy (interest rate spreads etc.).

•

The estimation of the future behavior of borrowers which belong to a group with similar characteristics.

•

The timely identification of potential troubled credit facilities and the prompt plan of the required actions for the minimization of the

expected loss for the Group.

•

The assessment of the Group’s loan portfolio quality and the credit risk undertaken.

The rating systems employed by the Bank and the Group entities are the Alpha Bank Rating System (ABRS) and Moody’s Credit Lens which

incorporate different credit rating models (including Slotting scorecards).

All current and potential clients of the Group are assessed based on the appropriate credit risk rating model and within the predefined time

frames.

For the estimation of the probability of default of the borrowers of the Group, the credit risk rating models evaluate a number of parameters,

which can be grouped as follows:

•

Financial analysis: borrower’s Financial Ability (liquidity ratios, debt to income, etc.)

•

Borrower’s position in the market environment in which operates compared to its competitors in the sector it belongs.

•

Transactional behaviour of the borrower both to the Group and third parties (debt in arrears, adverse transaction records, etc).

•

Borrower’s qualitative characteristics (integrity and succession plan of the management, appropriate infrastructure and equipment

etc.).

The credit rating models which are currently employed by the Group are differentiated according to:

•

The turnover of the companies.

•

The level of the total credit risk of the companies.

•

The credit facility’s specific characteristics.

•

The available information for the borrower’s assessment. Specifically, for the financial analysis the differentiation relates to the type

of the local accounting standards applied, the accounting framework applied (financial services, insurance services ect.) and whether

the financial statements are prepared in accordance with the International Financial Reporting Standards.

For each of the credit rating models, different parameters may be used, each of which contributes in a specific manner the relevant

assessment.

1.3 Borrowers Rating Scale

Borrowers are rated in the following rating scales: ΑΑ, Α+, Α, A-, ΒΒ+, ΒΒ, ΒΒ-, B+, Β, Β-, CC+, CC, CC-, C, D, D0, D1, D2

For special purpose finance (Structured Finance and Shipping Financing) special models have been designed (slotting) with the following

categorization scale:

Strong (Category 1), Good (Category 2), Satisfactory (Category 3), Weak (Category 4), Default (D, D0, D1, D2).

The mapping of the above Ratings to Credit Risk Zones follows: Credit Risk Zones Rating Scale Specialized Lending Categorization ΑΑ Α+ Low Α Strong (Category 1) Α- ΒΒ+ ΒΒ Medium ΒΒ- Good (Category 2) Β+ Β Acceptable Satisfactory (Category 3) Β- CC+ Moderate Risk – Watch List - CC CC- High Weak (Category 4) C Default status: With objective trigger events of inability to pay their D obligations In arrears D0 Default Denouncement of Loan Agreement D1 Issuance of a Payment Order D2 There is no one to one mapping between credit risk rating models and special purpose finance models (slotting) and especially as it regards

Watch List rating category, as above presented.

2. RETAIL BANKING CREDIT FACILITIES

Retail banking involves the lending facilities offered by the Group and fall under one of the following categories:

•

Housing loans/Mortgages

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•

Consumer Loans and Credit Cards

•

Small businesses (SB): Entrepreneurs with credit limit up to Euro 1 million and Personal Companies and Legal entities with turnover

up to Euro 5 million and credit limit up to Euro 1 million.

2.1 Credit Risk Approval Process

The Group has developed and implements a credit policy framework (taking into account the legislative and supervisory /regulatory

framework) on which the Group’s Retail Banking lending procedures are based on. Additionally, it has developed and put into effect a system

of key principles, processes and internal operating rules that are govern its lending activities and ensure the smooth and safe management

of the risk undertaken.

The main principles and rules that are applicable for the operations of Retail Banking lending are the following:

•

Sound lending management.

•

Prudent customer selection based on specific credit criteria

•

Correlation of risks and returns and development of a pricing policy, loans’ coverage with collaterals taking into account the credit risk

•

Monitoring and management of the Total Credit Risk, which refers to the aggregate amount of all revolving limits of the obligor, the

balances of one off lending facilities and specifically for small businesses the total balance of the approved lending facilities provided

to the companies’ stakeholders. Additionally, lending facilities for which the customer is guarantor or co-debtor are also considered.

Individuals: The credit approval process for individuals (persons with income from salaries, pensions or other sources of income not related

with business activities) is performed based on the classification of borrowers into risk groups, which represent a specific level of undertaken

risk. The level of risk undertaken by the Group is adjusted, when deemed necessary, according to its credit policy.

Small Businesses: The creditworthiness of Small Businesses fall under the responsibility of the Retail Banking is heavily related to the

creditworthiness of the company’s stakeholders/managers of the company and vice versa. Therefore, the evaluation of the applications in

this category is based on two dimensions:

•

The valuation of the creditworthiness of company’s stakeholders or business managers and the guarantors.

•

The valuation of the creditworthiness of the company.

2.2 Internal models

The fundamental parameter in measuring the credit risk of Retail Banking is the credit risk models developed and utilized throughout the

credit risk cycle, both for the Bank and the Group companies. The abovementioned models segment the population into homogeneous risk

groups (pools) and are categorized into:

•

Behavior Models, which assess the client’s behavior and predict the probability of default within the following months.

•

Application Credit Scoring Models. These models assess application data, mainly demographic and predict the probability of default

within the following months.

These models and the estimations for the probability of default that derive from them play a significant role in risk management and

decision-making process throughout the Group’s operations. The areas that these models are used are the following:

•

Decision-making process for granting /renewal of credit limit.

•

Impairment assessment.

•

Forecasting the future behavior of clients that belong in pool with similar characteristics.

•

The timely identification of potential troubled credit facilities and the prompt plan of required actions for the minimization of the

expected loss for the Group.

•

The assessment of the Group’s loan portfolio quality and the credit risk undertaken.

The parameters considered vary, according to the model’s type and product category that it assesses. Indicatively, some factors are:

•

Personal / demographic data, like the customer’s age, profession, marital status, or current address.

•

Loan characteristics, like the product applied for, loan term in the portfolio, the purpose of financing.

•

Behavioral data of loan during a recent period, like payments during the most recent period, maximum delinquency, outstanding loan

balance versus loan limit and the transaction type.

•

Qualitative data, like the activity sector and the company type.

Models are validated and updated on an annual basis and are subject to constant quality control, to ensure their predictive ability at any

point in time.

Furthermore, on a regular basis the Group conducts exercises simulating crisis situations (Stress Tests), which explore the potential impact

on the financial results of the Group due to unfavorable developments both in obligors’ transactional behavior, as well as in the broader

financial economic environment.

For presentation purposes of the table “Loans by credit quality and IFRS 9 Stage” for Retail Banking Loans the classification in “Strong”,

“Satisfactory” and “Watchlist” categories, is generally based on the twelve-month Probability of Default, weighted by the three IFRS9 macro

scenarios, as well as the Staging criteria and EBA status. Specifically, for Alpha Bank Greece, the range of probabilities that determines this

classification, was derived from an analysis aiming at optimizing the discriminatory power between categories. Therefore, ranges might differ

per portfolio and per subsidiary. For the Bank, the range of probability of default which defines the classification of a loan is presented in the

table below:

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Range of probability of default Rating Classification Mortgages Consumer Credit cards Small Businesses Strong up to 5% up to 5% up to 3% up to 5% Satisfactory from 5% up to 13% from 5% up to 13% from 3% up to 13% from 5% up to 13% Watchlist over 13% over 13% over 13% over 13% CREDIT CONTROL

According to risk management and control framework, there are three “lines of defense” with distinctive roles and responsibilities, with

Business and Operations Units being the first “line of defense”, Risk Management Units the second “line of defense” and the Internal Audit

Unit the third “line of defense”.

In the context of the operation of the second “line of defense” and within the single context of operations set out for the sectors of Retail

Banking, Wholesale Banking and Wealth Management, the Group carries out credit controls in order to optimize Credit Risk management, to

confirm the quality of the loan portfolio and ensure that the first “line of defense” operates within the framework set out for effective Credit

Risk management.

The operation of the second “line of defense” is independent and aims, among else, to:

•

Design and develop procedures and controls for credit risk management.

•

Monitor the adequacy and effectiveness of existing credit risk management procedures.

•

Highlight critical issues that occur and possible deviations from the Group’s Manuals and Policies.

•

Provide guidelines and instructions concerning the credit risk management and control procedures.

•

Provide information to Units of interest about the findings of the controls and possible recommendations made. At the same time,

depending on the scope of the controls, a summary of the findings and recommendations is sent to the Units of the Group that

participate in the procedure and to the General Management (to the competent Chief).

Risk Models and Data Validation

The Group, recognizing the inherent risk in credit risk models due to their complexity and their high degree of dependence on parameters

estimated from other models, has established a Model Risk Management Framework which includes the principles of the Model Development

Policy and the Model Validation Framework. In particular, the independent Business Area Risk Models and Data Validation , on the basis of

specific procedures, shall validate all models used for the purposes of calculating expected credit loss.

The role of Risk Models and Data Validation Business Area, in the context of the Model Risk Management Framework (MRM Framework),

includes responsibilities related to the monitoring of the performance of the models developed by the competent Business Area (Credit Risk

and Enterprise Risk Modelling). The primary task of the Risk Models and Data Validation Business Area is the independent validation of the

reliability of the models, their appropriateness, as well as the compliance with the regulatory guidelines. Risk Models and Data Validation

Business Area responsibility is to develop procedures for the evaluation of models’ performance, on a periodic basis.

The frequency and the extent of the validation process is determined from the significance of the models, that takes into account among other

criteria, the size and the complexity of the portfolio. The associated level of inherent model risk is determined from the methodology for the

grading of significance of the models (Model Tiering) which subsequently determines the frequency, the extent and the intensity of the

validation.

In addition, the Risk Models and Data Validation Business Area audits, as a second “line of defense”, the effectiveness of the design of the data

governance framework in accordance with supervisory guidelines and procedures. It performs assessments of the operational effectiveness of

the risk data collection processes as well as monitoring the accurate and timely implementation of reports, through regular or ad hoc controls.

Furthermore, it defines indicators for monitoring and performance of data quality by developing an action plan for their resolution, in

cooperation with the relevant Business Areas

CREDIT RISK MITIGATION

Collaterals

Collaterals are received in order to mitigate credit risk that may arise from the obligor’s inability to fulfill his contractual obligations, either at the

loan origination date, or during the loan life, either by consensus or after forced executions, auctions, etc.

Collaterals include all kind of assets and rights which are made available to the Group either by their debtors or by third parties, in order to be

used as complementary repayment sources of respective receivable. In any case, the necessary legal audit of the collaterals provided is carried

out, in order to ensure their validity, as well as the possibility of being liquidated or to come into the possession of the Group.

Collaterals are classified into two broad categories: a) Intangible and b) Tangible collaterals.

a) The main type of intangible collateral used in lending is the Guarantee. A guarantee constitutes the legal relationship between the

guarantor and the lender (Bank), through which the guarantor assumes the responsibility that the debt will be paid. The guarantor can be an

individual or a legal entity and the guarantee can be provided for future or conditional debt. It is noted that the intangible collaterals include

the guarantees of the Greek State which in case that are integral part of the loan, are taken into account in the calculation of expected credit

losses, compared to other intangible collaterals that are not taken into account in the calculation of expected loss.

b) Tangible collaterals are distinguished between mortgages and prenotation on mortgages which are registered on real estate properties and

pledges over movable assets (e.g., commodities, checks, bills of exchange) or on claims and rights. For better assurance of the credit facilities

granted, mortgaged and, where applicable, pledged collaterals assets are covered by an insurance contract, with assignment of the relevant

insurance contract to the Bank.

Mortgages are registered on real estate properties which can be liquidated and more specifically on: Residential Real Estate, Commercial Real

Estate, Industrial Buildings, Land, Mines, Ships or aircraft and engines, whether or not movable, Machinery or other facilities (if they are either

essential components of immovable property or any annexes thereto).

According to the Group’s Credit Policy, the existence and the valuation of collaterals are closely monitored. During the valuation, in addition to

the characteristics of the property, the property’s exposure to climate risks is taken into account, such as risk of fire, flood or drought, as well

as any burdensome characteristics that may affect its value. The property valuations are performed on an annual basis for all real estate types,

except for those cases where something different is foreseen contractually, in cases of known changes on the property or in the business

course, or in case there are urban planning changes or any other considerable factors. In addition to the review of collateral values, the Group

also validates such collateral values on an annual basis.

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The initial valuations of a real estate property, provided as collateral, are carried out through an on-site visit of the appraiser and internal

inspection. The revaluations of real estate properties, which collateralize performing exposures, are mainly carried out through:

•

The Bank of Greece’s residential property price index for exposures up to Euro 3 million, for residential properties.

•

Authorized appraisers, after their visit to the residential property used as collateral or via desktop valuation, if the amount of

exposure exceeds Euro 3 million.

•

The Bank of Greece’s commercial property price index (for the perimeter of the collaterals available) or the CRE price index that has

been developed by Alpha Real Estate Services for other categories of commercial properties, used as collateral, on performing

exposures of amount up to Euro 1 million.

•

Authorized appraisers, after their visit to the commercial property used as collateral or via desktop appraisal, if the exposure exceeds

Euro 1 million.

The revaluations for properties used as collateral for non-performing exposures, are mainly carried out through:

•

The Bank of Greece’s residential property price index, for residential properties linked to at least one non-performing exposure but

the total amount of linked exposures does not exceed Euro 300 thousand.

•

The Bank of Greece’s commercial property price index (for the perimeter of the collaterals available) or the CRE price index that has

been developed by Alpha Real Estate Services for other categories of commercial property, used as collateral, linked to at least one

non-performing exposure but the total amount of linked exposures does not exceed Euro 300 thousand.

•

Authorized engineers of Alpha Real Estate Services after their visit to the property used as collateral, if the borrower is cooperative,

or by desktop valuation if the borrower is not cooperative and provided that either the property is collateral linked to at least one

non-performing exposure and the total amount of linked exposures exceeds of Euro 300 thousand or in the cases where the indices

are not appropriate for the type of the property under revaluation.

Mortgaged properties must be secured throughout the duration of the loan, at the expense of the debtor and with insurance policy terms

approved by the Group, against fire, earthquake and flood risks.

The Group in the context of the credit control process performs on a regular basis and through proper sampling, audits over the procedures of

implementation of the Group Loan Collateral Policy as well as back-testing for the verification of property valuations. Audits relate to

valuations based either on indices or on individual valuations, in order to confirm that the proper depiction of property values in Group’s

systems in accordance with the values indicated in the relevant approvals of the competent Committees.

Pledge is the property right on movable assets, rights, claims and securities that gives the pledged lender the privilege to be satisfied with

priority by the sale or liquidation thereof. Pledges can be registered on movable assets, securities, rights or claims that have not been excluded

or disallowed from transactions and can be liquidated including raw materials, products or commodities, machinery (movable), bill of lading,

bill of exchange, cheques, securities, deposit and any type of claim that can be pledged. The frequency of the valuation varies according to the

right or asset on which the pledge may be registered, up to a maximum of one year.

Acceptable Value

During the approval process, the Group calculates the value of the collaterals received based on the potential proceeds that could arise from

liquidation. This estimation is referred to as the acceptable value of the assets provided as collaterals for loans and for its determination the

quality of the assets as well as their market value are considered. In this way, the rates for acceptable values are determined for each type of

collateral, which are expressed as a percentage of their market value, nominal or weighted value, depending on the type of the collateral.

CREDIT RISK EARLY WARNING SYSTEM

In the context of optimal management of lending and the timely identification of non-performing loans, the Group has developed and

implements a Credit Risk Early Warning System, which is defined as the aggregation of actions, processes and reports required to ensure the

early identification of events, at borrower (corporate and individuals) and portfolio level, which may deviate from the Bank's Credit Risk

Appetite or may lead to an increase in exposures with overdue debts or an increase in exposures with significant increase in credit risk.

The Group’s Credit Risk Early Warning System consists of the following stages:

•

Identification of early warning triggers

•

Actions (timely and appropriate action taken)

•

Monitoring the effectiveness of the procedure

•

Quality control of the procedure’s implementation

The perimeter to which the Credit Risk Early Warning System is implemented at account level encompasses all performing exposures, as well

as exposures up to 10 days-past-due for Retail Banking (beyond 11 days-past-due assignments for management) and up to 30 days past due

for the Wholesale Banking portfolio which have not been forborne (PLs).

Additionally, to the early identification and management of borrowers or loan portfolio segments with signals of deterioration, the Group also

monitors through the Early Warning System the loan portfolio, regardless of days past due, to ensure that the evolution and performance of

the lending portfolio are in accordance with the Bank’s and Group’s Credit Risk Appetite.

The Group has also incorporated events related to the deterioration of the prospects of the borrower's sector of activity, natural disasters and

Operating Risk, which relates to the normal business activity of the borrower.

CLIMATE-RELATED, ENVIRONMENTAL - SOCIAL AND GOVERNANCE (ESG) RISKS

The Group, 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, 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. Leveraging on the work already performed in previous years the

Bank has proceeded with targeted enhancements during 2024 in accordance Group’s ESG plan commitments. More specifically, the following

activities have been performed:

•

The Group 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 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 Bank has updated its Risk Inventory that it maintains and evaluates (ICAAP Report) to provide a comprehensive overview of

enhancements and progress achieved in climate and environmental-related risks in the Bank's Risk Registry.

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•

The Group has enhanced its materiality assessment of climate and ESG risks incorporating time horizons (short/ 2025-medium/2030-

long time/2050) and identifying the sectors that are most vulnerable to climate and environmental related risks. In addition, with

respect to nature-related factors, the Bank has examined the “inside-out” and “outside-in” impact by utilizing the UNEP FI and

ENCORE tool. 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. In the context of the materiality

assessment for each risk category, the following is noted:

a. Climate related risks:

• Credit risk:

o Transition risk : considered to be materially affected, both in the Non-Financial Corporate (NFC) portfolio and the Retail

portfolio secured by Real Estate in the medium and long-term horizons.

o Physical risk : It is, also, considered to be materially affected in the medium and long-term horizons, leveraging on the

vulnerability assessment outcome per sector and region.

• Operational risk: seems to be materially affected by transition and physical risks in the medium and long-term horizons as

examined in terms of the Bank’s Own used Real Estate Properties.

o As regards legal risk, and in particular greenwashing risk, also appears to be materially influenced by C&E risks over

medium and long-term horizons, taking into account: (i) the HDB Guideline on Green Mortgage Loans and the HDB report

'Greenwashing monitoring and supervision' as well as the related HDB report on green loans and mortgages; (ii) the

limited current number of exposures and the expected increased exposures in the future and (iii) the scenario related

to Greenwashing risk: "Fine imposed to the Bank due to Greenwashing".

• Market/Liquidity risk: currently assessed as immaterial to both transition and physical risks across time horizons.

• Reputational risk: materially affected by C&E risks in the medium and long-term time horizons. The assessment has taken into

consideration potential consequences in the reputation of the institution due to either Greenwashing Risk, or the risk associated

with clients with a delayed response to transition risk.

• Business & Strategic risk:

• Transition risk: considered to be materially affected by transition risk over the medium- and long-term horizons. The

assessment examines the Gross Interest and Fees & Commissions Income of the Bank’s performing portfolio within the

ESG Sensitive Perimeter, following the same approach as credit risk.

• Physical risk: considered to be materially affected by physical risks over the medium and long-term horizons.

b. Nature related risks:

•

Credit risk: materially affected by nature-related risks (and more specifically by biodiversity) over long-term horizon.

•

Operational risk: materially affected by nature-related factors in the medium- and long-term horizons.

•

Market/ Liquidity risk: immaterially affected by nature-related risks across time horizons.

•

Reputational risk: materially affected by nature-related factors in the medium and long-term horizon.

•

Business & Strategic risk: materially affected by nature-related risks (and more specifically by biodiversity) over long-term horizon.

c. Social related risks:

•

Credit risk: no material risks arise from the downstream portfolio due to the processes and controls applied by the institution,

despite the fact that certain part of the NFC portfolio impacts social factors.

•

Operational risk: considered material in the short-medium and long-term. Specifically, the social topics considered as material are (a)

for own workforce: the training & skills development, and (b) for consumers and end users: privacy, access to (quality) information

and responsible marketing practices.

d. Governance risks:

The governance of corruption and bribery is considered significant in the short, medium, and long term.

More information on ESG Materiality assessment is presented in the CSRD Report 2024.

•

The Bank has designed and implemented an internal report that includes ESG-related indicators regarding loans and advances. This report

is presented quarterly to the Group Sustainability Committee (GSC) and the Risk Management Committee (RMC), and through the RMC, it

is also presented in the Board of Directors.

•

The Group has incorporated ESG-related factors into its Remuneration Policy, reflecting its commitment to sustainable development and

environmental risk management.

•

The Bank developed and distributed a questionnaire to its employees, to assess the organization's awareness of risk culture.

•

The Bank conducted targeted internal training sessions on ESG Overall Assessment, covering topics such as ESG Obligor Assessment,

transaction assessment, and reputational risk assessment.

•

The Bank has carried out a systemic implementation for the assessment related to the CPRS sector and physical risk assessment. Through

this centralized implementation, both credit assessment and reporting requirements are covered.

Additionally, the Bank has established a greenwashing assessment process for its wholesale loan portfolio to ensure the proper green labeling

of loans.

To address the C&ESG risks, in 2024 the Bank has deployed a comprehensive strategic plan by carrying out the following key actions:

•

Identified, assessed, and prioritized the ESG issues related to its activities that may impact the Group’s operations and or its Stakeholders.

Under this scope, a Double Materiality Analysis (DMA) was performed by leveraging the UNEP FI Principles for Responsible Banking (PRB)

Tool, the RSCA inherent risk assessment and outcome from the Compliance Risk Assessments to identify the material Impacts, Risks and

Opportunities (IROs) and connect these with the relevant European Sustainability Reporting Standards (ESRS) topics, subtopics or sub-

subtopics under Corporate Sustainability Reporting Directive (CSRD).

•

Enhanced the regular monitoring of ESG Key Performance Indicators (KPIs) in order to cover all material C&E risks (transition & physical

for credit risk in NFCs and Collaterals, operational losses due to physical risk, social and governance risks, reputational risk due to ESG

considerations, business & strategic risk through the monitoring of income reliance from sectors sensitive to transition risk).

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•

Developed science-based financed emissions targets for material carbon-intensive sectors covering both lending and investment

portfolios, in alignment with the Paris Agreement on climate change and net zero emissions by 2050.

Moreover, the Group has already incorporated in its Risk Appetite Framework (RAF) a set of quantitative indicators and qualitative

commitments regarding Climate and ESG risks. Specifically:

•

The Group integrated climate risks into its overall risk management framework.

•

In terms of quantitative indicators, the Group has enhanced Climate & Environment indicators designed to cover all material C&E risks

which are included in its Risk and Capital Strategy (RCS). The material indicators have been upgraded to Tier II status, with appropriate

limits set for more effective monitoring and management.

•

Enhanced credit assessment process is in place according to the "Climate related, Environmental, Social and Governance Risk

Management Policy on Group’s Business Lending" incorporating additional dimensions of climate related and governance risks.

•

The Bank expanded its Exclusion List (i.e. the activities that it does not finance) to encompass additional activities with environmental and

social impact, according to the United Nations “Universal Declaration of Human Rights”.

•

The Group has enhanced its due diligence process with respect to the assessment of its Customers’ ESG/climate risk profile, through the

improvement of collection of relevant information.

•

The Group 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.

•

The Bank has developed climate risk-specific methodologies to estimate the impact of transition on credit risk across different time

horizons (short, medium and long term) by making use of leading global macroeconomic and sectoral models. Additional characteristics

such as buildings’ energy efficiency, geographic and counterparty level characteristics are also incorporated in the estimation to further

account for heterogeneity of impacts inherent in climate risks. These are examined as stand-alone climate scenarios and used under both

the Economic and Normative perspective. Where applicable these scenarios are also applied on operational risk and business & strategic

risks considering the relevant risk materiality assessment that has been performed.

•

Furthermore, the Bank has developed climate risk-specific methodologies to estimate the impact of physical risk (chronic and acute risks

– specifically flood and wildfire) on credit risk across different time horizons (short, medium and long term) by making use of leading

global macroeconomic and sectoral models, as well natural catastrophe models for Greece. Additional characteristics such as geographic

and counterparty level characteristics are also incorporated in the estimation to further account for heterogeneity of impacts inherent in

climate risks. These are examined as stand-alone climate scenarios and used under both the Economic and Normative perspective. Where

applicable these scenarios are also applied on operational risk and business & strategic risks considering the relevant risk materiality

assessment that has been performed.

•

In addition, regarding the Climate risk impact, the Bank has expanded its climate risk-specific methodologies to estimate the impact of

climate scenarios on operational risk and business & strategic risks under Normative perspective apart from the impact quantification on

economic perspective estimated in previous year.

•

The regular monitoring of ESG Key Performance Indicators (KPIs) were upgraded to Tier II status with limits set for more effective

monitoring. If any of these limits are breached, the Bank will follow the same escalation process as with all non-C&E KRIs.

In order to assess the impact of climate risk on the calculation of Expected Credit Loss (ECL), 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:

•

Data collections regarding ESG related information of the obligor through the use of the inter-banking ESG platform were ongoing on

2024.

•

Identification of needs for ESG-related data, utilization of the data collected for the borrower's assessment and enrichment with

additional information, where required.

•

Further enhancement and recalibration of the Bank’s ESG scorecards leveraging the data above.

• The models assessing environmental, governance and social risks are validated in line with the updated Group Credit Risk Models

Validation Framework.

•

Identifying enhancements or additions to the current set of models used for risk parameter estimation and prediction, in order to

integrate ESG risks.

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.

ESG Risk Assessment in the context of the Credit Approval Process

The ESG risk assessment is a key tool for the decision-making by the competent Committees. As part of the business lending approval and

monitoring, an ESG assessment is carried out at the obligor, transaction, and overall level.

The ESG assessment at obligor level is based on specific ESG questionnaires completed by the Clients. The type of questionnaire (e.g. sectoral,

cross sectoral, simplified) that the Client is asked to complete depends mainly on the size of the company and its industry sector. The

submitted questionnaire is scored using internal evaluation models. The outcome of the ESG assessment at obligor level may be High, Medium

or Low risk.

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 based on the criteria set out in the Group's Sustainable Finance Framework. Sustainable financings are further distinguished into

aligned or not aligned with the EU Taxonomy. Non-sustainable financings are classified as Low, Medium, or High ESG risk.

The overall ESG assessment is a combination of the ESG assessment at obligor and transaction level and is captured per transaction. When the

activity to be financed does not fall within the Exclusion List, the outcome of the overall ESG assessment may be: Sustainable, Low ESG impact,

Medium ESG impact, Increased ESG impact.

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Furthermore, in the Wholesale Banking portfolio, in the case of events that may result in a significant Reputational Risk to the Bank and its

Group Companies, an assessment of these events is conducted by Reputational Risk Committee, and the outcome is considered by the

competent approval committee.

CREDIT RISK CONCENTRATION MANAGEMENT

Concentration Risk is a specific form of credit risk and arises due to the low degree of diversification between counterparties, or group of

counterparties, sectors, geographic regions, products or collaterals.

The Group monitors on a regular basis concentration risk at sector level and at borrower/group of borrowers level as well, through detailed

reporting which informs senior management and Committees of the Board of Directors.

The Group categorizes the financed companies according to their NACE Rev.2 codes into Industry groups/Sectors, which are rated into risk

zones. The Sectors ranking relative to their credit risk is carried out by an independent and certified company and is based on a predictive

indicator that, focusing on future estimates rather than solely on past data, captures the risks and prospects of each sector. The Group

determines the Credit Risk Appetite per sector and manages the concentration risk by monitoring the evolution of its portfolio.

Additionally, the Group manages concentration risk at borrower/group of borrowers level by setting and monitoring compliance with limits set

both by regulatory guidelines and by internal policies that have been developed taking into account the existing exposure as well as the credit

risk rating of the borrowers.

DEFINITIONS

The following definitions are provided as guidance to the tables that follow:

The Public Sector includes loans to the Central Government, the Local Authorities and the companies controlled and fully or partially owned by

the State (excluding those engaged in commercial activity).

As Past Due Exposures is considered the sum of the principal, interest and charges/commissions that have not been paid at the date it was

due.

A Default event is considered to have occurred, regarding a particular Borrower, when at least one of the following criteria has taken place:

•

Past Due Criterion: The Borrower is past due more than 90 consecutive days on any material amount of the credit obligation(s).

Particularly, for Alpha Bank Greece, exposures at Alpha Leasing and ABC Factors are taken into consideration at the calculation of the

Past Due Criterion.

•

Unlikeliness to Pay (UTP) Criterion: The Group considers that the Borrower is unlikely to pay when assesses as unlikely the

repayment of obligations unless actions such as the liquidation of collaterals are enforced.

Additionally, it is necessary to harmonize the classification of exposures in Default and the classification of exposures according to EBA and

therefore any Forborne non-performing exposure (FNPL) or non-performing exposure (NPL) is considered as an exposure at Default.

For Retail exposures, the above definition of Default is applied at the level of an individual credit facility.

For Wholesale exposures, the definition of Default is applied at the obligor level meaning that when at least one of the above specified criteria

is met, the Obligor is considered as Defaulted. The Past Due Criterion is applied both at facility and at obligor level for exposures classified as

Wholesale, in order to be able to identify exposures for which the Past Due Criterion is satisfied at facility level, but not at obligor level.

An exposure is considered as Non-Performing when at least one of the following criteria apply at the time of the credit risk rating assessment:

•

The exposure is more than 90 days past due (NPL).

•

It is assessed as Unlikely to Pay (UTP).

•

Legal actions have been undertaken by the Bank -Legal (NPL).

•

The exposure is classified as Forborne Non-Performing Exposure (FNPL), as defined in the Implementing Regulation (EU) 2021/451 of

17 December 2020.

When a Wholesale Banking borrower has an exposure that is more than 90 days past due and the amount of this exposure exceeds 20% of

total exposures of the borrower, then all exposures of the borrower are considered as non-performing (Pulling Effect).

An exposure is flagged as ‘Unlikely To Pay’ (UTP) when the Group assesses that the borrower is unlikely to fully meet his credit obligations

without the liquidation of collateral, regardless the existence of any past due amount or the number of days past due, with the exception of

collaterals that are part of the production and trade chain of the borrower (e.g. properties for Real Estate companies, corporate shares for

Holding companies). For the identification of these the following are determined, separately for Wholesale Banking and Retail Banking, a)

events which when occur lead to the transfer of the exposure to Non-Performing status without requiring an assessment by any Committee

(Hard UTP Triggers) and b) triggers which when occur, lead to borrower’s credit assessment by the competent Committee in order to

determine whether borrower’s exposures should be classified as Non-Performing or not (Soft UTP Triggers).

An exposure is considered as Credit Impaired when the criteria specified by the definition of Non-Performing Exposures are met.

An exposure is considered as Default when the criteria specified by the definition of Non-Performing Exposures are met.

It is noted that the Group has decided since 2018 to align the perimeter of exposures recognized as “Non Performing loans”, as “Default

Exposures” and as “IFRS 9 Credit Impaired exposures’.

For credit risk reporting purposes the allowance for expected credit losses of loans measured at amortised cost includes also the fair value

adjustment for the contractual balance of loans which were impaired at their acquisition or origination (POCI) since the Group, from credit risk

perspective, monitors the respective adjustment as part of the expected credit losses. These loans were recognized either in the context of

acquisition of specific loans or companies (i.e. Emporiki Bank and Citibank Greece), or as a result of significant modification of the terms of the

previous loan that led to derecognition. Relevant adjustment has been performed to the carrying amount of the loans before allowance for

expected credit losses.

The collateral value taken into account is the latest market value of the collateral available. In the case of immovable properties, collateral

value is considered the lower between the prenotation amount and the market value. Value of guarantees only includes the amount that

exceeds the value of collaterals. All collateral values are capped at 100% of the outstanding amount of the loan.

EXPECTED CREDIT LOSS ESTIMATION METHODOLOGY

The Group, at each reporting date, recognizes a provision for expected credit losses on loans and advances to customers not measured at fair

value through profit or loss as well as for letters of guarantee, letters of credit and undrawn loan commitments.

The expected credit losses calculation Methodology is common and applicable for both the Wholesale and Retail Banking Portfolios.

Portfolio Classification in Stages based on the Credit Risk (Staging)

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Following an exposure’s initial recognition, exposure is classified into stages based on credit risk. The classification of loans in stages is based

on the changes of the credit quality since initial recognition. Upon initial recognition of an exposure, the Group must determine whether this

exposure is considered as credit impaired (Credit Impaired at Initial Recognition).

The POCI category (Purchased or Originated Credit Impaired, POCI) includes the following:

•

Exposures that at the time of purchase (Purchased) meet the criteria of non-performing exposures.

•

Exposures that the old one is derecognized and a new exposure is recognized and for which the following apply when Originated: if

the exposure was classified as credit impaired (NPE) prior to derecognition, the new exposure will continue to maintain this

classification and it will be classified as POCI.

The calculation for the credit risk of POCI exposures is calculated in lifetime.

For exposures not classified as POCI, the classification in stages is performed as follows:

•

Stage 1 includes performing credit exposures that have no significant increase in credit risk since the initial recognition date. In this

stage, expected credit losses calculated are based on the probability of default within the next twelve months and the assessment is

carried out on a collective basis.

•

Stage 2 includes credit exposures with significant increase in credit risk since the initial recognition but are not non-performing. In

this stage, expected credit losses calculated in lifetime and the assessment is carried out on a collective basis.

•

Stage 3 includes the non-performing / default exposures. In this stage expected credit losses calculated in lifetime and the

assessment is performed on a collective or individual basis.

All possible movements between Stages of credit risk are presented below:

•

An exposure which has been classified in Stage 1 in the previous quarter of reference could be classified either in Stage 1 in the next

reporting quarter, if the credit risk has not deteriorated and the exposure is still performing, or in Stage 2, if the exposure is still

performing but the credit risk has deteriorated, or in Stage 3 if the exposure is non-performing/default.

•

An exposure which has been classified in Stage 2 in previous quarter of reference could be classified either in Stage 1 in the next

reporting quarter, if the exposure is performing and does not meet any criteria of “Significant increase in credit risk” and in particular,

for case of Forborne Performing loans (FPL), if the exit criteria from the 2-years probation period are met or it could also remain in

Stage 2, if the credit risk has not substantially changed, or be transferred to Stage 3, if the exposure is non-performing/default.

•

An exposure which has been classified in Stage 3 in previous quarter could be classified either in Stage 1 in the next reporting quarter,

if the exposure is performing and does not meet any of the criteria of “Significant increase in credit risk”, or transferred in Stage 2, if it

is no longer considered as non-performing but meets one of the criteria of “Significant increase in credit risk”, or remain in Stage 3, if

it is still non-performing/default.

All exposures in default (Stage 3), except from those related to distressed restructuring, in order to be reclassified as non-default, a probation

period of at least 3 months is needed from the time when the conditions leading to default status are not applied. Exposures with distressed

restructuring, regardless of whether the restructuring took place before or after the default, should have a minimum probation period of 12

months from the most recent event of the following:

•

the time of restructuring

•

the time when the exposure has been classified as default

•

the end of the grace period provided by the restructuring terms

The Group does not make use of the exemption provided by the standard for low credit risk exposures.

For classification purposes, for wholesale banking revolving exposures, initial recognition date is the date of the most recent credit assessment

/ credit risk rating reflecting the annual thorough credit risk review.

Furthermore, the classification of the exposures in IFRS9 stages is also affected by the refinancing risk, which is an area of focus during the

credit review and UTP assessment process, either through the obligor rating, the financial difficulty indicator or through the identification of

relevant UTP triggers.

Significant Increase in Credit Risk

For the timely identification of significant increase in credit risk for an Exposure after the initial recognition (SICR) leading to the calculation of

lifetime credit losses of the exposure instead of twelve months credit losses, the risk of default at the reference date is compared to the risk of

default at the initial recognition date for all Performing Exposures, including those with no days past due (Delinquencies).

The assessment to determine whether an exposure shows significant increase in credit risk or not is based on the following:

•

Quantitative Indicators: They refer to the use of quantitative information and specifically to the comparison between the probability

of default (PD) at the reference date and the probability of default at the initial recognition date. The assessment of significant

increase in credit risk is based either on a relative or on an absolute increase of PD between the reporting date and the initial

recognition date. As a result of the annual update of credit risk parameters the relative increase can range between 75% and 200%

depending on the asset class of the loans. The increase in absolute number, when used, can range between 3 and 5 percentage

points depending on the asset class of the loans and acts as a backstop to the relative increase (i.e., just one of the two triggers needs

to be hit in order to trigger stage 2). Additionally, in the case of wholesale exposures, the Credit Risk Rating is taken into account

separately as a criterion for determining the significant increase in credit risk. Finally, the threefold increase in annualized PD as

backstop is ensured. Threshold determination derives based on portfolio level analyses. The assessment of the exposures for

significant increase in credit risk is applied on account level. It is noted that the critical points - both for the absolute increase and for

the relative increase of PD between the reference date and initial recognition - are validated on an annual basis, in order to confirm

their correct application and to confirm that the established criteria have sufficient identified the significant increase in credit risk.

•

Qualitative Indicators: They refer to use of qualitative information which is not necessarily depicted in the probability of default, such

as the assessment of an exposure as performing forborne (“FPL” within 2 years’ probation period according to EBA ITS) or as exposure

with Financial Difficulty or as exposure with Operating Risk (for Wholesale exposures). Additional qualitative indicators for the

Wholesale Banking portfolios and the Retail Banking portfolios are included in Credit Risk Early Warning mechanisms where

according to the assessment performed, an exposure may be considered as significant increase in credit risk or not. Especially for

Specialized Lending portfolios through rating (slotting category) additional qualitative indicators are identified.

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•

Backstop Indicators: In addition to the above, and with a view to addressing cases where there is no evidence of significant credit risk

deterioration based on the quantitative and qualitative indicators, exposures over 30 days past due are considered by definition to

show significant increase in credit risk.

Allowance for expected credit losses estimation

Expected credit losses are calculated either on an individual basis or on a collective basis, taking into account the significance of the exposure

or common risk characteristics and historical behavioral data.

Exposures assessed on individual basis (Individual Assessment): On an individual basis, the Exposures to Companies with the following

characteristics are assessed:

•

Borrowers with at least one Non-Performing Exposure whose Customer overall credit Limit in the Bank exceeds the amount of Euro 2

mil. or

•

Specialized Lending Borrowers regardless the overall credit limit with at least one Non-Performing Exposure or

•

Exposures that do not share common risk characteristics or for which no relevant historical data that enables a collective analysis is

available.

Any remaining wholesale exposures are assessed collectively.

On an individual basis, the exposures of Individual Borrowers are assessed when they are classified as Non-Performing Exposures (NPE), and

they relate to:

•

Consumer Loans: Exposures of Consumer Credit Borrowers with total on balance exposures over € 500 thousand.

•

Mortgage Loans: Accounts of Mortgage Credit Borrowers with on balance exposures over € 2 mil.

Any remaining exposure to Individuals is assessed collectively.

Exposures assessed on collective basis (Collective Assessment): Collective Assessment applies to credit exposures which are not assessed

individually, i.e. exposures classified in Stage 1 and Stage 2 as well as non-performing exposures that do not meet the above criteria for individual

assessment, after having been categorized based on similar credit risk characteristics of the group and the portfolio to which the borrower or the

credit facility is allocated.

For the classification of credit facilities into groups with similar credit risk characteristics ( e.g. Staging according to Credit Risk, Type of Product,

Days Past Due, Time in default, Indication of unlikeliness to pay, Modification of contractual terms for borrowers showing financial difficulty

(Forbearance Measures), Existence of Collateral/ Greek State Guarantee, Credit Risk Rating etc).

The groupings are reviewed on a regular basis to ensure that each group is comprised of homogenous exposures in terms of credit risk. Expected

Credit Loss is calculated on account level.

Calculation of allowance for expected credit losses

Allowance for expected credit losses is reassessed at each financial statement date, reflecting the reassessment of credit risk.

Credit risk parameters

Calculation of Expected Credit Loss is based on the following credit risk parameters which are incorporated in the internal statistical models based

on historical data.

• Probability of Default (PD): It is an estimate of the probability of a borrower to default over a specific time horizon. The Probability of Default

is determined with the assistance of the Credit Risk Models. The Group uses statistical models through regression in order to analyze the

collected data and make estimates of the remaining probability of default over the life of the exposures and how they will evolve over time.

Specifically, based on historical time series of observations, specialized models have been developed per portfolio and portfolio type, which

evaluate separately the twelve-month probability of default (12-month PD models) as well as the probability of default throughout the

lifetime of exposures (Lifetime PD models). The twelve-month default models basically evaluate the behavioural characteristics of the loan

(behavioural models), while the Lifetime models evaluate two types of factors: the endogenous such as the maturity of the loan and the

exogenous ones such as the macroeconomic environment (unemployment, annual percentage change in GDP, change in property prices,

inflation). The final estimate of the probability of default is derived from the combination of the two components (12-month PD & Lifetime

PDs).

•

Exposure at default (EAD): Exposure at Default is an estimate of the amount of the exposure at the time of the default taking into

account: (a) expected changes in the exposure after the reporting date, including principal and interest payments; (b) the expected use of

credit limits and (c) accrued interest. The approved credit limits that have not been fully disbursed represent a potential credit exposure

and are converted into a credit exposure equal to the approved undrawn loan commitments multiplied by a Credit Conversion Factor

(CCF). The Credit Conversion factor of credit exposure is calculated based on statistical models. The maximum period for which credit

losses are calculated is the remaining contractual maturity of a financial instrument unless the Group has the legal right to recall the

financial instrument earlier. Exceptionally, for Credit Cards and loan agreements to individuals, the maximum period is set at three years,

while for revolving loans to Small Businesses, the corresponding maturity is set at five years. Regarding Wholesale Banking loan

agreements, the period is set to one year, given the thorough credit review performed at least once a year. If the residual maturity of the

loan agreements classified in Stage 2 was increased by one year, Expected Credit Losses would increase by € 2 mil. as at 31.12.2024

(31.12.2023: € 4.3 mil.).

The Group uses models for exposure at default that reflect the characteristics of each portfolio.

Loss given default (LGD): Loss given default is an estimate of the loss that will occur if the default occurs at a given time. It is based on the

difference between the contractual cash flows due and those expected to be received, including the liquidation of collaterals, cure rate and

cash recoveries based on historical data.

For unsecured loans, the Estimated Expected loss at the time of the default, takes into account expected recovery rates which vary throughout the

recovery period as well as the cure rate.

Expected recoveries from tangible collaterals are based on the following inputs: the most recent (updated within the year) market value of the

collateral, the time required for the liquidation/sale of the collateral (ranging between 1 to 4 years depending on the legal action status of the

loan), the expected market value at liquidation /sale date based on the evolution of real estate prices within the next 4 years, the expected

recoveries through foreclosure process or sale (as derived from historical data obtained for foreclosures and sales of collateral). The recovery rate

is adjusted at the end to reflect value of preferential claims. Expected cash flows are discounted using the original effective interest rate.

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As part of the annual update, credit risk parameters are reviewed and revised if needed to incorporate the impact of any changes in the

business environment.

Finally, it is noted that the LGD varies based on each macroeconomic scenario since it differentiates the value of collateral, cash recoveries and the

cure rate.

Estimates of expected cash recoveries are adjusted by incorporating macroeconomic indexes (i.e. unemployment, annual percentage change in

GDP, change in real estate prices, inflation) through the development of corresponding statistical models. More specifically, based on historical

time series of observations, specialized models (regression) have been developed per portfolio, which evaluate the expected recoveries combined

with the impact of macroeconomic indicators.

In respect of cure rate estimates, statistical models (regression) per portfolio have been developed based on historical time series of observations

which incorporate the effect of the macroeconomic environment through relevant indicators (indicative unemployment, annual percentage

change in GDP, change in property prices, inflation).

Management overlays:

Sale scenarios: In case the Bank 's business plan includes targets and strategies for recovery through sale, then for the loans and advances to

customers included in the portfolio that may be sold, the recoverable amount is calculated by weighting

(i) the value in case of sale (sale price) and

(ii) the amount expected to be recovered according to the internal methods applied by the Bank for the impairment of non-

performing loans, i.e. based on the individual assessment for exposures exceeding a specified limit and based on the collective

assessment for the rest.

The weighting is based on the probability of sale attributed to each non-performing loan portfolio, assessing the stage of preparation of the

underlying portfolios, the importance of the conditions preceding the realization of the sale as well as the recovery time.

Taking into account developments in sales transactions of portfolios of non-performing loans included in the NPE Business Plan, as described in

note 52 "Assets For Sale", the calculation of expected credit risk losses has been adjusted; incorporating a sale scenario with a probability of

100%, for the following perimeters:

• Portfolio of non-performing business credit loans (Project "Solar" )

• Portfolio of non-performing Cypriot loans (Project ACAC)

• Portfolio of mainly non-performing housing loans with collateral (Project "Gaia I")

• Portfolio of non-performing mainly small and medium-sized enterprises (Project "Gaia II")

• Portfolio of non-performing leasing leases of Alpha Leasing S.A. (transaction "Leasing")

• Other loan portfolios

The adjustments made by the Group concern the incorporation of alternative recovery scenarios in relation to the NPL reduction targets

included in the Group's strategic plan.

Post model adjustments (PMA)

Moreover, Management proceeds, when deemed necessary, to additional adjustments. These adjustments are recognized by the Group

following a detailed examination of the results of the models, market data and/or the Bank's strategy and other risk factors, particularly in

periods of economic uncertainty, which cannot be incorporated into the models.

The Group’s governance framework requires such adjustments to be adequately documented and approved by the Groups’ appropriate

authorization levels.

On a regular basis and at least on each reporting period, the Group examines whether the PMA have a more permanent impact and there is

the necessary historical data in order to incorporate it in in the expected credit losses internal models.

Within 2024 Management reassessed PMAs and determined that for a specific portfolio of the Group’s retail loans with certain characteristics,

a post-model adjustment is required. The PMA was applied to specific retail non-performing exposures amounting to € 462 (31.12.2023: € 687)

for which based on the current circumstances the collection of the outstanding balance (through liquidation or other alternative strategy) is

extremely difficult.

Furthermore, based on the Group’s assessment these specific retail non-performing exposures are more vulnerable to the inflationary

pressures and are at a non-performing status for a long period, which makes their collection even more difficult.

As result of the above assessment, Management has identified that these specific factors that are interrelated with the characteristics of these

retail non-performing exposures and the profile of the underlying borrowers, cannot be captured by the credit risk models and therefore

proceeded with an adjustment in the loss rate applied for this retail sub-portfolio.

In this context the Group has recognised an accumulated PMA as of 31.12.2024 of € 103 versus € 123 as of 31.12.2023.

Incorporation of forward looking information

The Group calculates allowance for expected credit losses based on the weighted probability of three alternative scenarios.

More specifically, the Group produces forecasts for the possible evolution of macroeconomic variables that affect the level of allowance for

expected credit losses of loan portfolios under a baseline and under two alternative macroeconomic scenarios (an upside and a downside one)

and also estimates the cumulative probabilities associated with these scenarios.

The macroeconomic variables affecting the level of expected credit losses are the Gross Domestic product (hereinafter “GDP”), the

unemployment rate, the inflation rate and forward-looking prices of residential and commercial real estates.

The main features of these scenarios can be described as follows:

Baseline Scenario

Amidst a volatile international environment, the Greek economy continued its upward trajectory in the first nine months of 2024, growing by

2.3% on an annual basis, outperforming the respective euro area average. Despite the high level of uncertainty surrounding the economic

outlook, the growth momentum of the Greek economy is expected to continue over the scenario horizon amidst favorable conditions:

•

the investment grade status and the upgrade of Greece's credit rating by Scope Ratings within the investment grade (to BBB),

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•

the achievement of fiscal surpluses which, along with the projected growth path, are expected to further reduce the debt-to-GDP

ratio,

•

the increasing contribution of investment to the growth mix, also as a result of the absorption of the Resilience and Recovery Facility

(RRF) funds,

•

the ongoing recovery in euro area and

•

the expected strong tourism performance.

Economic growth is expected to be supported by private consumption – on the back of rising real disposable income following ongoing

employment gains and de-escalating inflation - and investment supported by the RRF implementation. The unemployment rate is expected to

continue to decline to single-digit levels over the scenario horizon, in line with the projected economic recovery and the anticipated new

investments, which will create new jobs. In 2024, inflation based on the Harmonised Index of Consumer Prices (HICP) averaged 3% compared

to 4.2% in 2023, as a result of the more moderate price increases in food and industrial goods. The baseline scenario foresees a further,

gradual de-escalation of headline inflation to 2.7% in 2025 and convergence towards the European Central Bank's medium-term inflation

target. The upward trend in residential property prices is expected to continue, albeit at a slower pace.

Upside Scenario

In the upside scenario, Greek economy is assumed to record stronger growth rates compared to the baseline scenario, supported by rising

investment and consumption, a stronger performance in tourism, a faster deceleration of the unemployment rate and high growth rates in

residential property prices.

Downside scenario

In the downside scenario, Greek economy is assumed to register weaker growth rates compared to the baseline scenario, reflecting, inter alia,

increased geopolitical uncertainty, weaker-than-expected growth in the European economy and delays in the absorption of RRF funds.

Specifically in Greece, the average of the macroeconomic variables which impact both the Probability of Default and the Loss Given Default in

the estimation of expected credit losses at 31.12.2024 (period 2025-2028) and the comparative period (period 2024-2027) are the following: 31.12.2024 2025-2028 GREECE Downside Scenario Baseline Scenario Upside Scenario Real GDP growth 0.1% 1.9% 3.6% Unemployment rate 11.4% 8.6% 5.8% Inflation 3.4% 2.4% 1.4% RRE prices change (0.4)% 2.5% 5.3% CRE Price Index change 0.1% 1.9% 3.8% 31.12.2023 2024 – 2027 GREECE Downside Scenario Baseline Scenario Upside Scenario Real GDP growth 0.0% 1.8% 3.7% Unemployment rate 10.6% 8.5% 6.4% Inflation 3.4% 2.4% 1.5% RRE prices change (0.1)% 2.7% 5.7% CRE Price Index change 0.3% 1.9% 3.6% In the countries where the Group mainly operates, the year-on-year average of macroeconomic variables for the period 2025-2027 affecting

the expected credit risk loss as at 31.12.2024, is presented in the following tables:

2025 – 2027 CYPRUS Downside Scenario Baseline Scenario Upside Scenario Real GDP growth (% change) 0.4% 3.0% 5.6% Unemployment (% change) 6.5% 4.8% 3.0% Inflation prices (% change) 3.6% 2.0% 0.8% RRE Price Index (% change) 1.5% 3.4% 5.4% CRE Price Index (% change) 0.9% 2.2% 3.4% Respectively, the average of the macroeconomic variables for the period 2024-2026 that impacted the expected credit losses at 31.12.2023 is

presented in the following tables:

2024 – 2026 CYPRUS Downside Scenario Baseline Scenario Upside Scenario Real GDP growth (% change) 1.1% 3.0% 4.8% Unemployment (% change) 7.6% 5.7% 3.9% RRE prices (% change) 1.0% 3.2% 5.6% CRE Price Index (% change) (0.5)% 1.3% 2.9% The production of baseline scenario, supported by a consistent economic description, constitutes the most likely scenario according to the

current economic conditions and the Group’s basic assessment of the course of the economy.

The cumulative probabilities of the macroeconomic scenarios for the Greek economy indicate that the economy performs better or worse than

forecasts of the baseline scenario and the alternative scenarios, i.e. the upside and downside scenario. For each one of the alternative scenarios,

the allowance for expected credit losses is calculated and weighted against the probability of each scenario in order to calculate the weighted

expected credit loss.

The cumulative probability assigned to the baseline scenario remained 60%, while cumulative probability assigned to the downside and upside

scenario remained 20% for each of the scenario.

If the assigned cumulative probability of the downside scenario was weighted at 100%, Expected Credit Losses would increase by € 106. at

31.12.2024 (31.12.2023: € 102).

If the assigned cumulative probability of the upside scenario was weighted at 100%, Expected Credit Losses would decrease by € 72 at

31.12.2024 (31.12.2023: € 88).

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The following table shows in more detail this impact per Stage classification.

(In millions of Euro) Downside Scenario Baseline Scenario Upside Scenario 31.12.2024 31.12.2023 31.12.2024 31.12.2023 31.12.2024 31.12.2023 Retail Exposures 78 89 (4) (5) (62) (74) Stage 1 10 6 (1) (1) (11) (9) Stage 2 46 56 (1) (3) (33) (41) Stage 3 22 27 (2) (1) (18) (24) Wholesale Exposures 28 13 (2) (2) (10) (14) Stage 1 4 3 (1) (1) (4) (4) Stage 2 20 5 (1) (1) (2) (5) Stage 3 4 5 - - (4) (5) Total 106 102 (6) (7) (72) (88)

Undrawn loan commitments

According to IFRS 9, these contracts fall within the scope for expected credit losses recognition.

When estimating the allowance for expected credit losses over the life of an undrawn loan commitment, the Group assesses the expected part

of the loan commitment that will be used throughout its expected life.

Governance

Credit Risk Committee is responsible for approving the Expected Credit Losses as well as the methodologies developed by the Group for

calculating the expected credit loss (ECL Methodology) for loan portfolio.

The Board of Directors approves the Group Loan Impairment Policy through the Risk Management Committee.

FORBEARANCE

The credit tools which are normally used by the Group for managing the liquidity problems that borrowers are facing for repaying their

obligations are the restructuring of debt through the renegotiation of the original terms and conditions of the loan agreement they have

entered into.

The Executive Committee “Act 175/2/29.7.2020 of the Bank of Greece, has determined the supervisory framework for the management of

loans in arrears and non-performing loans, over and above the already applicable requirements of European Regulation 2024/1623 (CRR),

amending Regulation (EU) No 575/2013 as well as European Directive 2024/1619 (CRD), amending Directive (EU) 2013/36, and delegated the

decision authority to the Bank of Greece. Furthermore, in the context of the Commission Implementing Regulation (EU) 2021/451 of 17

December 2020 and the executive technical standards of the European Banking Authority, the Group assumes the resulting regulatory

obligations for forborne exposures.

Forbearance measures are proposed to cooperative and viable borrowers provided that they are assessed as effective and sustainable in the

long term, taking into account both the causes of the financial difficulty and the borrower's ability to repay.

Forbearance measures may be applied either on the basis of a customer’s request or in accordance with the Code of Conduct under

Law 4224/2013, as currently is in force, which is a State initiative under the supervision of the Bank of Greece.

Apart from the forbearance measures applied to existing Retail lending exposures, which are initiated by the Group in accordance with the

directives of the Executive Committee Acts of the Bank of Greece (No. 175/2/29.7.2020) and Arrears Resolution Process (ARP) of the Code of

Conduct under Law 4224/2013 as currently is in force, there are restructuring solutions according to the Legislative Framework.

The existence of more favorable terms for renegotiating and modifying the terms and conditions of the bilateral arrangement between the

Group and the debtor (concession), who is facing or is about to face difficulties in meeting his financial commitments (“financial difficulty”), are

defined with respect to:

•

Respective terms existing and applied to customers with no financial difficulty; and

•

Corresponding terms existing in market for debtors with similar credit risk profile.

Financial Difficulty is defined as the situation where the debtor is unable to comply or is about to face difficulties in servicing his credit

obligations as per the current loan repayment schedule due to the worsening of his financial status.

WRITE-OFFS AND WRITE-DOWNS OF BAD DEBTS

Bad Debt Write-off is defined as the reduction of the gross carrying amount of a financial asset, when there is no reasonable expectation of

recovery. The write-off refers to the accounting write-off of a debt or a portion of it, i.e. the removal of the financial asset or part of it from the

balance sheet, which does not necessarily entail the waiver of the legal right to recover the debt. In the event that the Group decides to waive

its legal right to recover the debt, this is called Debt Forgiveness and this waiver may include either on or off-balance sheet items as well.

Bad Debt Write-down is defined as the definitive reduction of a debt or portion of it, as a result of a legally binding decision or agreement

(court judgment, contractual agreement etc.), which is not further claimable. It is noted that this category encompasses Definitive Write-

Downs which are unconditional and Contingent Write-Downs subject to the achievement by the Customer of a specific performance (usually,

upon the successful implementation of a specific repayment program). In the case of Definitive Write-downs, both the accounting and the

legal reduction (Debt Forgiveness) take place immediately and simultaneously, whereas in the case of Contingent Write-downs, the accounting

reduction takes place when the relevant decision is taken or when the agreement is concluded, while the legal reduction (Debt Forgiveness)

takes place either simultaneously with the relevant decision or at a later (future) time, depending on the type of the condition.

DUE FROM FINANCIAL INSTITUTIONS

Exposure to credit institutions relates to loans. interbank transactions (which include positions in derivatives), reverse repos transactions and

International trade activities. Following the basic rules of designation, monitoring and revision of corporate lending, boundaries are

established by the relevant Credit Committees for the monitoring of credit risk for the overall exposure per credit institution counterparty,

excluding positions related to bonds issued by them. The approved credit limits are monitored on a daily basis. The validity period of the limits

is specified in the approval of the limits in accordance with the counterparty credit institutions rating from international credit rating agencies.

In addition to the regular revisions of counterparty credit institutions limits, interim revisions may be carried out either due to circumstances

associated with the trading activity of the Group or due to markets conditions or problems associated with counterparty credit institutions.

Criteria for an extraordinary review are regularly monitored per counterparty in order to review the relevant limits when such criteria exist.

At each reporting date. a loss allowance for expected credit losses on due from financial institutions is recognized.

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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 Group 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. 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. Also, if the receivable or security falls

within the definition of impaired financial instruments upon initial recognition (Purchased or Originated Credit - Impaired - POCI), an impairment

provision equal to the expected credit losses for its entire life is recognized.

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 Group 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 Group 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.

FINANCIAL ASSETS EXPOSURE TO CREDIT RISK

The maximum credit risk exposure per category of financial asset in which the Group is exposed is depicted in the “Net exposure to credit risk”

column.

31.12.2024 31.12.2023 Exposure Provision for Net Exposure Provision for Net before impairment exposure to before impairment exposure to impairment losses credit risk impairment losses credit risk A. Credit risk exposure relating to balance sheet items Balances with central Banks 2,539 2,539 3,726 3,726 Receivables from credit institutions 2,366 70 2,296 1,642 70 1,572 Loans and advances to customers 39,651 601 39,050 37,071 910 36,161 Derivative financial assets 628 628 727 727 Trading securities 28 28 9 9 Investment securities measured at fair value through other 970 1 969 1,318 1 1,317 comprehensive income Investment securities measured at amortised cost 16,439 19 16,420 14,509 19 14,490 Investment securities measured at fair value through profit or loss 11 1 10 14 14 Held for sale assets - Loan’s portfolio 1,576 959 617 4,186 573 3,613 Total amount of balance sheet items exposed to credit risk (a) 64,208 1,651 62,557 63,202 1,573 61,629 Β. Credit risk exposure relating to off balance sheet items: 10,285 24 10,261 9,573 29 9,544 Total credit risk exposure (a+b) 74,493 1,675 72,818 72,775 1,602 71,173

LOANS AND ADVANCES TO CUSTOMERS

For credit risk disclosure purposes, the allowance for expected credit losses of loans measured at amortised cost includes also the fair value

adjustment for the contractual balance of loans which were impaired at their acquisition or origination (POCI) since the Group, from credit risk

perspective, monitors the respective adjustment as part of the provisions. These loans were recognized either in the context of acquisition of

specific loans or companies (i.e. Emporiki Bank and Citibank’s retail operations in Greece), or as a result of significant modification of the terms

of the previous loan that led to derecognition. Relevant adjustment has also been performed at the carrying amount of loans before allowance

for expected credit losses.

It is noted that the credit risk tables do not include the outstanding balances and allowance for expected credit losses of loans that have been

classified as assets held for sale.

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Loans by credit quality and IFRS 9 Stage

The following tables present past due and not past due loans, measured at amortised cost, per IFRS 9 Stage as well as loans that are measured at fair value through profit or loss, as at 31.12.2024 and

31.12.2023:

31.12.2024 Loans measured at amortised cost Loans measured at fair value Stage 1 Stage 2 Stage 3 POCI Total through profit or loss MORTGAGE Strong credit quality 3,848 3,848 Satisfactory credit quality 359 170 214 743 Watch list (higher risk) 177 1,140 285 1,602 Default 595 99 694 Carrying amount (before allowance for expected credit losses) 4,384 1,310 595 598 6,887 - Allowance for expected credit losses (7) (30) (112) (24) (173) Net Carrying Amount 4,377 1,280 483 574 6,714 - Value of collateral 4,236 1,225 543 552 6,556 CONSUMER Strong credit quality 559 559 Satisfactory credit quality 150 34 71 255 Watch list (higher risk) 4 139 63 206 Default 140 51 191 Carrying amount (before allowance for expected credit losses) 713 173 140 185 1,211 - Allowance for expected credit losses (4) (20) (66) (29) (119) Net Carrying Amount 709 153 74 156 1,092 - Value of collateral 254 41 25 102 422 CREDIT CARDS Strong credit quality 739 739 Satisfactory credit quality 16 41 57 Watch list (higher risk) 32 32 Default 34 1 35 Carrying amount (before allowance for expected credit losses) 755 73 34 1 863 - Allowance for expected credit losses (4) (7) (24) (1) (36) Net Carrying Amount 751 66 10 - 827 - Value of collateral 2 1 3 SMALL BUSINESSES Strong credit quality 899 899 Satisfactory credit quality 20 250 28 298 Watch list (higher risk) 15 338 34 387 Default 218 61 279 Carrying amount (before allowance for expected credit losses) 934 588 218 123 1,863 - Allowance for expected credit losses (3) (37) (77) (37) (154) Net Carrying Amount 931 551 141 86 1,709 - Value of collateral 669 410 142 76 1,297 LARGE CORPORATE Strong credit quality 18,888 30 18,918 127 Satisfactory credit quality 960 504 4 1,468 Watch list (higher risk) 44 144 10 198

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31.12.2024 Loans measured at amortised cost Loans measured at fair value Stage 1 Stage 2 Stage 3 POCI Total through profit or loss Default 60 4 64 Carrying amount (before allowance for expected credit losses) 19,892 678 60 18 20,648 - Allowance for expected credit losses (6) (9) (21) (36) Net Carrying Amount 19,886 669 39 18 20,612 127 Value of collateral 14,383 597 51 14 15,045 126 SME’s Strong credit quality 3,632 3,632 Satisfactory credit quality 2,826 414 2 3,242 Watch list (higher risk) 32 15 47 Default 207 19 226 Carrying amount (before allowance for expected credit losses) 6,490 429 207 21 7,147 - Allowance for expected credit losses (4) (2) (78) (11) (95) Net Carrying Amount 6,486 427 129 10 7,052 Value of collateral 4,234 322 150 14 4,720 PUBLIC SECTOR Strong credit quality 20 20 Satisfactory credit quality 11 11 Watch list (higher risk) Default 1 1 Carrying amount (before allowance for expected credit losses) 31 - 1 - 32 - Allowance for expected credit losses (1) (1) Net Carrying Amount 31 - - - 31 - Value of collateral 17 17 31.12.2023 Loans measured at amortised cost Loans measured at fair value Stage 1 Stage 2 Stage 3 POCI Total through profit or loss MORTGAGE Strong credit quality 3,507 3,507 Satisfactory credit quality 372 311 174 857 Watch list (higher risk) 16 1,657 330 2,003 Default 782 185 967 Carrying amount (before allowance for expected credit losses) 3,895 1,968 782 689 7,334 - Allowance for expected credit losses (3) (58) (148) (47) (256) Net Carrying Amount 3,892 1,910 634 642 7,078 - Value of collateral 3,780 1,819 696 626 6,921 CONSUMER Strong credit quality 437 437 Satisfactory credit quality 132 65 60 257 Watch list (higher risk) 8 180 76 264 Default 212 82 294 Carrying amount (before allowance for expected credit losses) 576 246 212 219 1,253 - Allowance for expected credit losses (3) (26) (90) (38) (158) Net Carrying Amount 573 220 122 181 1,095 -

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31.12.2023 Loans measured at amortised cost Loans measured at fair value Stage 1 Stage 2 Stage 3 POCI Total through profit or loss Value of collateral 179 64 48 116 407 CREDIT CARDS Strong credit quality 719 719 Satisfactory credit quality 67 67 Watch list (higher risk) 36 36 Default 38 2 40 Carrying amount (before allowance for expected credit losses) 719 103 38 2 862 - Allowance for expected credit losses (4) (13) (25) (2) (44) Net Carrying Amount 715 90 13 - 818 - Value of collateral 2 2 4 SMALL BUSINESSES Strong credit quality 755 755 Satisfactory credit quality 63 287 25 375 Watch list (higher risk) 24 411 46 481 Default 425 111 536 Carrying amount (before allowance for expected credit losses) 842 698 425 182 2,147 - Allowance for expected credit losses (3) (33) (142) (59) (237) Net Carrying Amount 839 665 283 123 1,910 - Value of collateral 598 488 268 106 1,460 LARGE CORPORATE Strong credit quality 16,400 1 16,401 358 Satisfactory credit quality 642 159 18 819 15 Watch list (higher risk) 50 258 1 309 Default 93 22 115 Carrying amount (before allowance for expected credit losses) 17,092 418 93 41 17,644 Allowance for expected credit losses (3) (4) (34) (6) (47) Net Carrying Amount 17,089 414 59 35 17,597 373 Value of collateral 13,230 385 64 37 13,716 365 SME’s Strong credit quality 3,046 1 3,047 Satisfactory credit quality 2,965 301 3 3,269 Watch list (higher risk) 27 29 56 Default 247 40 287 Carrying amount (before allowance for expected credit losses) 6,038 331 247 43 6,659 Allowance for expected credit losses (2) (1) (98) (22) (123) Net Carrying Amount 6,036 330 149 21 6,536 Value of collateral 3,852 269 191 22 4,334 PUBLIC SECTOR Strong credit quality 23 23 Satisfactory credit quality 13 13 Watch list (higher risk) 1 1 Default 1 1 Carrying amount (before allowance for expected credit losses) 36 1 1 38 Allowance for expected credit losses (1) (1)

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31.12.2023 Loans measured at amortised cost Loans measured at fair value Stage 1 Stage 2 Stage 3 POCI Total through profit or loss Net Carrying Amount 36 1 37 Value of collateral 20 1 21

Letters of guarantee, letters of credit and undrawn loan commitments by credit quality and IFRS 9 Stage

31.12.2024 Stage 1 Stage 2 Stage 3 POCI Total Letters of guarantee, letters of credit and other guarantees) Strong credit quality 4,551 4,551 Satisfactory credit quality 575 159 734 Watch list (higher risk) 238 10 248 Default 203 203 Carrying amount (before allowance for expected credit losses) 5,364 169 203 - 5,736 Allowance for expected credit losses (1) (21) (22) Net Carrying Amount 5,363 169 182 - 5,714 Value of collateral of impaired letters of guarantee, letters of credit and other guarantees 207 12 29 248 Undrawn loan commitments Strong credit quality 3,955 3,955 Satisfactory credit quality 424 144 3 571 Watch list (higher risk) 5 23 28 Default - Carrying amount (before allowance for expected credit losses) 4,384 167 - 3 4,554 Allowance for expected credit losses (2) (2) Net Carrying Amount 4,382 167 - 3 4,552 Value of collateral of impaired undrawn loan commitments

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31.12.2023 Stage 1 Stage 2 Stage 3 POCI Total Letters of guarantee, letters of credit and other guarantees) Strong credit quality 3,811 3,811 Satisfactory credit quality 706 96 802 Watch list (higher risk) 135 21 156 Default 264 264 Carrying amount (before allowance for expected credit losses) 4,652 117 264 - 5,033 Allowance for expected credit losses (1) (27) (28) Net Carrying Amount 4,651 117 237 - 5,005 Value of collateral of impaired letters of guarantee, letters of credit and other guarantees 35 35 Undrawn loan commitments Strong credit quality 3,983 3,983 Satisfactory credit quality 419 107 3 529 Watch list (higher risk) 5 23 28 Default 1 1 Carrying amount (before allowance for expected credit losses) 4,407 130 1 3 4,541 Allowance for expected credit losses - Net Carrying Amount 4,407 130 1 3 4,541 Value of collateral of impaired undrawn loan commitments -

The value of the collaterals that relates to impaired exposures, amounts to € 1,085 as at 31.12.2024 (31.12.2023: € 1,583).

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Ageing analysis by IFRS 9 Stage and product line of loans

The following tables present the ageing analysis as of 31.12.2024 and 31.12.2023 and the allocation of the net carrying amount of the loans

per loan portfolio and IFRS 9 Stage including the collateral value. 31.12.2024 Loans measured at fair value through Loans measured at amortised cost profit or loss (FVPL) Retail Corporate lending Retail lending lending Total Large Mortgage Consumer SME’s Corporate Stage 1 Stage 2 Stage 3 POCI Total Current 127 127 4,341 1,149 175 503 6,168 1 - 30 days 43 87 15 25 170 31 - 60 days 38 12 12 62 61 - 90 days 36 11 11 58 91 - 180 days 69 14 83 181 - 360 days 67 15 82 > 360 days 246 18 264 Carrying amount (before allowance for expected credit losses) 4,384 1,310 595 598 6,887 Allowance for expected credit losses (7) (30) (112) (24) (173) Net Carrying Amount - 127 - 127 4,377 1,280 483 574 6,714 Value of collaterals 126 126 4,236 1,225 543 552 6,556 31.12.2024 Loans measured at amortised cost Retail lending Consumer Credit cards Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 694 138 37 139 1,008 750 61 3 814 1 - 30 days 19 24 7 9 59 5 7 1 13 31 - 60 days 7 4 2 13 3 3 61 - 90 days 4 3 3 10 2 2 91 - 180 days 17 5 22 4 4 181 - 360 days 18 7 25 5 5 > 360 days 54 20 74 21 1 22 Carrying amount (before allowance for expected credit losses) 713 173 140 185 1,211 755 73 34 1 863 Allowance for expected credit losses (4) (20) (66) (29) (119) (4) (7) (24) (1) (36) Net Carrying Amount 709 153 74 156 1,092 751 66 10 - 827 Value of collaterals 254 41 25 102 422 2 1 3 31.12.2024 Loans measured at amortised cost Retail lending Corporate lending Small Business Large Corporate Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 927 530 53 64 1,574 18,339 549 45 18 18,951 1 - 30 days 7 45 5 4 61 1,553 129 1,682 31 - 60 days 8 3 2 13 - 61 - 90 days 5 3 1 9 10 10 91 - 180 days 18 2 20 - 181 - 360 days 21 2 23 - > 360 days 115 48 163 5 5 Carrying amount (before allowance for expected credit losses) 934 588 218 123 1,863 19,892 678 60 18 20,648 Allowance for expected credit losses (3) (37) (77) (37) (154) (6) (9) (21) (36) Net Carrying Amount 931 551 141 86 1,709 19,886 669 39 18 20,612 Value of collaterals 669 410 142 76 1,297 14,383 597 51 14 15,045

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

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31.12.2024 Loans measured at amortised cost Corporate lending Public Sector SME’s Greece Other countries Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 6,047 384 75 2 6,508 17 17 15 15 1 - 30 days 443 26 5 474 - - 31 - 60 days 13 5 18 - - 61 - 90 days 6 6 - - 91 - 180 days 13 13 - - 181 - 360 days 17 17 - - > 360 days 92 19 111 1 1 - Carrying amount (before allowance 6,490 429 207 21 7,147 17 - 1 - 18 15 - - - 15 for expected credit losses) Allowance for expected credit losses (4) (2) (78) (11) (95) (1) (1) - Net Carrying Amount 6,486 427 129 10 7,052 17 - - - 17 15 - - - 15 Value of collaterals 4,234 322 150 14 4,720 17 17 - 31.12.2023 Loans measured at fair value through Loans measured at amortised cost profit or loss (FVPL) Retail lending Corporate lending Retail lending Large Total Mortgage Consumer SME’s Corporate Stage 1 Stage 2 Stage 3 POCI Total Current 373 373 3,894 1,822 379 592 6,687 1 - 30 days 1 101 20 21 143 31 - 60 days 29 24 8 61 61 - 90 days 16 19 6 41 91 - 180 days (1) 65 11 75 181 - 360 days 1 58 11 70 > 360 days 217 40 257 Carrying amount (before allowance for expected credit losses) 3,895 1,968 782 689 7,334 Allowance for expected credit losses (3) (58) (148) (47) (256) Net Carrying Amount 373 373 3,892 1,910 634 642 7,079 Value of collaterals 365 365 3,780 1,819 696 626 6,921 31.12.2023 Loans measured at amortised cost Retail lending Consumer Credit cards Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 565 205 64 160 994 717 90 3 810 1 - 30 days 12 29 10 11 62 2 9 1 12 31 - 60 days - 8 6 4 18 3 3 61 - 90 days (1) 4 5 3 11 2 2 91 - 180 days 19 6 25 4 4 181 - 360 days 20 7 27 5 5 > 360 days 88 29 117 25 2 27 Carrying amount (before allowance for expected credit losses) 576 246 212 220 1,254 719 104 38 2 863 Allowance for expected credit losses (3) (26) (90) (38) (158) (4) (13) (25) (2) (44) Net Carrying Amount 573 219 122 180 1,095 715 91 13 - 819 Value of collaterals 179 64 48 116 407 2 2 4

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31.12.2023 Loans measured at amortised cost Retail lending Corporate lending Small Business Large Corporate Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 835 644 159 85 1,723 16.914 418 60 38 17,430 1 - 30 days 7 41 10 4 62 177 177 31 - 60 days 8 9 3 20 - 61 - 90 days 5 6 2 13 20 20 91 - 180 days 20 4 24 - 181 - 360 days 29 4 33 - > 360 days 192 80 272 13 2 15 Carrying amount (before allowance for expected credit losses) 842 698 425 182 2,147 17,091 418 93 40 17,642 Allowance for expected credit losses (3) (33) (142) (59) (237) (2) (4) (34) (6) (47) Net Carrying Amount 839 665 282 124 1,910 17,089 414 59 34 17,595 Value of collaterals 598 488 268 106 1,460 13,230 386 64 37 13,717 31.12.2023 Loans measured at amortised cost Corporate lending Public Sector SME’s Greece Other countries Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 5,866 291 74 9 6,240 20 1 21 15 15 1 - 30 days 172 17 9 198 - - 31 - 60 days 19 1 3 23 - - 61 - 90 days 4 1 5 - - 91 - 180 days 9 6 15 - - 181 - 360 days 18 18 - - > 360 days 136 26 162 1 1 - Carrying amount (before allowance 6,038 331 248 44 6,661 20 1 1 - 22 15 - - - 15 for expected credit losses) Allowance for expected credit losses (2) (1) (99) (22) (124) (1) (1) - Net Carrying Amount 6,036 330 149 22 6,537 20 1 - - 21 15 - - - 15 Value of collaterals 3,852 269 191 22 4,334 20 1 21 -

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

353 | ANNUAL FINANCIAL REPORT

Reconciliation of loans by IFRS 9 Stage

The following tables present the movement of the loans measured at amortised cost by IFRS 9 Stage for the years 2024 and 2023: 31.12.2024 Retail lending Corporate lending and public sector Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 6,032 3,016 1,457 1,092 11,597 23,166 750 341 84 24,341 29,198 3,765 1,798 1,176 35,937 Changes for the year 1.1 - 31.12.2024 Transfers to Stage 1 from Stage 2 or 3 1,865 (1,844) (21) - 447 (435) (12) - 2,312 (2,279) (33) - Transfers to Stage 2 from Stage 1 or 3 (1,203) 1,620 (417) - (727) 750 (23) - (1,930) 2,370 (440) - Transfers to Stage 3 from Stage 1 or 2 (118) (430) 548 - (23) (47) 70 - (141) (477) 618 - New loans originated or purchased 993 993 8,114 8,114 9,107 9,107 Derecognition of loans (6) 20 1 15 (805) (10) (815) (811) (10) 20 1 (800) Changes due to modifications that did not result in derecognition (1) 2 (10) (3) (12) 1 (1) (2) (2) 1 (12) (3) (14) Write-offs (2) (97) (29) (128) (21) (10) (31) (2) (118) (39) (159) Repayments, foreign exchange and other movements (765) (172) (57) (6) (1,000) (3,790) (74) (27) (19) (3,910) (4,555) (246) (84) (25) (4,910) Reclassification of loans to “Assets held for sale” (11) (46) (436) (148) (641) 30 174 (58) (16) 130 19 128 (494) (164) (511) Balance 31.12.2024 6,786 2,144 987 907 10,824 26,413 1,107 268 39 27,827 33,199 3,251 1,255 946 38,651 Allowance for expected credit losses (18) (94) (279) (91) (482) (10) (11) (100) (11) (132) (28) (105) (379) (102) (614) Balance of loans 31.12.2024 6,768 2,050 708 816 10,342 26,403 1,096 168 28 27,695 33,171 3,146 876 844 38,037 31.12.2023 Retail lending Corporate lending and public sector Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2023 7,679 3,092 2,182 1,265 14,218 23,069 1,441 272 158 24,940 30,747 4,533 2,454 1,424 39,158 Changes for the year 1.1 - 31.12.2023 Transfers to Stage 1 from Stage 2 or 3 1,511 (1,485) (26) - 691 (680) (11) - 2,203 (2,165) (38) - Transfers to Stage 2 from Stage 1 or 3 (1,744) 2,310 (566) - (718) 726 (8) - (2,462) 3,036 (574) - Transfers to Stage 3 from Stage 1 or 2 (47) (461) 508 - (9) (134) 143 - (56) (595) 651 - New loans originated or purchased 1,009 1 1,010 7,124 6 7,130 8,133 8 8,141 Derecognition of loans (4) (1) (2) - (7) (1,101) (15) (4) (1,120) (1,105) (16) (7) (1,128) Changes due to modifications that did not result in derecognition (8) (1) (20) (5) (34) 1 1 1 3 (8) (19) (5) (32) Write-offs (2) (195) (72) (269) (2) (2) (2) (197) (72) (271) Repayments, foreign exchange and other movements (1,020) (163) (5) 5 (1,183) (4,686) (210) (24) (6) (4,926) (5,705) (373) (29) (2) (6,109) Reclassification of loans to “Assets held for sale” (1,344) (273) (419) (102) (2,138) (1,205) (379) (26) (74) (1,684) (2,549) (652) (443) (177) (3,821) Balance 31.12.2023 6,032 3,016 1,457 1,092 11,597 23,166 750 341 84 24,341 29,198 3,766 1,798 1,176 35,938 Allowance for expected credit losses (13) (130) (405) (146) (694) (5) (5) (133) (28) (171) (18) (135) (538) (174) (865) Balance of loans 31.12.2023 6,019 2,886 1,052 946 10,903 23,161 745 208 56 24,170 29,180 3,631 1,260 1,002 35,073

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

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Reconciliation of allowance for expected credit losses of loans by IFRS 9 Stage

The following tables include the movement of allowance for expected credit losses of loans measured at amortized cost for the years 2024 and 2023:

31.12.2024 Allowance for expected credit losses Retail lending Corporate lending and public sector Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 13 130 406 145 694 5 5 133 28 171 18 135 539 173 865 Changes for the year 1.1. - 31.12.2024 Transfers to Stage 1 from Stage 2 or 3 66 (64) (2) - 3 (3) - 69 (67) (2) - Transfers to Stage 2 from Stage 1 or 3 (5) 69 (64) - 11 (11) - (5) 80 (75) - Transfers to Stage 3 from Stage 1 or 2 (36) 36 - - (36) 36 - Net remeasurement of expected credit losses(a) (56) 4 26 (8) (34) (3) (7) 22 12 (59) (3) 48 (8) (22) Impairment losses on new loans (b) 3 3 3 3 6 6 Change in risk parameters (c) (3) (6) 228 62 281 (1) 3 25 5 32 (4) (3) 253 67 313 Impairment losses on loans (a)+(b)+(c) (56) (2) 254 54 250 (1) (4) 47 5 47 (57) (6) 301 59 297 Derecognition of loans - - - Write offs (2) (97) (29) (128) 6 (21) (10) (25) 6 (2) (118) (39) (153) Foreign exchange and other movements 1 (2) 1 - (3) 4 1 (3) 1 2 1 1 Change in the present value of the impairment losses 3 2 5 2 2 5 2 7 Transfer of allowance for expected credit losses to "Assets held for sale (2) (255) (82) (339) 2 (54) (12) (64) (309) (94) (403) Balance 31.12.2024 18 94 279 91 482 10 11 100 11 132 28 105 379 102 614 During 2024, allowance for expected credit losses have been affected by the following movements :

•

Transfer to Stage 1 of loans amounting € 2 from Stage 2 and Stage 3 due to an improvement in their creditworthiness compared to their initial recognition.

•

The loan impairment losses incorporate the change in post model adjustments between 31.12.2023 and 31.12.2024, which are taken in the context of inflationary pressures, and the general uncertainty

that exists in economic environment, by € (21), from € 123 as at 31.12.2023 to € 102 as at 31.12.2024 mainly due to the reclassification of loan portfolios under “Assets held for sale” amounting to € 34.

It is noted that the loans that were written off within 2024 that are still subject to enforcement activity amount to € 157 (31.12.2023 : € 236).

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31.12.2023 Allowance for expected credit losses Retail lending Corporate lending and public sector Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2023 15 143 578 211 947 16 19 122 29 186 31 162 700 240 1,133 Changes for the year 1.1. - 31.12.2023 Transfers to Stage 1 from Stage 2 or 3 52 (49) (3) - 8 (4) (4) - 60 (53) (7) - Transfers to Stage 2 from Stage 1 or 3 (6) 93 (87) - (2) 4 (2) - (8) 97 (89) - Transfers to Stage 3 from Stage 1 or 2 (41) 41 - (1) 1 - (42) 42 - Net remeasurement of expected credit losses(a) (47) 4 34 (12) (21) (10) 1 21 16 28 (57) 6 55 4 8 Impairment losses on new loans (b) 5 5 9 (1) 8 14 (1) 13 Change in risk parameters (c) (2) (7) 214 65 270 (9) (7) 9 24 17 (11) (15) 223 90 287 Impairment losses on loans (a)+(b)+(c) (44) (3) 248 53 254 (10) (6) 30 39 53 (54) (9) 278 93 308 Derecognition of loans (1) (1) (1) (1) (1) (2) (3) Write offs (2) (195) (72) (269) (2) (2) (2) (197) (72) (271) Foreign exchange and other movements (2) 1 1 - (3) 6 (2) 1 2 (4) 6 1 3 Change in the present value of the impairment losses 1 1 2 1 1 2 2 2 4 Reclassification of allowance for expected credit losses to "Assets held for sale” (2) (12) (177) (48) (239) (3) (13) (11) (42) (69) (6) (24) (188) (91) (309) Balance 31.12.2023 13 130 406 145 694 5 5 133 28 171 18 135 539 173 865 During 2023, allowance for expected credit losses have been affected by the following movements:

•

Transfer to Stage 1 of loans amounting € 2 from Stage 2 and Stage 3 due to an improvement in their creditworthiness compared to their initial recognition.

•

The loan impairment losses incorporate the change in post model adjustments between 31.12.2022 and 31.12.2023, which are taken in the context of inflationary pressures, the increase in the

borrowing costs to households and businesses and the general uncertainty that exists in economic environment, by € (45), from € 168 as at 31.12.2022 (of which € 14 regards Alpha Bank Romania) to €

123 as at 31.12.2023 mainly due to the reclassification of loan portfolios to “Assets held for sale” amounting to € 27 and the classification of Alpha Bank Romania as discontinued operations of € 14.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

356 | ANNUAL FINANCIAL REPORT

Reconciliation of letters of guarantee, letters of credit and undrawn loan commitments by IFRS 9 Stage

The movement for the years 2024 and 2023 of letters of guarantee, letters of credit and undrawn loan commitments is presented in the tables

that follow:

31.12.2024 Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 9,058 247 265 3 9,573 Changes for the year 1.1 - 31.12.2024 Transfers to Stage 1 from Stage 2 or 3 148 (140) (8) - Transfers to Stage 2 from Stage 1 or 3 (254) 261 (7) - Transfers to Stage 3 from Stage 1 or 2 (1) (1) 2 - New letters of guarantee, letters of credit and undrawn loan 2,110 2,110 commitments Foreign exchange, repayments and other movements (1,313) (31) (49) (1,396) Balance 31.12.2024 9,748 336 203 3 10,290 Allowance for expected credit losses (2) (1) (21) (24) Balance 31.12.2024 9,746 335 182 3 10,266 31.12.2023 Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2023 8,902 354 281 1 9,538 Changes for the year 1.1 - 31.12.2023 Transfers to Stage 1 from Stage 2 or 3 173 (168) (5) - Transfers to Stage 2 from Stage 1 or 3 (199) 205 (6) - Transfers to Stage 3 from Stage 1 or 2 (6) (5) 11 - New letters of guarantee, letters of credit and undrawn loan 2,495 2,495 commitments Foreign exchange, repayments and other movements (2,307) (139) (16) 2 (2,460) Balance 31.12.2023 9,058 247 265 3 9,573 Allowance for expected credit losses (1) (1) (27) (29) Balance 31.12.2023 9,057 246 238 3 9,544

Reconciliation of allowance for expected credit losses of letters of guarantee, letters of credit and undrawn loan commitments by IFRS 9

Stage

The Group has recognized allowance for expected credit losses for the undrawn loan commitments, letters of credit and letters of guarantee,

the reconciliation of which is presented in the following tables for the years 2024 and 2023:

31.12.2024 Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 1 1 27 - 29 Changes for the year 1.1 - 31.12.2024 Transfers to Stage 1 from Stage 2 or 3 Transfers to Stage 2 from Stage 1 or 3 1 (1) Transfers to Stage 3 from Stage 1 or 2 Net remeasurement of expected credit losses(a) (1) (1) Impairment losses on new exposures (b) 2 2 Change in risk parameters (c) 1 (1) (6) (6) Impairment losses (a)+(b)+(c) 3 (2) (6) - (5) Foreign exchange and other movements (1) 1 Balance 31.12.2024 3 - 21 - 24 31.12.2023 Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2023 5 3 32 - 41 Changes for the year 1.1 - 31.12.2023 Transfers to Stage 1 from Stage 2 or 3 1 (1) Transfers to Stage 2 from Stage 1 or 3 1 (1) Transfers to Stage 3 from Stage 1 or 2 Net remeasurement of expected credit losses(a) (3) 1 (2) Impairment losses on new exposures (b) 7 7 Change in risk parameters (c) (2) (1) (4) (7) Impairment losses (a)+(b)+(c) 2 (1) (3) - (2) Foreign exchange and other movements (7) (1) (2) (10) Balance 31.12.2023 1 1 27 - 29

Advances to customers

Advances to customers derive mainly from Group’s commercial activity other than lending, including mainly receivables from letters of

guarantee, receivables from credit cards and other receivables from banking activities. The calculation of allowance for expected credit losses

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357 | ANNUAL FINANCIAL REPORT

for the receivables that are exposed to credit risk, is being performed using the simplified approach, taking into account their lifetime (without

being allocated into stages), as provided by IFRS 9.

The expected credit loss rate applied by the Group was determined based on the assessment of expected credit losses taking into account the

time that the aforementioned receivables, which are mainly short-term, remain due.

The following tables present the reconciliation of advances to customers for the years 2024 and 2023:

2024 2023 Balance 1.1 232 266 Repayments, foreign exchange and other movements 97 (34) Balance 31.12 329 232 Allowance for expected credit losses (38) (46) Balance of advances to customers 31.12 291 186 The reconciliation of the allowance for expected credit losses for the years 2024 and 2023 presented in the following tables below: 2024 2023 Balance 1.1 46 41 Impairment losses on advances to customers 2 6 Foreign exchange, write-offs and other movements (10) (1) Balance 31.12 38 46 PLEDGED COLLATERALS

Collaterals are received in order to mitigate credit risk that may arise from the borrower’s inability to fulfill his contractual obligations.

Collaterals include all kind of assets and rights which are made available to the Group either by its borrowers or by third parties, in order to be

used as complementary liquidation sources of the relevant receivables.

The breakdown of collaterals and guarantees received to reduce the credit risk exposure is summarized below:

Breakdown of collaterals and guarantees 31.12.2024 Value of collateral Loans measured at fair value through profit or loss (FVPL) Loans measured at amortised cost Real estate Financial Other Total value Value of Real estate Financial Other Total value Value of collateral collateral collateral of collateral Guarantees collateral collateral collateral of collateral Guarantees Retail lending 7,263 271 744 8,278 846 Corporate lending 11 92 23 126 5,338 2,466 11,961 19,765 2,959 Public sector 17 17 Total 11 92 23 126 - 12,601 2,737 12,722 28,060 3,805 31.12.2023 Value of collateral Loans measured at fair value through profit or loss (FVPL) Loans measured at amortised cost Real estate Financial Other Total value Value of Real estate Financial Other Total value Value of collateral collateral collateral of collateral Guarantees collateral collateral collateral of collateral Guarantees Retail lending 7,829 289 673 8,792 1,029 Corporate lending 64 234 66 365 5,063 1,793 11,194 18,051 2,893 Public sector 21 21 Total 64 234 66 365 - 12,892 2,082 11,888 26,864 3,922 There are no cases of transfer or reassignment of collaterals received from borrowers for which an obligation to return them has been

recognized.

Loan-to-value ratio (LTV)

The loan-to-value ratio of loans reflects the relationship between the loan and the value of the property held as collateral.

The table below presents the mortgage loan portfolio by LTV ratio. Loans measured at amortised cost 31.12.2024 31.12.2023 < 50% 1,351 1,297 50% - 70% 1,484 1,475 71% - 80% 995 975 81% - 90% 961 941 91% - 100% 916 1,159 101% - 120% 422 547 121% - 150% 219 301 > 150% 539 639 Total exposure 6,887 7,334 Simple average of LTV (%) 59% 63%

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

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REPOSSESSED ASSETS

Policy of disposal of repossessed assets

Within 2018 the Group established a uniform management strategy for repossessed assets by setting up two new Committees and assigning to

a group company the management of all the repossessed properties of the Group. In December 2023, the Group updated its corporate

governance framework to reflect the Group’s new organizational structure. Upon transfer of the legal title of properties to the Group, in the

context of the management of non-performing exposures (NPEs), the respective company is in charge of monitoring the repossession

procedures (asset on - boarding), determining the optimal property management strategy and assigning to the appropriate channels, within or

outside the Group, the management of the properties.

Depending on the defined strategy, the property is classified for accounting purposes, in the appropriate category. The classification process is

periodically reviewed so that the classification of each property is updated based on its current status. Finally, there is continuous supervision

and co-ordination of collaborating asset management channels on the implementation of the defined strategies as well as of the asset

commercialization in accordance with the Group’s policy and monitoring of their performance through appropriate Key Performance

Indicators (KPIs).

Repossessed assets 31.12.2024 Balance Disposals during the year Value of collaterals Accumulated Net carrying amount of Of which in Net disposal Net gain/(loss) on repossessed Of which in 2024 impairment collaterals repossessed 2024 value disposal 31.12.2024 31.12.2024 31.12.2024 Real estate collaterals 695 26 (141) (12) 554 124 13 31.12.2023 Balance Disposals during the year Value of collaterals Accumulated Net carrying amount of Of which in Net disposal Net gain/(loss) on repossessed Of which in 2023 impairment collaterals repossessed 2023 value disposal 31.12.2023 31.12.2023 31.12.2023 Real estate collaterals 857 28 (202) (11) 655 320 127 Other collaterals 6 3 5 9 The net carrying amount of the collaterals repossessed as of 31.12.2024, includes an amount of € 50 (31.12.2023: € 149) that relates to

properties that were classified as “Assets held for sale”.

Loans and allowance for expected credit losses by IFRS 9 Stage, industry and geographical region

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31.12.2024 Greece Loans measured at fair value Loans measured at amortised cost through profit or loss Carrying amount Allowance for Net Net amount Stage 1 Stage 2 Stage 3 POCI (before allowance for expected carrying expected credit losses) credit losses amount Construction and real estate 847 305 1 1,153 6 1,147 Wholesale and retail trade 68 19 4 91 5 86 Transportation 235 235 235 Shipping 23 2,977 19 22 3,018 5 3,013 Hotels-Tourism 144 17 161 1 160 Services and other sectors 521 8 529 6 523 Public sector - 15 - - - 15 - 15 Total (B) 23 11,289 466 70 48 11,873 47 11,826 31.12.2023 Greece Loans measured at fair value Loans measured at amortised cost through profit or loss Carrying amount Allowance for Net Net amount Stage 1 Stage 2 Stage 3 POCI (before allowance for expected carrying expected credit losses) credit losses amount A. Greece Retail lending 5,487 2,873 1,361 1,048 10,770 649 10,121 Mortgage 3,420 1,844 699 656 6,619 221 6,399 Consumer 528 231 204 209 1,172 150 1,022 Credit cards 709 103 37 2 852 43 808 Small Businesses 830 695 421 181 2,127 235 1,892 Corporate lending 345 13,525 492 308 62 14,388 143 14,246 Financial institutions and other 203 203 203 financial services Manufacturing 213 5,372 109 104 25 5,610 61 5,549 Construction and real estate 57 1,375 158 32 1 1,566 10 1,556 Wholesale and retail trade 2,381 80 92 21 2,574 42 2,532 Transportation 75 870 8 19 5 901 9 893 Shipping 76 1 77 77 Hotels-Tourism 2,439 93 26 6 2,565 5 2,560 Services and other sectors 809 44 34 4 892 16 876 Public sector 20 1 1 22 1 21 Total (A) 345 19,032 3,366 1,670 1,110 25,180 792 24,388 B. Other Countries Retail lending 545 142 96 44 826 46 781 Mortgage 475 124 83 33 715 35 680 Consumer 48 15 8 10 81 8 73 Credit cards 10 1 10 1 10 Small Businesses 12 3 4 1 20 2 18 Corporate lending 27 9,606 257 32 21 9,916 28 9,888 Financial institutions and other 2 5,491 1 5,493 1 5,491 financial services Manufacturing 177 10 187 1 186 Construction and real estate 582 148 2 732 2 730 Wholesale and retail trade 54 20 75 74 Transportation 212 2 214 2 212 Shipping 25 2,837 58 28 2 2,926 12 2,913 Hotels-Tourism 24 19 3 43 3 43 Services and other sectors 229 1 16 246 7 239 Public sector - 16 - - - 16 - 15 Total (B) 27 10,167 399 127 65 10,758 74 10,684

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

360 | ANNUAL FINANCIAL REPORT

Interest income from loans by loan category and IFRS 9 stage

The following tables present the interest income from loans for the year 2024 and 2023 by IFRS 9 Stage.

For loans classified in Stages 1 and 2, interest income is calculated by applying the effective interest rate to the gross carrying amount of the

loan.

31.12.2024 Loans measured at amortised cost Loans measured at fair value through Stage Total Interest Stage 1 Stage 2 Stage 3 POCI 1 Stage 2 Stage 3 profit or loss (FVPL) Income Retail lending 370 178 60 56 664 Corporate lending 1,211 47 15 6 1,279 25 Public sector 2 2 Total interest income 1,583 225 75 62 1,945 25 31.12.2023 Loans measured at amortised cost Loans measured at fair value through Stage Total Interest Stage 1 Stage 2 Stage 3 POCI 1 Stage 2 Stage 3 profit or loss (FVPL) Income Retail lending 360 176 87 65 688 Corporate lending 1,098 61 18 14 1,191 23 Public sector 1 1 Total interest income 1,459 237 105 79 1,880 23 FORBORNE LOANS

The restructuring of loans is performed through renegotiation of the original contractual terms and include changes such as the extension of

the credit duration, write-off of a portion of borrower’s amounts due, grace period for the principal and/or interest and the decrease in

interest rates. As a rule forbearance measures which are extended include a combination of the above amendments to the contractual terms.

In addition, in the context of renegotiations of the terms of loans granted, the Group has participated in agreements for the exchange of debt

with borrowers’ equity shares. As at 31.12.2024, the Group included in the portfolio measured at fair value through other comprehensive

income shares, with a fair value of € - (31.12.2023: € 9) which were acquired from respective transactions.

Analysis of forborne loans by type of forbearance measure 31.12.2024 31.12.2023 Loans measured at fair Loans measured at Loans measured Loans measured at value through profit or Total fair value through Total at amortised cost amortised cost loss (FVPL) profit or loss (FVPL) Interest only payment 52 52 44 44 Reduced payments scheme 213 213 291 291 Grace period 2 2 4 4 Loan term extension 1,475 1,475 1,982 1,982 Arrears capitalization 273 273 785 785 Partial write-off in borrower’s 205 205 301 301 obligations Other 19 19 33 33 Total net carrying amount - 2,239 2,239 - 3,440 3,440 Forborne loans by product line

31.12.2024 31.12.2023 Loans measured at fair Loans measured at Loans measured Loans measured at value through profit or Total fair value through Total at amortised cost amortised cost loss (FVPL) profit or loss (FVPL) Retail lending - 1,968 1,968 3,023 3,023 Mortgage 1,447 1,447 2,147 2,147 Consumer 206 206 311 311 Credit cards 1 1 2 2 Small Businesses 314 314 563 563 Corporate lending - 271 271 - 417 417 Large corporate 177 177 291 291 SME's 94 94 126 126 Public sector - - - - - - Greece - - Total net carrying amount - 2,239 2,239 - 3,440 3,440

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Forborne loans by geographical region

31.12.2024 31.12.2023 Loans measured at fair Loans measured at Loans measured Loans measured at value through profit or Total fair value through Total at amortised cost amortised cost loss (FVPL) profit or loss (FVPL) Greece 2,032 2,032 3,138 3,138 Other Countries 207 207 302 302 Total net carrying amount - 2,239 2,239 - 3,440 3,440 Forborne loans according to their credit quality

31.12.2024 3.12.2023 Total amount Percentage of Total amount Percentage of Total amount of Total amount of Forborne Forborne Loans of Forborne Forborne Loans of Loans Loans (%) Loans Loans (%) Loans measured at fair value through profit or loss (FVPL) Past due Not past due 127 373 Total net carrying amount 127 - 373 - - Value of collaterals 126 365 Loans measured at amortised cost Stage 1 33,199 29,198 Stage 2 3,251 1,435 44% 3,765 2,029 54% Stage 3 1,255 615 49% 1,798 1,171 65% Purchased or originated credit impaired (POCI) 945 438 46% 1,176 709 60% Carrying amount (before allowance for expected credit losses) 38,651 2,488 6% 35,937 3,909 11% Stage 1 - Allowance for expected credit losses 28 18 % Stage 2 - Allowance for expected credit losses 105 53 50% 135 82 61% Stage 3 - Allowance for expected credit losses 379 144 38% 538 284 53% Allowance for expected credit losses for purchased or 102 52 51% 174 103 60% originated credit impaired loans (POCI) Total net carrying amount 38,037 2,239 6% 35,072 3,440 10% Value of collaterals 28,060 2,033 7% 26,863 3,110 12%

Reconciliation of the net value of forborne loans

2024 2023 Loans measured at Loans measured at fair Loans Loans measured fair value through Total value through profit or measured at Total at amortised cost profit or loss (FVPL) loss (FVPL) amortised cost Balance 1.1 - 3,440 3,440 2 4,015 4,017 Changes for the year 1.1 - 31.12 Forbearance measures during the year 243 243 623 623 Interest income 233 233 239 239 Repayment of loans (partial or total) (244) (244) (2) (301) (303) Loans that exited forbearance status during the (971) (971) (682) (682) year Impairment losses (202) (202) (212) (212) Remeasurment of fair value Reclassification of loans to "Assets held for sale" (268) (268) (286) (286) Other movements 8 8 44 44 Balance 31.12 - 2,239 2,239 - 3,440 3,440

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 31.12.2024 and 31.12.2023 by IFRS 9 Stage and credit rating:

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31.12.2024 Stage 1 Stage 2 Stage 3 POCI Total Balances with central Banks AAA 800 800 AA+ to AA- A+ to A- BBB+ to BBB- 1,227 1,227 Lower than BBB- 512 512 Unrated - Carrying amount (before allowance for expected credit losses) 2,539 - - - 2,539 Allowance for expected credit losses - Net carrying amount 2,539 - - - 2,539 Value of collaterals Due from financial institutions AAA AA+ to AA- 435 435 A+ to A- 1,783 1,783 BBB+ to BBB- 30 30 Lower than BBB- 23 23 Unrated 25 70 95 Carrying amount (before allowance for expected credit losses) 2,296 - 70 - 2,366 Allowance for expected credit losses (70) (70) Net carrying amount 2,296 - - - 2,296 Value of collaterals Securities measured at fair value through other comprehensive income AAA 69 69 AA+ to AA- 94 94 A+ to A- 5 5 BBB+ to BBB- 19 19 Lower than BBB- 778 778 Unrated 4 4 Carrying amount (before allowance for expected credit losses) 969 - - - 969 Allowance for expected credit losses - - Net carrying amount 969 - - - 969 Value of collaterals Securities measured at amortized cost AAA 1,689 1,689 AA+ to AA- 366 366 A+ to A- 1,613 1,613 BBB+ to BBB- 4,290 4,290 Lower than BBB- 8,265 7 8,272 Unrated 209 209 Carrying amount (before allowance for expected credit losses) 16,432 - 7 - 16,439 Allowance for expected credit losses (14) (5) (19) Net carrying amount 16,418 - 2 - 16,420 Value of collaterals 31.12.2023 Stage 1 Stage 2 Stage 3 POCI Total Balances with central Banks AAA AA+ to AA- A+ to A- BBB+ to BBB- 1,297 1,297 Lower than BBB- 2,429 2,429 Unrated Carrying amount (before allowance for expected credit losses) 3,727 - - - 3,727 Allowance for expected credit losses Net carrying amount 3,727 - - - 3,727 Value of collaterals Due from financial institutions AAA AA+ to AA- 171 171 A+ to A- 1,218 1,218 BBB+ to BBB- 129 129 Lower than BBB- 12 12

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Unrated 42 70 112 Carrying amount (before allowance for expected credit losses) 1,572 - 70 - 1,642 Allowance for expected credit losses (70) (70) Net carrying amount 1,572 - - - 1,572 Value of collaterals Securities measured at fair value through other comprehensive income AAA 103 103 AA+ to AA- 49 49 A+ to A- - BBB+ to BBB- - Lower than BBB- 1,154 1,154 Unrated 12 12 Carrying amount (before allowance for expected credit losses) 1,318 - - - 1,318 Allowance for expected credit losses (1) (1) Net carrying amount 1,317 - - - 1,317 Value of collaterals Securities measured at amortized cost AAA 1,155 1,155 AA+ to AA- 442 442 A+ to A- 1,021 1,021 BBB+ to BBB- 3,808 3,808 Lower than BBB- 7,842 6 7,848 Unrated 236 256 Carrying amount (before allowance for expected credit losses) 14,504 - 6 - 14,510 Allowance for expected credit losses (15) (4) (19) Net carrying amount 14,488 - 2 - 14,490 Value of collaterals

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Trading portfolio - Derivative financial assets - Securities measured at fair value through profit or loss

The following table presents the other financial instruments measured through profit or loss per credit rating. 2024 2023 Trading securities AA+ to AA- 7 A+ to A- 3 5 Lower than BBB- 19 4 Net carrying amount 29 9 Value of collaterals Derivative financial assets AA+ to AA- 62 84 A+ to A- 364 468 BBB+ to BBB- 14 7 Lower than BBB- 184 167 Unrated 4 1 Net carrying amount 628 727 Value of collaterals Securities measured at fair value through profit or loss Lower than BBB- 10 Unrated 14 Net carrying amount 10 14 Value of collaterals - ANALYSIS OF FINANCIAL ASSETS PER IFRS 9 STAGE

Investment Securities

i. Investment Securities measured at fair value through other comprehensive income

with fair value € 40 (31.12.2023: € 52).

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ii. Investment securities measured at amortized cost

The following table depicts the classification of securities per IFRS 9 stage and issuer’s category as of 31.12.2024 and 31.12.2023: 31.12.2024 31.12.2023 Stage 1 Stage2 Stage 3 POCI Total Stage 1 Stage2 Stage 3 POCI Total Greek Government Bonds Carrying amount (before allowance for expected credit losses) 7,996 7,996 7,022 7,022 Allowance for expected credit losses (8) (8) (7) (7) Net value 7,988 - - - 7,988 7,015 - 7,015 Other Government Bonds Carrying amount (before allowance for expected credit losses) 4,354 4,354 4,029 4,029 Allowance for expected credit losses (3) (3) (2) (2) Net value 4,351 - - - 4,351 4,027 - 4,027 Other securities Carrying amount (before allowance for expected credit losses) 4,083 6 4,089 3,452 6 3,458 Allowance for expected credit losses (4) (4) (8) (6) (4) (10) Net value 4,079 - 2 - 4,081 3,446 2 3,448 Total securities measured at amortized cost Carrying amount (before allowance for expected credit losses) 16,433 - 6 - 16,439 14,503 6 14,509 Allowance for expected credit losses (15) - (4) - (19) (15) (4) (19) Net value 16,418 - 2 - 16,420 14,488 2 14,490 Reconciliation of other financial assets (except loans) before allowance for expected credit losses per IFRS 9 Stage

The table below presents the movement of the carrying amount before allowance for expected credit losses of due from financial institutions,

securities measured at amortized cost and the movement of the fair value of investment securities at fair value through other comprehensive

income including the allowance for expected credit losses per IFRS 9 Stage. Investment Securities measured at fair value through other comprehensive income 2024 2023 Stage 1 Stage2 Stage 3 POCI Total Stage 1 Stage2 Stage 3 POCI Total Balance 1.1 1,317 - - - 1,317 1,769 2 - 1,771 Changes for the year 1.1 - 31.12 - New financial assets originated 1,992 1,992 2,410 2,410 Derecognition of financial assets (764) (764) (686) (686) Interest on carrying amount before 39 39 52 52 impairment Repayments and other movements (1,615) (1,615) (1,616) (1,616) Reclassification of the portfolio of the (612) (2) (614) subsidiaries Balance 31.12 969 - - - 969 1,317 - - - 1,317 Investment securities measured at amortized cost 2024 2023 Stage 1 Stage2 Stage 3 POCI Total Stage 1 Stage2 Stage 3 POCI Total Balance 1.1 14,504 - 6 - 14,510 11,354 10 - 11,364 Changes for the year 1.1 - 31.12 - Transfers to Stage 3 from Stage 1 or 2 - (10) 10 - New financial assets originated 3,781 3,781 4,730 4,730 Derecognition of financial assets (830) (830) (578) (578) Interest on carrying amount before 284 283 impairment 401 1 402 Write-of - (4) (4) Repayments and other movements (1,423) (1,423) (946) (4) Reclassification of the portfolio of the (340) (4) subsidiaries Balance 31.12 16,433 - 7 - 16,440 14,504 - 6 14,510

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Reconciliation of Allowance for Expected Credit Losses

The tables below present the movement of the allowance for expected credit losses of Due from financial institutions, Investment securities

measured at fair value through other comprehensive income and Investment securities measured at amortized cost per IFRS 9 stage. Investment Securities measured at fair value through other comprehensive income 2024 2023 Stage 1 Stage2 Stage 3 POCI Total Stage 1 Stage2 Stage 3 POCI Total Balance 1.1 1 - - - 1 3 2 - 5 Changes for the year 1.1 – 31.12 - Impairment losses on new receivables/ securities (a) 1 1 Change in credit risk parameters (b) 1 1 (1) (1) Impairment losses on receivables/ securities (a)+(b) 1 1 - - - - - Derecognition of financial assets (1) (1) (1) ) (1) Foreign exchange and other movements - Transfer to Held for Sale (1) (2) (3) Balance 31.12 1 - - - 1 1 - - - 1 Investment securities measured at amortized cost 2024 2023 Stage 1 Stage2 Stage 3 POCI Total Stage 1 Stage2 Stage 3 POCI Total Balance 1.1 15 - 4 - 19 25 3 - - 28 Changes for the year 1.1 – 31.12 - Transfers to Stage 3 from Stage 1 or 2 - (3) 3 - Net measurement of expected credit losses (a) - 4 4 Impaiment losses on new receivables/ securities (b) 3 3 4 4 Change in credit risk parameters (c) (2) (2) (12) 1 (11) Impairment losses on receivables/ securities 1 - - 1 (8) - 5 - (3) (a)+(b)+(c) Derecognition of financial assets (1) (1) (2) (2) Write offs - (4) (4) Balance 31.12 15 - 4 19 15 - 4 - 19

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FINANCIAL ASSETS EXPOSED TO CREDIT RISK - ANALYSIS BY INDUSTRY SECTOR 31.12.2024 Public sector / Financial Institutions Construction Services Manufa-Wholesale and Goverment Hotels - Retail and other financial and Real Transportation Shipping and other Total cturing retail trade Securities / Tourism lending services estate sectors Derivatives Credit risk of exposures relating to balance sheet items: Balances with Central Banks 2,539 2,539 Due from financial institutions 2,366 2,366 Loans and advances to customers 6,518 6,442 3,099 2,675 33 1,982 3,109 2,973 1,873 10,947 39,651 Derivative financial assets 425 29 44 4 65 42 13 4 2 628 Trading securities 6 22 28 Securities measured at fair value through other comprehensive income 40 9 1 916 4 970 Securities measured at amortized cost 2,936 551 98 201 12,350 303 16,439 Securities measured at fair value through profit or loss 11 11 Assets held for sale - Loans Portfolio 125 110 154 15 11 216 945 1,576 Total amount of balance sheet items exposed to credit risk (a) 14,841 7,156 3,351 3,035 13,386 2,039 3,122 2,988 2,398 11,892 64,208 Credit risk of exposures relating to off-balance sheet items: Letters of guarantee, letters of credit and other guarantees 1,082 1,589 1,001 958 201 91 8 53 684 66 5,733 Undrawn loan commitments 196 1,243 155 947 66 5 115 151 1,674 4,552 Total amount of off-balance sheet items exposed to credit risk (b) 1,278 2,832 1,156 1,905 201 157 13 168 835 1,740 10,285 Total credit risk exposures (a+b) 16,119 9,988 4,507 4,940 13,587 2,196 3,135 3,156 3,233 13,632 74,493

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31.12.2023 Public sector / Financial Institutions Construction Services Manufa-Wholesale and Goverment Hotels - Retail and other financial and Real Transportation Shipping and other Total cturing retail trade Securities / Tourism lending services estate sectors Derivatives Credit risk of exposures relating to balance sheet items: Balances with Central Banks 3,726 3,726 Due from financial institutions 1,642 1,642 Loans and advances to customers 6,277 6,010 2,355 2,648 37 1,190 3,028 2,610 1,223 11,693 37,071 Derivative financial assets 563 18 35 1 86 7 7 3 7 727 Trading securities 5 4 9 Securities measured at fair value through other comprehensive income 38 26 1,254 1,318 Securities measured at amortized cost 2,259 667 45 189 11,051 298 14,509 Securities measured at fair value through profit or loss 13 1 14 Assets held for sale - Loans Portfolio 84 289 623 486 1 101 155 374 2,073 4,186 Total amount of balance sheet items exposed to credit risk (a) 14,607 7,010 3,058 3,325 12,433 1,298 3,035 2,768 1,902 13,766 63,202 Credit risk of exposures relating to off-balance sheet items: Letters of guarantee, letters of credit and other guarantees 913 1,708 1,004 472 191 78 11 58 527 70 5,032 Undrawn loan commitments 298 1,350 158 783 41 6 75 168 1,662 4,541 Total amount of off-balance sheet items exposed to credit risk (b) 1,211 3,058 1,162 1,255 191 119 17 133 695 1,732 9,573 Total credit risk exposures (a+b) 15,818 10,068 4,220 4,580 12,624 1,417 3,052 2,901 2,597 15,498 72,775

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47.2 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. Losses may also occur either from the trading portfolio or from the Assets-Liabilities

management.

More specifically:

• Interest rate risk is the risk that results from adverse changes or adverse volatility of interest rates.

• Foreign exchange risk is the risk arising from adverse changes or adverse volatility of foreign exchange rates.

• Equity risk is the risk arising from adverse changes in the value or volatility of equities or equity indices. The Group does not hold any

material portfolio in such instruments.

• Commodity risk is the risk arising from adverse changes in the value or volatility of commodities. The Group does not hold any material

portfolio in such instruments.

i. Trading portfolio

The Group’s Market Risk Management Policy elaborates on how market risk is managed within the Bank, i.e. the identification, measurement,

monitoring and control of market risk inherent in Treasury assets and liabilities transacted by the Bank and the country local Treasury

Management Units, as well as the determination that adequate capital is held against this type of risk. The ultimate objective of the Policy is to

provide the framework and principles for the effective management of market risk, in order to:

• maintain market risk within the limits, in line with the Bank’s risk appetite;

• reduce the risk of fraud or regulatory non-compliance by prescribing sound methodologies;

• ensure adequate controls to prevent significant losses;

• facilitate efficient decision-making by quantifying where possible the probabilities of failing to achieve earnings or other targets.

All competent Group units and country local Units apply the Policy by developing and applying corresponding processes.

Market risk of trading portfolio is measured by Value at Risk - VAR, that is the maximum amount of loss with a given probability (confidence

level). The method applied for calculating Value at Risk is historical simulation with full revaluation with 99% confidence level. The historical

observation period is one year at minimum. Risk factor returns are calculated according to the absolute or relative approach.

The Group calculates VAR on a daily basis and the data sets are updated daily. A holding period of one and ten days is applied for regulatory

purposes. Additional holding periods may be applied for internal purposes, according to the time required for the liquidation of the portfolio.

According to regulatory expectations a prospective and retrospective test is performed on a daily basis for the regulatory trading book of the

Bank using hypothetical and actual results. The Group monitors the numbers of days that the results exceed the respective risk limit.

1 day value at risk, 99% confidence interval (2 years historical data)

(Amounts in Million Euro) 2024 Foreign currency risk Interest rate risk Price risk Comodity risk Covariance Total 31 December 0.4233 0.4684 0.0445 0.0001 (0.4053) 0.5310 Average daily value (annual) 0.7954 0.9059 0.0065 0.0006 (0.5904) 1.1180 Maximum* daily value (annual) 0.6874 1.5097 0.0003 (0.4131) 1.7843 Minimum* daily value (annual) 0.4233 0.4684 0.0445 0.0001 (0.4053) 0.5310 * Relates to the total Value at Risk within the year.

(Amounts in Million Euro) 2023 Foreign currency risk Interest rate risk Price risk Comodity risk Covariance Total 31 December 0.7118 0.6626 0.0005 (0.3125) 1.0624 Average daily value (annual) 0.7422 0.3636 0.0017 0.0017 (0.3103) 0.7989 Maximum* daily value (annual) 0.8457 0.6933 0.0012 (0.3854) 1.1548 Minimum* daily value (annual) 0.5583 0.3575 0.0007 (0.4006) 0.5159 * Relates to the total Value at Risk within the year.

The Value at Risk methodology is based on certain theoretical assumptions, which under extreme market conditions might not capture the

maximum loss the Bank may suffer. The limitations of the methodology may be summarized as follows:

• VAR refers to the potential loss at a 99% confidence level, without considering any losses beyond that level

• Risk factor returns are assumed to follow the empirical distribution that was experienced during the historical observation period.

On a daily basis, a perspective and retrospective test of Value at Risk model is carried out, taking into account hypothetical and actual changes

in the trading book’s profit and loss. According to best practices, the model is validated by an independent unit at the Bank on an annual basis.

The Value at Risk methodology is complemented with scenario analysis and stress testing, in order to estimate the potential size of losses that

could arise from the trading portfolio for hypothetical as well as historical extreme movements of market parameters (stress-testing).

Within the scope of market risk control, open position, maximum loss (stop loss) and value at risk limits have been set across trading positions.

In particular, limits have been set for the following risks:

• Foreign currency risk regarding spot and forward positions and FX options

• Interest rate risk regarding positions in bonds, Interest Rate Swaps, Interest Futures, Interest Options

• Price risk regarding positions in shares, index Futures and options, Commodity Futures and Swaps

• Credit risk regarding interbank transactions and bonds

Positions held in these products are monitored on a daily basis and are examined for the corresponding limit percentage cover and for any

limit excess.

ii. Financial Risks of Banking portfolio

The Market risk may arise, apart from the trading portfolio, from the structure of assets and liabilities of loan and deposits portfolio of the

Group. This risk is foreign exchange risk and interest rate risk.

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a. Foreign exchange risk

The Group takes on the risk arising from the fluctuations in foreign exchange rates.

The management of foreign currency position is centralized.

The policy of the Group is the positions to be closed immediately using spot transactions or currency derivatives. In case that positions remain

open, they are daily monitored in the context of the financial risk management policy and they are subject to limits.

Total position derives from the aggregate balance of current position of balance sheet items and the derivatives forward position as depicted

in the tables follow.

31.12.2024 USD GBP CHF JPY RON Other FC Euro Total ASSETS Cash and balances with Central Banks 11 3 2 15 4 2,963 2,998 Due from financial institutions 124 44 8 (5) 3 19 2,103 2,296 Trading securities 6 47 53 Derivative financial assets 628 628 Loans and advances to customers 3,200 719 126 19 34,986 39,050 Investment securities: - Measured at amortized cost 112 16,308 16,420 - Measured at fair value through other comprehensive income 38 20 951 1,009 - Measured at fair value through profit or loss 33 134 167 Investments in associates and joint ventures 1 329 240 570 Investment property 83 207 290 Property, plant and equipment 13 1 520 534 Goodwill and other intangible assets 3 3 432 438 Deferred tax assets 1 4,814 4,815 Other assets 47 4 12 745 808 Assets held for sale 1,999 1,999 Total Assets 3,566 812 148 (5) 454 23 67,077 72,075 LIABILITIES Due to banks and customers 3,161 296 31 4 5 172 53,896 57,565 Derivative financial liabilities 793 793 Debt securities in issue and other borrowed funds 12 14 3,182 3,208 Liabilities for current income tax and other taxes 69 69 Deferred tax liabilities 18 18 Employee defined benefit obligations 24 24 Other liabilities 13 3 4 2 873 895 Provisions 161 161 Liabilities related to assets classified as held for sale 1,153 1,153 Total Liabilities 3,174 308 34 4 23 174 60,169 63,886 Net balance sheet position 392 504 114 (9) 431 (151) 6,908 8,189 Derivatives forward foreign exchange position (355) (489) (85) 9 (370) 154 2,669 1,533 Total Foreign exchange position 37 15 29 - 61 3 9,577 9,722

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31.12.2023 USD GBP CHF JPY RON Other FC Euro Total ASSETS Cash and balances with Central Banks 11 6 1 13 3 4,185 4,219 Due from financial institutions 163 33 8 2 1 17 1,348 1,572 Trading securities 33 33 Derivative financial assets 727 727 Loans and advances to customers 3,054 490 154 1 32,462 36,161 Investment securities: - - Measured at amortized cost 140 107 14,243 14,490 - Measured at fair value through other comprehensive income 78 19 83 1 1,188 1,369 - Measured at fair value through profit or loss 37 122 159 Investments in associates and joint ventures 1 99 100 Investment property 84 25 192 301 Property, plant and equipment 3 34 2 462 501 Goodwill and other intangible assets 12 1 454 467 Deferred tax assets 1 4,977 4,978 Other assets 115 173 12 2 643 945 Assets held for sale 4,536 1,863 6,399 Total Assets 3,599 724 175 3 4,871 51 62,998 72,421 LIABILITIES Due to banks and customers 3,026 433 32 3 172 51,704 55,370 Derivative financial liabilities 934 934 Debt securities in issue and other borrowed funds 2,920 2,920 Liabilities for current income tax and other taxes 4 4 Deferred tax liabilities 9 1 15 25 Employee defined benefit obligations 24 24 Other liabilities 165 5 3 746 919 Provisions 7 113 120 Liabilities related to assets classified as held for sale 4,280 502 4,782 Total Liabilities 3,191 433 37 3 4,296 176 56,962 65,098 Net balance sheet position 408 291 138 575 (125) 6,036 7,323 Derivatives forward foreign exchange position (358) (263) (100) (588) 157 1,152 - Total Foreign exchange position 50 28 38 - (13) 32 7,188 7,323

Τhe open foreign exchange position as at 31.12.2024 presents the following sensitivity analysis:

Currency Exchange rate variation scenario against Euro (%) Impact in net profit/(loss) before Income tax Impact on equity 5% Depreciation EUR against USD 2 USD 5% Appreciation EUR against USD (2) 5% Depreciation EUR against GBP 1 GBP 5% Appreciation EUR against GBP (1) 5% Depreciation EUR against CHF 2 CHF 5% Appreciation EUR against CHF (1) 5% Depreciation EUR against RON (3) RON 5% Appreciation EUR against RON 3

b. Interest rate risk

Interest rate risk in the banking book relates to the volatility on Equity and interest income of the Bank due to the mismatch between the non-

trading Assets-Liabilities and the portfolio measured at fair value through other comprehensive income.

The interest rate risk management framework is determined in accordance with the Asset Liability Risk Management Policy. Based on this

framework, the risk analysis of the Banking Portfolio is analyzed through the Interest Rate Gap Analysis. Specifically, 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 that analyze their behavior. In addition,

extreme interest rate change scenarios are carried out on a monthly basis, while their impact on the change in interest rate income (Net

Interest Income) and funds through EVE (Economic Value of Equity) is calculated. The models used for these analyses have been validated by

the relevant independent Business Area of the Bank.

The interest rate risk management is carried out by ALCO following recommendations from the Asset-Liability Management Business Area. In

addition, the Bank has set appropriate thresholds to monitor interest rate risk exposure. The results of the relevant interest rate change

scenarios for interest rate risk, together with the respective use of the thresholds, are presented to the Asset-Liability Management Committee

(ALCO) and the Risk Management Committee of the Governing Council.

In 2024, the Group continued to implement its hedging strategy to manage interest rate risk exposure and remains within the limits for the

Change in Economic Value of Equity to Tier 1 funds ratio and the Change in Net Interest Income to Tier 1 funds ratio, in all extreme interest rate

scenarios. Interest rate risk is managed holistically, taking into account the balance sheet dynamics as well as the market expectations on

interest rates evolution, either through the use of natural hedges (i.e. matching assets and liabilities) or through the complementary use of

financial derivatives, in order to dynamically maintain a balanced interest rate risk profile.

In addition, the Group monitors and manages the "Credit Spread Risk in the Banking Book" (CSRBB), which refers to the risk arising from

changes in the market price, credit risk, liquidity and possibly other characteristics of financial instruments with credit risk, not covered by any

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other existing regulatory framework, such as Interest Rate Risk in the Banking Book (IRRBB) or expected credit/default risk (jump-to-default

risk). The CSRBB captures the risk of an instrument's margin changing, assuming the same level of creditworthiness. In order to monitor this

risk in the Group, specific risk indicators have been defined that record the change in economic value (Economic Value of Equity) and the

impact on market value (Market value impact).

The following table presents the Interest Rate Repricing Analysis of both Assets and Liabilities, financial and non-financial.

31.12.2024 Less than 1 3 to 6 6 to 12 Non-interest 1 to 3 months 1 to 5 years > 5 years Total month months months bearing ASSETS Cash and balances with Central Banks 2,561 437 2,998 Due from financial institutions 1,154 608 327 207 2,296 Trading securities 53 53 Derivative financial assets 628 628 Loans and advances to customers 12,392 11,277 5,797 877 4,703 3,767 237 39,050 Investment securities: - Measured at amortized cost 589 835 1,036 850 4,998 8,112 16,420 - Measured at fair value through other 115 195 318 70 149 162 1,009 comprehensive income - Measured at fair value through profit or loss 145 11 11 167 Other Non-Affected items 9,454 9,454 Total Assets 17,637 12,926 7,478 1,797 9,850 12,259 10,128 72,075 LIABILITIES Due to banks 3,141 2,384 781 227 6,533 Derivative financial assets 793 793 Due to customers 16,190 5,292 4,388 4,260 15,768 5,134 51,032 Debt securities in issue and other borrowed 88 131 2,977 12 3,208 funds Other Non-Affected items 2,320 2,320 Total Liabilities 20,124 7,764 5,169 4,618 18,745 5,146 2,320 63,886 EQUITY Non Affected items 8,189 8,189 Total Equity - - - - - - 8,189 8,189 Total Liabilities and Equity 20,124 7,764 5,169 4,618 18,745 5,146 10,509 72,075 OPEN EXPOSURE (2,487) 5,162 2,309 (2,821) (8,895) 7,113 (381) - CUMULATIVE EXPOSURE (2,487) 2,675 4,984 2,163 (6,732) 381 - -

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31.12.2023 Less than 1 3 to 6 6 to 12 Non-interest 1 to 3 months 1 to 5 years > 5 years Total month months months bearing ASSETS Cash and balances with Central Banks 3,730 489 4,219 Due from financial institutions 1,179 70 96 227 1,572 Trading securities 26 4 1 2 33 Derivative financial assets 727 727 Loans and advances to customers 11,090 13,174 3,722 951 4,184 3,040 36,161 Investment securities: - Measured at amortized cost 493 827 521 858 4,871 6,920 14,490 - Measured at fair value through other 175 324 418 160 198 94 1,369 comprehensive income - Measured at fair value through profit or loss 146 10 3 159 Other Non-Affected items 13,691 13,691 Total Assets 17,566 14,409 4,662 2,065 9,253 10,286 14,180 72,421 LIABILITIES Due to banks 6,378 304 148 91 6,921 Derivative financial assets 934 934 Due to customers 14,691 3,747 3,354 4,830 16,657 5,170 48,449 Debt securities in issue and other borrowed funds 400 2,452 68 2,920 Other Non-Affected items 5,874 5,874 Total Liabilities 22,003 4,051 3,502 5,321 19,109 5,238 5,874 65,098 EQUITY Non Affected items 7,323 7,323 Total Equity - - - - - - 7,323 7,323 Total Liabilities and Equity 22,003 4,051 3,502 5,321 19,109 5,238 13,197 72,421 OPEN EXPOSURE (4,437) 10,358 1,160 (3,256) (9,856) 5,048 983 - CUMULATIVE EXPOSURE (4,437) 5,921 7,081 3,825 (6,031) (983) - - From the Interest Rate Gap Analysis and from the implementation of alternative scenarios regarding the changes in the market interest rates

or the changes in the base interest rates of the Bank and Group companies, the change in the net interest income and in equity in the case of

instruments measured at fair value through other comprehensive income as well as the related hedging instruments is directly calculated. In

the scenarios of Interest Rate decrease the variance is examined, up to the point it’s feasible (interest rate equals to zero), according to the

interest rate curves per currency as in force.

Interest rate variation scenario (parallel fall or rise in Sensitivity for net interest income (annual) Sensitivity of Equity yield curves) (200) (141) 40 200 (102) (34)

47.3 Liquidity risk

Liquidity risk relates to the Group’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 Group’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).

According to the Group’s Liquidity Risk Policy, the Board Risk Management Committee assigns the overall responsibility for overseeing the asset

and liability management to the Asset - Liability Committee (ALCo). The ALCo is responsible to monitor the quantitative and qualitative aspects

of liquidity risk and to ensure that appropriate policies and procedures are in place to control and limit liquidity risk. In addition, ALCo is

responsible for approving the business proposals, risk measurement techniques, and liquidity limits that are proposed by the Market Risk

Control, the Treasury, and the Asset Liability Management Business Areas.

The Group’s senior management is informed on current liquidity risk exposures on a daily basis, ensuring that the Bank’s liquidity risk profile

remains within approved limits. For the purpose of proper management of liquidity risk and in line with supervisory requirements, 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, and the rollover of funding are reported on a monthly level to the senior management.

Additionally, the Group monitors the liquidity exposure that arises from collateralised derivatives and repo interbank transactions by utilizing

appropriate risk sensitivities, such as the change in mark-to-market for 1 basis point change in interest rates. Client transactions are primarily

non-collateralized, and therefore, no liquidity requirements may arise from them.

Liquidity risk management aims to ensure that the respective risk of the Group is measured properly and remains within acceptable levels,

even under adverse conditions, and that the Group maintains access to surple sources of funding to cover customer needs, maturing liabilities

and other capital needs.

The Group calculates the ratios "Liquidity Coverage Ratio (LCR)" and "Net Stable Funding Ratio (NSRF)" on a monthly and quarterly basis

respectively as provided by the European Regulation 575/2013 (CRR). As of 31.12.2024 the two ratios LCR and NSFR exceeded the minimum

acceptable supervisory limit of 100%, standing at 199.8% and 125.3% respectively at Group level.

Short-term stress tests are carried out at least on a monthly basis, for liquidity purposes, in order to assess potential outflows (contractual or

contingent) and determine the level of immediate liquidity available to cover the Group’s needs. These tests are carried out according to the

approved Short-term Liquidity Stress Test Methodology and evaluate the liquidity risk in idiosyncratic extraordinary events, in systemic events,

as well as in events that combine idiosyncratic and systemic elements. It is noted that stress tests are also used to determine the liquidity buffer

for recovery purposes. For those assets and liabilities with no maturity date, the distribution of flows is based on models that analyze their

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374 | ANNUAL FINANCIAL REPORT

behavior. These models have been validated by the Risk Models and Data Validation Business Area of the Group. In accordance with the policy

and within the framework of the Internal Liquidity Adequacy Procedure (ILAAP), the Group also applies reverse stress tests to assess their

impact on liquidity.

The Group’s securities’ portfolio, that is a primary source of liquidity in time of stress, consists of approximately 85% of high-quality liquid

assets (HQLAs) and has a total size significantly greater than the outflows derived from the regular liquidity short-term stress tests exercises.

These HQLAs can be pledged to raise financing through the Eurosystem or the interbank money market without the need of liquidation.

The Group’s total funding can be divided into two main categories:

Α. Customer Deposits

1. Customer deposits on demand for cash flow needs

Deposits that are intended to meet short-term needs of customers are the savings accounts and the sight deposits. Although these deposits

may be withdrawn on demand, the number of accounts and type of depositors ensure that unexpected significant fluctuations are limited.

Therefore, these deposits constitute a significant factor of stability of the deposit base.

2. Customer term deposits and bonds for investment purposes

Customer term deposits have a pre-determined tenor primarily between three and twelve months. The customer has the right to terminate

the deposit prior to its maturity by paying a penalty that cannot exceed the amount of accrued interest.

Β. Wholesale Funding

1. Medium-term borrowing from international capital markets

The Group is a frequent issuer in the international capital markets, primarily through its European Medium Term Note (EMTN) programme.

This allows it to diversify its funding sources and extend its funding horizon by obtaining longer-term funding.

In February 2024, it successfully placed a Euro 400 million, senior preferred bond with a coupon of 5.00%. The bond has a 6.25-year tenor and

is callable at year 5.25. Additionally, in June 2024, it placed a Euro 500 million Subordinated Tier II bond with a coupon of 6%, featuring a

10.25-year tenor and callable at year 5.25. In September 2024, it placed a Euro 300 million Additional Tier I bond with a coupon of 7.5%. The

bond has perpetual maturity and is callable at year 6. Finally, in November 2024, it exercised the early redemption option on its Euro 400

million Senior Preferred bond, which carried a coupon of 7% and was set to mature in November 2025.

In June 2024, it was upgraded to Baa3 by Moody’s with a positive outlook. In September 2024, it was upgraded to BB+ by S&P Global Ratings

and to BB with a positive outlook by Fitch.

2. Funding from Central Banks

The Group utilises the financing operations of the European Central Bank, such as the three-month Long-term Refinancing Operations (LTRO)

and the weekly Main Refinancing Operations (MRO) to obtain short-term funding. For this purpose, the Bank pledges ECB-eligible assets such

as bonds. Both operations are conducted through fixed-rate tender procedures with full allotment. The Eurosystem, therefore, satisfies all bids

received from banks against eligible collateral.

In 2024, the European Central Bank reduced its deposit facility rate by 100 basis points, from 4% to 3%. Similarly, the MRO rate was reduced by

135 basis points, from 4.50% to 3.15%, narrowing the spread between the deposit facility and MRO rate from 50 basis points to 15 basis

points. As of year-end 2024, the Group’s financing from the ECB financing operations stood at EUR 2.6 billion, reduced from Euro 5 billion on

31.12.2023. The table below presents the Liquidity Gap Analysis. According to it, the cash flows arising from balance sheet items are calculated

and classified into time periods in accordance with the contractual maturity date or an estimated date based on a statistical analysis

(convention). An exception to the above, are the securities portfolios, which can contribute directly to raise liquidity, and they are allocated in

the first period under the condition they have not been used to raise liquidity either by the Central Bank or through interbank repos.

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375 | ANNUAL FINANCIAL REPORT

31.12.2024 1 to 3 3 to 6 6 to 12 < 1 month > 1 year Total months months months ASSETS Cash and balances with Central Banks 2,998 2,998 Due from financial institutions 1,086 608 350 252 2,296 Trading securities 53 53 Derivative financial assets 628 628 Loans and advances to customers 1,091 1,554 1,595 2,767 32,043 39,050 Investment securities: - Measured at amortized cost 1,009 1,009 - Measured at fair value through other comprehensive income 953 76 277 386 14,728 16,420 - Measured at fair value through profit or loss 167 167 Investments in associates and joint ventures 570 570 Investment property 290 290 Property, plant and equipment 534 534 Goodwill and other intangible assets 438 438 Deferred tax assets 281 82 4,452 4,815 Other assets 808 808 Assets held for sale 231 173 1,325 270 1,999 Total Assets 8,216 2,692 3,547 3,505 54,115 72,075 LIABILITIES Due to banks 1,656 3,726 802 271 78 6,533 Derivative financial assets 793 793 Due to customers 8,414 5,535 4,752 5,487 26,844 51,032 Debt securities in issue and other borrowed funds 132 3,076 3,208 Liabilities for current income tax 69 69 Deferred tax liabilities 18 18 Employee defined benefit obligations 24 24 Other liabilities 895 895 Provisions 161 161 Liabilities related to assets held for sale 1,152 1 1,153 Total Liabilities 10,863 9,261 6,706 5,960 31,096 63,886 Total Equity - - - - 8,189 8,189 Total Liability and Equity 10,863 9,261 6,706 5,960 39,285 72,075 OPEN LIQUIDITY GAP (2,647) (6,569) (3,159) (2,455) 14,830 - CUMULATIVE LIQUIDITY GAP (2,647) (9,216) (12,375) (14,830) - -

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376 | ANNUAL FINANCIAL REPORT

31.12.2023 < 1 month 1 to 3 months 3 to 6 months 6 to 12 months > 1 year Total ASSETS Cash and balances with Central Banks 4,219 4,219 Due from financial institutions 1,148 74 5 107 238 1,572 Trading securities 33 33 Derivative financial assets 727 727 Loans and advances to customers 1,124 1,240 1,144 3,062 29,591 36,161 Investment securities: - Measured at amortized cost 1,369 1,369 - Measured at fair value through other comprehensive 117 114 103 506 13,650 14,490 income - Measured at fair value through profit or loss 159 159 Investments in associates and joint ventures 100 100 Investment property 301 301 Property, plant and equipment 501 501 Goodwill and other intangible assets 467 467 Deferred tax assets 284 106 4,588 4,978 Other assets 945 945 Assets held for sale 78 448 5,873 6,399 Total Assets 8,896 1,790 1,700 9,654 50,381 72,421 LIABILITIES Due to banks 523 1,212 172 4,758 256 6,921 Derivative financial assets 934 934 Due to customers 7,263 3,968 3,693 5,506 28,019 48,449 Debt securities in issue and other borrowed funds 400 2,520 2,920 Liabilities for current income tax 4 4 Deferred tax liabilities 25 25 Employee defined benefit obligations 24 24 Other liabilities 919 919 Provisions 120 120 Liabilities related to assets held for sale 1 4,781 4,782 Total Liabilities 8,720 5,180 3,866 15,474 31,858 65,098 Total Equity - - - - 7,323 7,323 Total Liability and Equity 8.720 5.180 3.866 15.474 39.181 72.421 OPEN LIQUIDITY GAP 176 (3,390) (2,166) (5,820) 11,200 - CUMULATIVE LIQUIDITY GAP 176 (3,214) (5,380) (11,200) -

Trading and Investment portfolios measured at fair value through profit or loss and through other comprehensive income are listed based on

their liquidity potential and not according to their maturity.

Cash flows arising from financial liabilities including derivative financial liabilities, are allocated into time bands according to their maturity

date. Estimated interest payments are also included. Liabilities in foreign currency have been converted into Euro. Outflows and inflows

relating to derivatives are estimated according to their contractual terms.

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377 | ANNUAL FINANCIAL REPORT

31.12.2024 Total Nominal inflows/(outflows) Balance 1 to 3 3 to 6 6 to 12 Total < 1 month > 1 year Sheet months months months Liabilities- non-derivative Due to banks 6,533 (1,667) (3,752) (807) (281) (81) (6,588) Due to customers 51,032 (8,426) (5,562) (4,777) (5,514) (26,909) (51,188) Debt securities in issue and other borrowed funds 3,208 (8) (28) (43) (217) (3,507) (3,803) Other liabilities 895 (895) (895) Derivative held for assets fair value hedge 251 - Outflows (95) (192) (43) (30) (960) (1,320) - Inflows 96 189 23 37 712 1,057 Derivatives held for liabilities fair value hedge 49 - Outflows (7) (4) (11) - Inflows 66 66 Derivatives held for trading 493 - Outflows (548) (657) (879) (368) (26,615) (29,067) - Inflows 550 565 230 431 2,186 3,923 Total 62,461 (10,032) (9,444) (6,296) (5,942) (56,073) (87,787) Off Balance sheet items Undrawn loan commitments which can’t be recalled (committed) (699) (699) Financial guarantees 1,053 99 88 344 3,732 5,316 Total off Balance sheet items - 354 99 88 344 3,732 4,617 31.12.2023 Total Nominal inflows/(outflows) Balance to 1 1 to 3 3 to 6 6 to 12 Total >1 year Sheet month months months months Liabilities- non-derivative Due to banks 6,921 (714) (1,251) (217) (4,827) (263) (7,272) Due to customers 48,449 (7,272) (3,992) (3,714) (5,554) (28,090) (48,622) Debt securities in issue and other borrowed funds 2,920 (7) (28) (42) (481) (2,791) (3,349) Other liabilities 919 (919) (919) Derivative held for assets fair value hedge 181 - - Outflows (37) (30) (123) (20) (889) (1,099) - Inflows 69 149 56 45 834 1,153 Derivatives held for liabilities fair value hedge 101 - - Outflows (22) (25) (15) (11) (73) - Inflows 17 11 1 29 Derivatives held for trading 652 - - Outflows (132) (272) (329) (226) (2,516) (3,475) - Inflows 332 204 229 199 1,983 2,947 Total 60,143 (7,761) (5,242) (4,148) (10,868) (32,638) (60,657) Off Balance sheet items Undrawn loan commitments which can’t be recalled (committed) (854) (854) Financial guarantees 209 110 76 290 3,136 3,821 Total off Balance sheet items - (645) 110 76 290 3,136 2,967

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

378 | ANNUAL FINANCIAL REPORT

47.4 Fair value of financial assets and liabilities

Hierarchy of financial instruments that are not measured at fair value

31.12.2024 Total carrying Level 1 Level 2 Level 3 Total fair value amount Financial Assets Loans and advances to customers 39,235 39,235 38,328 Investment securities - Measured at amortized cost 13,546 1,592 778 15,916 16,420 Financial liabilities Due to customers 51,011 51,011 51,032 Debt securities in issue and other borrowed funds 2,668 649 88 3,405 3,208 31.12.2023 Total carrying Level 1 Level 2 Level 3 Total fair value amount Financial Assets Loans and advances to customers 37,320 37,320 35,261 Investment securities - Measured at amortized cost 12,052 1,421 467 13,940 14,490 Financial liabilities Due to customers 48,434 48,434 48,469 Debt securities in issue and other borrowed funds 2,902 124 3,026 2,920The above tables set out the fair values and carrying amounts of those financial assets that are not measured at fair value classified by fair

value hierarchy.

The fair value of loans measured at amortized cost is estimated using a model for discounting the contractual future cash flows until maturity.

The components of the discount rate are the interbank market yield curve, the liquidity premium, the operational cost, the capital

requirement and the expected loss rate. For the loans that for credit risk purposes are classified as impaired and are individually assessed for

impairment, the model uses the expected future cash flows excluding expected credit losses. For the fair valuation of the impaired loans which

are collectively assessed for impairment, estimates are made for principal repayment after taking into account the allowance for expected

credit losses. The discount rate of impaired loans is constituted of the interbank market yield curve, the liquidity premium, the operational cost

and the capital requirement.

The fair value of debt securities classified as Loans and advances to customers and measured at amortized cost, is being calculated through the

use of a model for discounting the contractual future cash flows until their maturity taking into account their credit risk. The fair value of

deposits is estimated based on the interbank market yield curve the operational cost and the liquidity premium until their maturity.

Level 1 includes securities and debt securities in issue that are traded in active market.

Level 2 includes securities and debt securities in issue, the fair value of which, is determined based on non-binding 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.

Level 3 includes securities for which there are no observable data in an active market.

The fair value of the remaining financial assets and liabilities which are measured at amortized cost does not differ materially from their

respective carrying amount.

Fair Value hierarchy - financial assets and liabilities measured at fair value 31.12.2024 Level 1 Level 2 Level 3 Total fair value Derivative financial assets 2 626 628 Trading securities - Bonds and Treasury bills 22 6 28 - Shares 25 25 Securities measured at fair value through other comprehensive income - Bonds and Treasury bills 969 969 - Shares 15 25 40 Securities measured at fair value through profit or loss - Bonds and Treasury bills 11 11 - Other variable yield securities 11 9 20 - Shares 127 10 137 Loans measured at fair value through profit or loss 127 127 Other Receivables measured at fair value through profit or loss 595 595 Derivative financial liabilities 793 793

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379 | ANNUAL FINANCIAL REPORT

31.12.2023 Level 1 Level 2 Level 3 Total fair value Derivative financial assets 2 725 727 Trading securities - Bonds and Treasury bills 4 5 9 - Shares 24 24 Securities measured at fair value through other comprehensive income - Bonds and Treasury bills 1.317 1.317 - Shares 27 25 52 Securities measured at fair value through profit or loss - Bonds and Treasury bills 14 14 - Other variable yield securities 18 13 2 33 - Shares 104 9 113 Loans measured at fair value through profit or loss 372 372 Other Receivables measured at fair value through profit or loss 528 528 Derivative financial liabilities 1 933 934

The above tables present the fair value hierarchy of financial instruments measured at fair value per fair value hierarchy level based on the

significance of the data used for its determination.

Level 1 includes securities which are traded in an active market and exchange-traded derivatives.

Level 2 includes securities whose fair value is calculated based on non-binding market prices provided by dealers-brokers or securities whose

fair value is estimated based the income approach methodology with the use of interest rates and credit spreads which are observable in the

market.

Level 3 includes securities the fair value of which is estimated using significant unobservable inputs

The valuation methodology of securities is subject to approval of Asset Liability Committee. It is noted that specifically for securities whose fair

value is calculated based on market prices, bid prices are used and daily checks are performed with regards to their change in fair value.

The fair value of loans measured at fair value through profit or loss, is estimated based on the valuation methodology as described above in

the disclosure of fair value for loans measured at amortized cost. Given that the data used for the calculation of fair value are non observable,

loans are classified at Level 3.

Shares the fair value of which is computational, are classified to Level 2 or Level 3, depending on the extent of the contribution of

unobservable data in the calculation of the fair value. The fair value of non-listed shares, as well as shares not traded in an active market is

determined either based on the Group’s share on the issuer’s equity or by the multiples valuation method or the estimations made by the

Group regarding the future profitability of the issuer taking into account the expected growth rate of its operations, as well as the weighted

average rate of capital return which is used as discount rate.

Income methodologies are used for the valuation of over the counter derivatives: discounted cash flow models, option calculation models, or

other widely accepted economic valuation models.

The valuation methodology of the over the counter derivatives is subject to approval by the Assets Liabilities Committee. Mid prices are

considered as both long and short positions may be open. Valuations are checked on a daily basis with the respective prices of counterparty

banks or central clearing houses in the context of the daily process of provision of collaterals and settlement of derivatives. If the non-

observable inputs used for the determination of fair value are significant, then the above financial assets are classified as Level 3 or otherwise

as Level 2.

In addition, the Group calculates the credit valuation adjustment (CVA) in order to take into account the counterparty credit risk for the OTC

derivatives. In particular, taking into consideration its own credit risk, the Group calculates the bilateral credit valuation adjustment (Bilateral

CVA/BCVA) for the OTC derivatives held on a counterparty level according to netting and collateral agreements in force. BCVA is calculated

across all counterparties with a material effect on the respective derivative fair values taking into consideration the default probability of both

the counterparty and Group, the impact of the first time of default, the expected OTC derivative exposure, the loss given default of the

counterparty and of Group and the specific characteristics of netting and collateral agreements in force.

Collaterals and derivatives exposure per counterparty simulate throughout the life of respective financial assets. Calculations performed

depend largely on observable market data. Market quoted counterparty and Bank’s CDS spreads are used in order to derive the respective

probability of default, a market standard recovery rate is assumed for developed market counterparties, correlations between market data are

taken into account and subsequently a series of simulations is performed to model the portfolio exposure over the life of the related

instruments. In the absence of observable market data, the counterparty probability of default and loss given default are determined using the

Group’s internal models for credit rating and collateral valuation. BCVA model is validated from an independent division of the Group

according to best practices. The tables below present a breakdown of BCVA counterparty sector and credit quality, (as defined for the

presentation purposes of the table “Loans by credit quality and IFRS 9 Stage”): 31.12.2024 31.12.2023 Category of counterparty Corporates 2 2 Governments (1) 1 31.12.2024 31.12.2023 Hierarchy of counterparty by credit quality Strong 1 2

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

380 | ANNUAL FINANCIAL REPORT

The Group reassess the fair value hierarchy on an instrument-by-instrument basis at each reporting period and proceeds with the transfer of

financial instruments, when required, based on the data at the end of each reporting period.

Within the current reporting period bonds of a total amount of € 1 have been transferred from Level 2 to Level 1 due to the bid-ask spread

which is inside the limit range set in order for a market to be classified as active.

Within the previous reporting period bonds of a total amount of € 26 have been transferred from Level 2 to Level 1 due to the bid-ask spread

which is inside the limit range set in order for a market to be classified as active.

Below is a reconciliation of changes in financial assets measured at fair value and categorized at Level 3.

31.12.2024 Assets Securities measured Securities Loans measured Other at fair value through measured at fair at fair value receivables other value through through profit measured at comprehensive profit or loss or loss fair value income Balance 1.1.2024 25 25 372 528 Total gain or loss recognized in Income Statement (3) 2 17 - Interest 1 12 12 - Gains less losses on financial transactions (4) (10) 5 Total gain(loss) recognized in OCI (2) Total gain/(loss) recognized in Equity-Reserves Purchases / Disbursements / Initial Recognition 6 148 81 Repayments (4) (1) (82) (31) Sales / Derecognition (313) Balance 31.12.2024 25 21 127 595 Gain/(loss) included in the income statement and relate to financial instruments included in the balance sheet at the end of the reporting period (2) (2) 12 1.1 - 31.12.2024 - Interest 1 6 12 - Gains less losses on financial transactions (3) (8) 31.12.2023 Assets Securities measured Securities Loans measured Other at fair value through measured at fair at fair value receivables other value through through profit measured at comprehensive profit or loss or loss fair value income Balance 1.1.2023 24 22 314 183 Total gain or loss recognized in Income Statement - 4 29 19 - Interest 1 12 7 - Gains less losses on financial transactions 3 17 14 - Gains less losses on disposal of fixed assets and equity investments (2) Total gain/(loss) recognized in Equity-Reserves 4 Purchases / Disbursements / Initial Recognition 4 1 212 329 Repayments (58) (3) Sales / Derecognition (2) (125) Transfer to assets held for sale from level 3 (7) Balance 31.12.2023 25 25 372 528 Gain/(loss) included in the income statement and relate to financial instruments included in the balance sheet at the end of the reporting period - 4 27 7 1.1 - 31.12.2023 - Interest 1 9 7 - Gains less losses on financial transactions 3 18

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381 | ANNUAL FINANCIAL REPORT

The table below presents the valuation methods used for the measurement of Level 3 fair value and sensitivity analysis of significant unobservable data as at 31.12.2024 and 31.12.2023.

31.12.2024 Total effect in income Total effect in Equity Fair Quantitative information on Non – observable statement Valuation Method Significant Non-observable Inputs Value non – observable inputs inputs change Favorable Unfavorable Favorable Unfavorable variation variation variation variation Shares measured at fair value through other Discounted cash flows / Multiples Future profitability of the issuer, Variation ± 10% in Net 25 Estimated Net Asset Value 2 (2) comprehensive income valuation expected growth / Valuation ratios Asset Value Average issuer price equal to Variation ± 10% in Based on issuer price / Discounted Bonds measured at fair value through profit or Issuer price / Credit spread - Future 91% issuer price, ± 10% n 11 cash flows with estimation of credit 1 (1) loss Cashflows Average credit spread equal adjustment of risk to 3400 bps estimated / Credit Risk % Implementation of Adjusted Discounted cash Business Plan: Discounted cash flows / Multiples flows in relation with the Shares measured at fair value through profit or Future profitability of the issuer, Applying scenarios in 10 valuation method / Expected Business Plan of the buyer 3 (2) loss expected growth / Valuation ratios the change of the BP's transaction price (average expected % of projected cash flows implementation 90%) by ± 33%. Discounted cash flows with interest Weighted Average Spread Increase of the Loans measured at fair value through profit or being the underlying instruments, Expected loss and cash flows from for Credit Risk, Liquidity 127 expected cash flows by - - loss taking into account the counterparty’ credit risk Premium & Operational Risk 10% counterparty’s credit risk equal to 5.69% Contingent consideration - Rate of Average revenue increase increase in revenue Nexi Payments 23% by year between 2022 ± 10% 3 (2) Hellas S.A. by 2025 and 2025 Contingent consideration- EBITDA Discounted cash flows of the Estimated profits of the ± 10% in estimated of Cepal Holdings for the next 3 - - Advances to customers measured at fair value underlying receivables portfolio / company Cepal Holdings profits of the company 595 years through profit or loss Discounted cash flows of estimated Contingent consideration related to Weighted average cost of revenue / EBITDA ± 10% in WACC 2 (2) NPE portfolio sales capital Deferred consideration – Collection Weighted average cost of time in relation to the time of ± 10% in WACC - - capital transfer of the properties. Σύνολο 768 9 (7) 2 (2)

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

382 | ANNUAL FINANCIAL REPORT

31.12.2023 Total effect in income Total effect in Equity Fair Quantitative information on Non – observable statement Valuation Method Significant Non-observable Inputs Value non – observable inputs inputs change Favorable Unfavorable Favorable Unfavorable variation variation variation variation Shares measured at fair value through other Discounted cash flows / Multiples Future profitability of the issuer, 25 Valuation index P/BV 0.67x Variation ± 10% in P/B comprehensive income valuation expected growth / Valuation ratios Average issuer price equal to Variation ± 10% in Based on issuer price / Discounted Bonds measured at fair value through profit or Issuer price / Credit spread - Future 89% issuer price, ± 10% n 14 cash flows with estimation of credit 1 (1) loss Cashflows Average credit spread equal adjustment of risk to 567 bps estimated / Credit Risk % Implementation of Adjusted Discounted cash Business Plan: Discounted cash flows / Multiples flows in relation with the Shares measured at fair value through profit or Future profitability of the issuer, Applying scenarios in 9 valuation method / Expected Business Plan of the buyer 11 6 loss expected growth / Valuation ratios the change of the BP's transaction price (average expected % of projected cash flows implementation 90%) by ± 32%. Other variable yield securities 2 Discounted cash flows Future profitability of the issuer - - Discounted cash flows with interest Weighted Average Spread Decrease of the Loans measured at fair value through profit or being the underlying instruments, Expected loss and cash flows from for Credit Risk, Liquidity 373 expected cash flows by - - loss taking into account the counterparty’ credit risk Premium & Operational Risk 10% counterparty’s credit risk equal to 12.86% Contingent consideration - Rate of Average revenue increase 4 (4) increase in revenue Nexi Payments 23% by year between 2022 ± 15% Discounted cash flows of the Hellas S.A. by 2025 and 2025 Advances to customers measured at fair value underlying receivables portfolio / Contingent consideration- EBITDA 528 Estimated profits of the ± 10% in estimated through profit or loss Discounted cash flows of estimated of Cepal Holdings for the next 3 - - company Cepal Holdings profits of the company revenue / EBITDA years Contingent consideration related to Weighted average cost of ± 10% in WACC 4 (4) NPE portfolio sales capital Σύνολο 951 20 (3) - - In the context of the disposal of the 80% of the equity shares of Cepal Holdings, for the valuation of the earn-out that relates to the estimated earnings before depreciation, tax, and interest (EBITDA) for the next

six years, the base scenario of the company’s business plan was taken into consideration. Based on this scenario (which is in line with the valuation of 20% of the Bank’s investment in the company), the valuation

for the years 2024-2026 of the earn-out consideration is zero.

In the context of the sale of Alpha Payment Services S.M.S.A. to Nexi S.p.A., the Bank reserves the right to repurchase in the fourth year after the completion of the transaction part of the shares that will

correspond to a participation between 24% and 39% in the company for a fixed strike price. According to the estimated figures of the company, the value of this option as of 31.12.2024 is zero.

The contingent consideration related to the sale of NPE portfolios is based on the estimated net recoveries of the underlying portfolio’s under the base scenario of the Business Plan as agreed between the

parties. The expected earn-out consideration, based on the above base case assumptions, have been further discounted to their present value based on their projected payment period.

For shares measured at fair value through profit or loss for the current period, the sensitivity analysis does not show a material change.There are no interactions between unobservable data that significantly

affect fair value.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

383 | ANNUAL FINANCIAL REPORT

47.5 Transfers of financial assets

The Group in its ordinary course of business, transfers financial assets. In cases that, despite the fact that the contractual right to receive cash

flows has been transferred, the risks and rewards remain with the Group, these assets continue to be recognized on the balance sheet.

As of 31.12.2024 the financial assets that have not been derecognized, despite the contractual transfer of their cash flows, derive from the

following categories:

a) Securitization of financial assets

As at 31.12.2024, the Group holds retail loans and credit cards as well as non-performing loans that have been transferred, by means of

securitization transactions, to fully consolidated special purpose entities which have issued notes. The securitized financial assets continue to

be recognized in loans and advances to customers as the Group retains the risks and rewards associated with them. This is justified by several

factors, which include the full consolidation of the special purpose entity, the retention of the notes issued and the right to receive the

deferred consideration from the transfer. As a result of the fact that the Group holds the notes, there is substantially no liability associated

with the transfer. The carrying amount of these securitized loans as of 31.12.2024 amount to € 3,407 while the comparative period

(31.12.2023 € 4,596) also includes the balances of securitized corporate loans and receivables from financial leases whose securitization

transactions were revoked during the year.

b) Sale and repurchase agreements of debt securities

The Group as at 31.12.2024, has transferred certain Greek Government Bonds and Treasury Bills and bonds of other issuers and agreements to

repurchase. These securities are recognized in the Group’s investment portfolio and the respective amounts are presented in the following

table.

31.12.2024 Securities measured at fair value through Securities measured at fair value through other comprehensive income that have other comprehensive income been transfer to Assets Held for Sale Other Greek Government Bonds Government Other Issuers’ Bonds and Treasury Bills Bonds Carrying amount of transferred securities 6 24 13 Carrying amount of related liability (6) (22) (13) Fair value of transferred securities 6 24 13 Fair value of related liability (6) (22) (13) Net position - 1 - 31.12.2024 Securities Measured at Amortised Cost Greek Government Bonds Other Issuers’ Senior Other Government Bonds and and Treasury Bills Bonds Securitization Notes Treasury Bills Carrying amount of transferred securities 33 577 302 94 Carrying amount of related liability (33) (534) (133) (88) Fair value of transferred securities 33 577 267 91 Fair value of related liability (33) (534) (133) (88) Net position - 43 133 2 The Group as at 31.12.2023, has transferred certain Greek Government Bonds and Treasury Bills and bonds of other issuers and agreements to

repurchase. These securities are recognized in the Group’s investment portfolio and the respective amounts are presented in the following

table.

31.12.2023 Securities measured at fair value through Securities Measured at Amortised Cost other comprehensive income Greek Government Other Issuers’ Senior Securitization Bonds and Treasury Greek Government Bonds and Treasury Bills Bonds Notes Bills Carrying amount of transferred securities 96 213 302 28 Carrying amount of related liability (91) (189) (128) (27) Fair value of transferred securities 94 214 275 28 Fair value of related liability (91) (189) (128) (27) Net position 3 24 147 1

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

384 | ANNUAL FINANCIAL REPORT

47.6 Offsetting financial assets - liabilities

The Group can offset its assets and liabilities according to IAS 32 criteria and the net amount is depicted in the balance sheet, when there is a

legal right of set off the recognized amounts and there is an intention to settle on a net basis, or to realize the asset and settle the liability

simultaneously (the offsetting criteria). Financial instruments that meet offsetting criteria relate to OTC derivative financial instruments that

are cleared by a central clearing counterparty (CCP) and for which the Group examined the terms of the respective International Exchange and

Derivatives Association (ISDA) agreements with the Clearing Members and concluded that the criteria for offsetting in the balance sheet its

valuations with the financial guarantee accounts relating to the coverage of the margin of valuation differences are met.

The Group can offset its assets and liabilities relating to a counterparty in case of a credit default for Financial instruments such as derivative

transactions under International Exchange and Derivatives Association (ISDA) agreements with financial institutions, as well as repurchase

agreements under global master repurchase agreement (GMRA).

The following tables present financial assets and liabilities that meet offsetting criteria in the Balance Sheet, as well as financial assets and

liabilities subject to contracts for which the criteria mentioned above for offsetting in the Balance Sheet are not met.

Financial assets subject to offsetting

31.12.2024 Related amounts not offset Net amount of Gross amount of Gross amount of financial assets Cash Net recognized financial recognized financial Financial presented in the collateral Amount assets liabilities offset instruments balance sheet received Derivatives 1,819 (1,329) 490 (155) (326) 9 Guarantees for derivative securities coverage and 616 (68) 548 (237) 311 repurchase agreements Reverse repos 985 985 (969) 16 31.12.2023 Related amounts not offset Net amount of Gross amount of Gross amount of financial assets Cash Net recognized financial recognized financial Financial presented in the collateral Amount assets liabilities offset instruments balance sheet received Derivatives 1,740 (1,092) 648 (171) (454) 23 Guarantees for derivative securities coverage and 699 (200) 499 (272) 227 repurchase agreements Reverse repos 263 263 (258) 5

Financial liabilities subject to offsetting

31.12.2024 Gross amount of recognized Net amount of Gross amount of Gross amount of financial liabilities financial liabilities Net recognized financial recognized financial Cash presented in the Financial Amount liabilities assets offset collateral balance sheet instruments received Derivatives 1,855 (1,176) 679 (172) (237) 270 Guarantees for derivative securities coverage and 569 (221) 348 (326) 22 repurchase agreements Repos 2,770 2,770 (969) (2) 1,799 31.12.2023 Gross amount of recognized Net amount of Gross amount of Gross amount of financial liabilities financial liabilities Net recognized financial recognized financial Cash presented in the Financial Amount liabilities assets offset collateral balance sheet instruments received Derivatives 1,864 (1,070) 794 (169) (272) 353 Guarantees for derivative securities coverage and 695 (223) 472 (454) 18 repurchase agreements Repos 661 661 (258) (1) 402

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

385 | ANNUAL FINANCIAL REPORT

Reconciliation of the net amount of financial assets and liabilities presented in the balance sheet

31.12.2024 Carrying amount of Financial assets not in Net amount presented in Note financial assets in the scope of offsetting the balance sheet balance sheet disclosures Type of financial asset Derivatives 22 490 628 138 Guarantees for derivative securities coverage and repurchase 548 548 agreements Repos 19 985 985 31.12.2024 Carrying amount of Financial liabilities not in Net amount presented in Note financial liabilities in the scope of offsetting the balance sheet balance sheet disclosures Type of financial liability Derivatives 22 679 793 114 Guarantees for derivative securities coverage and repurchase 348 348 agreements Repos 19 2,770 2,770 31.12.2023 Carrying amount of Financial assets not in Net amount presented in Note financial assets in the scope of offsetting the balance sheet balance sheet disclosures Type of financial asset Derivatives 22 648 727 79 Guarantees for derivative securities coverage and repurchase 499 499 agreements Repos 19 263 263 31.12.2023 Carrying amount of Financial liabilities not in Net amount presented in Note financial liabilities in the scope of offsetting the balance sheet balance sheet disclosures Type of financial liability Derivatives 22 794 934 140 Guarantees for derivative securities coverage and repurchase 472 472 agreements Repos 19 661 661

48. Capital Adequacy

The policy of the Group is to maintain strong capital ratios and capital buffers over requirements in order to secure that the business plan will

be achieved and to ensure trust of depositors, shareholders, markets, and business partners.

Share capital increases are conducted following resolutions of the General Meeting of Shareholders or the Board of Directors, in accordance

with articles of incorporation or the relevant laws.

The Capital Adequacy ratio compares the Group’s regulatory capital with the risks that it undertakes (Risk Weighted Assets - RWAs).

Regulatory capital includes Common Equity Tier 1 (CET1) capital (share capital, reserves, minority interests), Additional Tier1 capital (hybrid

securities) and Tier 2 capital (subordinated debt). RWAs include the credit risk of the investment portfolio [including also counterparty credit

risk and credit valuation adjustment (CVA) risk], the market risk of the trading book and the operational risk.

Alpha Bank S.A., as a systemic bank, and therefore its Parent company Alpha Services and Holdings S.A., is supervised by the Single Supervisory

Mechanism (SSM) of the European Central Bank (ECB), to which reports are submitted every quarter. The supervision is conducted in

accordance with the European Regulation 575/2013 (CRR) as amended, inter alia, by Regulation (EU) 876/2019 (CRR 2) and the relevant

European Directive 2013/36 (CRD IV), as incorporated into the Greek Law through the Law 4261/2014 as amended, inter alia, by Directive

(EU)2019/878 (CRD V) and incorporated by Law 4799/2021.

The adoption of the Capital Requirements Regulation (CRR III), applicable from 01.01.2025, introduces a series of significant changes to the

regulatory framework established under CRR 2, particularly in the context of standardized approaches to credit risk, market risk, operational

risk and CVA risk. These modifications aim to enhance the resilience of financial institutions while ensuring greater consistency and

comparability across jurisdictions.

The transition from CRR II to CRR III reflects the European Union’s commitment to implementing the final Basel III reforms (Basel IV). CRR III aims

to:

➢ Enhance the risk sensitivity of prudential frameworks.

➢ Improve the comparability and transparency of financial institutions’ risk profiles.

➢ Promote a more resilient banking system capable of withstanding economic shocks.

For the calculation of capital adequacy ratio, the current regulatory framework is followed. In addition:

•

Besides the 8% capital adequacy limit, there are applicable limits of 4.5% for CET 1 ratio and 6% for Tier 1 ratio, respectively.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

386 | ANNUAL FINANCIAL REPORT

•

The maintenance of capital buffers additional to the CET1 capital are required. In particular the Combined Buffer Requirement (CBR)

consisting of:

The Capital conservation buffer (CCB) stands at 2.5%.

the following capital buffers set by the Bank of Greece through its Executive Committee Acts:

- countercyclical capital buffer (CCyB), equal to “zero percent” (0%) for 2024.

- other Systemically Important Institutions (O-SII) buffer, which will gradually rise to “one percent” (1%) from 1.1.2019 to 1.1.2023.

For 2024, the O-SII buffer stands at 1.00%.

It is noted that, under Executive Committee Act 235/1/07.10.2024 the Bank of Greece has decided to set the countercyclical capital buffer rate

for Greece at 0.25%, applicable from 1 October 2025. The target rate for the positive neutral rate of the countercyclical capital buffer in

Greece at 0.5%.

These limits should be met on a consolidated basis.

The following table presents the capital adequacy ratios of the Group: 31.12.2024 31.12.2023 Common Equity Tier I Ratio 16.3% 14.4% Tier I Ratio 18.6% 15.7% *Total Capital Adequacy Ratio 21.9% 18.8%

The above capital ratios include FY 2024 profits post a provision for dividend payout of €281 either as cash dividend and/or in the form of share buybacks, in accordance with the

dividend policy. Excluding the provision for dividend at FY 2024, capital ratios increase by c. 97 bps and the Total Capital ratio would stand at 22.9%.

Group's CET1 Ratio includes specific prudential adjustments in accordance with Article 3 of CRR and the expectations of regulatory authorities,

including those related to exposures guaranteed by the Greek state. Specifically, for the exposures guaranteed by the Greek state, the Bank

made a prudential adjustment of € 73 million as of December 31, 2024, in alignment with the guidelines issued by the ECB to banks at the

beginning of 2024. This adjustment is temporary and depends, among other factors, on the progress of payments from the Greek state (based

on the new Law 5104/24). The book value of these exposures, recognized in the "Loans and receivables from customers" account, amounted

to € 100 million as of December 31, 2024, and, in accordance with ECB guidelines, were classified as non-performing exposures (NPE) and

accordingly as Stage 3 loans.

Taking into consideration the 2023 Supervisory Review and Evaluation Process (SREP) decision, ECB notified Alpha Services and Holdings S.A.,

that for Q4 2024 it is required to meet the minimum limit for consolidated Overall Capital Requirements (OCR), of at least 14.69% (OCR

includes for Q4 2024 the CCB Capital Buffer of 2.5% the O-SII buffer of 1% and the CCyB of 0.19% which mainly derives from the contribution

of subsidiaries).

The OCR consists of the minimum limit of the total Capital adequacy Ratio (8%), in accordance with art. 92(1) of the CRR, the additional

regulatory requirements of Pillar2 (P2R) in accordance with article 16(2) (a) of the Council Regulation EU 1024/2013 (3%), as well as the

combined buffers’ requirements (e.g. CCB, OSII, CCyB), in accordance with Article 128 (6) of Directive 2013/36/EU. The minimum rate should

be kept on an on-going basis, considering the CRR/CRD Transitional Provisions.

On December 2024 Alpha Services and Holdings S.A. received the SREP decision 2024 regarding the Capital Requirements for the year 2025.

The additional supervisory requirements for Pillar II (P2R) remains unchanged to 3.0%

Minimum requirements for own funds and eligible liabilities (MREL)

On 22 April 2024, Alpha Bank S.A. received a communication letter from the European Single Resolution Board (SRB) including its decision for

the minimum requirements for own funds and eligible liabilities (MREL). The requirements are based on the Recovery and Resolution Directive

(“BRRD2”), which was incorporated into the Greek Law 4799/2021 on 18.5.2021. At the same time, by the same decision, the Resolution

Authority defined the single point of entry (SPE) resolution strategy. The letter also sets out the intermediate MREL targets to be met from 1

January 2024 up to 31 December 2024, i.e. 18.81%

of TREA and 5.91% of LRE.

Following the Decision of SRB on 20 December 2024, Alpha Bank received the binding Minimum Requirement of Own Funds and Eligible

Liabilities (MREL), according to which the Bank needs to meet from 30 June 2025 on a consolidated basis an MREL requirement of 23.57% of

Total Risk Exposure Amount (TREA) and 5.91% of Leverage Exposure (LRE). The Decision also sets out that the binding target of AB SA also

reflect the MCC allowance.

The said MREL requirements expressed as a percentage of TREA do not include the Combined Buffer Requirement (CBR), equal to 3.69% as of

31.12.2024.

Furthermore, the Resolution Authority has decided that Alpha Bank S.A. is not subject to requirement for subordinated MREL. Minimum

requirements for own funds and eligible liabilities (MREL), including the transition compliance period, are subject to annual review/approval

from SRB.

On 31 December 2024, the Bank’s MREL ratio stood at 29.04%, which is well above the interim non-binding target of 22.50% of the Total Risk

Exposure Amount (TREA) (effective 01.01.2024, including CBR). The ratio includes the profit of the financial reporting period that ended on 31

December 2024 post a provision for dividend payout.

Supervisory disclosures regarding capital adequacy and risk management in accordance with Regulation 575/2013 (Pillar III) will be published on the Bank’s website.

Excluding CBR

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

387 | ANNUAL FINANCIAL REPORT

49. Related party transactions

The Company and the other companies of the Group enter into transactions with related parties in the normal course of business. These

transactions are performed at arm’s length and are approved by the respective bodies. Credit limits provided are in line with the credit and

pricing policy of the Group.

a. The outstanding balances of the Group’s transactions with key management personnel consisting of members of the Bank’s Board of

Directors and the Executive Committee, their close family members and the entities controlled by them, as well as, the results related to

these transactions are as follows: (Amounts in thousands €) 31.12.2024 31.12.2023 Assets Loans and advances to customers 3,181 3,633 Liabilities Due to customers 5,222 7,346 Employee defined benefit obligations 278 253 Debt securities in issue and other borrowed funds 4,268 4,765 Provisions 1,011 Total 10,779 12,364 Letters of guarantee and approved limits 422 308 (Amounts in thousands €) From 1 January to 31.12.2024 31.12.2023 Income Interest and similar income 151 174 Fee and commission income 6 5 Gains less losses on financial transactions 2 Total 157 180 Expenses Interest expense and similar charges 174 106 Remuneration of Board members, salaries and wages 14,052 9,922 Total 14,226 10,028

Remuneration of key executives and their close relatives is analyzed as follows:

(Amounts in thousands €) From 1 January to 31.12.2024 31.12.2023 Remuneration of Board members, salaries and wages 7,511 6,451 Employee defined benefit obligations 14 21 Bonus Incentive program expenses 3,862 2,511 Termination benefits 1,890 Employer contributions 603 728 Other 172 216 Total 14,052 9,927In addition, according to the decision of the General Meeting of Shareholders held at 29.6.2018, a compensation scheme for the Bank’s Senior

Management is operating, the terms of which were specified through a Regulation issued subsequently. The program is voluntary, does not

constitute business practice and the program may be terminated in the future by a decision of the General Meeting of the Shareholders. It

provides incentives for the eligible personnel to comply with the terms of departure, proposed by the Bank, thus ensuring the smooth (only

during the period and under the terms and conditions approved by the Bank) departure and succession of Senior Management.

b. The outstanding balances with the Group’s, associates as well as the results related to these transactions are as follows: (Amounts in thousands €) 31.12.2024 31.12.2023 Assets Due from financial institutions 17,595 Derivate financial instruments 1,296 Loans and advances to customers 233,409 90,020 Other Assets 2,362 75,442 Total 254,662 165,462 Liabilities Due to banks 70,000 Due to customers 165,440 29,758 Other Liabilities 37,977 33,598 Total 273,417 63,356

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

388 | ANNUAL FINANCIAL REPORT

(Amounts in thousands €) From 1 January to 31.12.2024 31.12.2023 Income Interest and similar income 11,413 15,217 Fee and commission income 26 18 Gains less losses on financial transactions 3,234 Other income 8,082 2,014 Total 19,521 20,483 Expenses Interest and similar expense 159 General administrative expense 14,147 27,712 Other expenses 44,940 31,019 Total 59,246 58,731

c. The outstanding balances with the Group’s, joint ventures as well as the results related to these transactions are as follows: (Amounts in thousands €) 31.12.2024 31.12.2023 Assets Loans and advances to customers 48,667 55,564 Other Assets 154 165 Total 48,821 55,729 Liabilities Due to customers 9,829 10,400 Total 9,829 10,400 (Amounts in thousands €) From 1 January to 31.12.2024 31.12.2023 Income Interest and similar income 3,910 4,791 Fee and commission income 213 Other income 233 Total 4,143 5,004 Expenses Interest expense and similar charges 31 18 Impairment losses and provisions to cover credit risk on loans and advances to customers and related expenses 3 495 Total 34 513

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 Real Estate Services S.A., Alpha Services and Holdings S.A., Alpha Supporting

Services S.A., Alphalife A.A.E.Z.

The results related to the transactions with TEA are as follows: (Amounts in thousands €) From 1 January to 31.12.2024 31.12.2023 Expenses Staff cost and expenses 7,146 9,403

TEA Group Alpha Services and Holdings keeps a deposit with Alpha Bank amounting to € 25 thsd. as at 31.12.2024, (31.12.2023 : € 61 thsd.)

50. Auditor’s fees

The total fees of the statutory auditor of the Bank “Deloitte Certified Public Accountants S.A.”, a member of Deloitte Touche Tohmatsu Ltd

(“DTTL”), as well as of the other DTTL companies and their respective associates, are analyzed below, in accordance with the provisions of

paragraph 2 and 32, article 29, of Law 4308/2014.

From 1 January to (Amounts in thousands €) 31.12.2024 31.12.2023 Statutory audit of the annual accounts * 3,503 3,372 Issuance of tax certificate * 696 572 Other audit related services * 908 704 Other non-audit services* 121 32 Total 5,228 4,680

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

389 | ANNUAL FINANCIAL REPORT

*The amount of the fee includes other expenses up to 2% of the fee

51. Disclosure of Law 4151/2013

The purpose of the provisions of chapter B of Law 4151/2013 is the funds from dormant deposit accounts to be used by the Greek State to

cover government needs, after the write off of rights of depositors or their legal heirs. According to the aforementioned the provisions of Law

4151/2013:

i. Dormant deposit account to credit Institution, according to the provisions of Law 4261/2014, is an account on which no

transaction by depositors has been recorded for a period of 20 years from the day following the last transaction (the crediting or

capitalizing of interest to an account will not constitute a transaction and not interrupt the prescription),

ii. Following the expiry of the 20-year period, the credit institutions in Greece are obliged to transfer to the Greek State the

aggregate balance of dormant deposit accounts, including any interest, by the end of April of each year by making a deposit of

the relevant amount in a special account held in Bank of Greece, notify the General Accounting Office (GAO) and the General

Directorate of Public Property to fulfill the obligations arising from the Law 4151/2013 and to provide information to

beneficiaries and heirs after the lapse of 20 years for the transfer of the respective amounts, if requested (the abovementioned

amounts, in total, will be recorded as income in the Annual State Budget)

For the fiscal year 2024, the amount of dormant deposit accounts that will be granted to the Greek State, according to article 8 par. 2 of Law

4151/2013, until 31.12.2024, amounts to € 9.

52. Assets held for sale 31.12.2024 31.12.2023 Project Unicorn (Alpha Life, Alpha Bank Romania) 1,192 5,484 Alpha Leasing Romania S.A. and Alpha Insurance Brokers S.R.L. 30 37 Non-performing loans and assets portfolio in Cyprus – (ACAC) 63 39 Non-performing loans and assets portfolio – Project Leasing – Andros 19 56 Other Non-performing loans portfolio 509 311 Skyline Project 131 408 APE Investment Property S.A. 42 42 Investment properties Alpha Leasing S.A. 11 5 Other real estate properties 2 3 Investment securities 14 Total 1,999 6,399 Liabilities related to assets held for sale

31.12.2024 31.12.2023 Project Unicorn (Alpha Life, Alpha Bank Romania) 1,152 4,781 Other liabilities 1 1 Total 1,153 4,782

The Group has initiated the process for the sale of selected subsidiaries, joint ventures, Non-Performing loan portfolios, as well as real estate

properties and other fixed assets for which the criteria of IFRS 5 are met, thus they are classified as “Assets Held for Sale”.

Non-Performing loans continue to be measured in accordance with the provisions of IFRS 9, however, for those loans measured at amortised cost,

the estimate of expected credit loss incorporates the sale scenario with 100% probability weight, taking into consideration the interested /

preferred investors’ prices and the estimated costs for the completion of the transactions. Similarly, for loans measured at fair value through profit

or loss the determination of fair value is based also on investors’ prices.

For other assets classified as Held for sale the fair value is calculated at each reporting period in accordance with the methods referred to in note

1.2.7, considering offers from the investors for the items included in the perimeter that is expected to be transferred in conjunction with

Management decisions for the completion of the transactions.

Fair vales in terms of fair value hierarchy are classified as Level 3, since they make use of data from market research, estimates and data which

refer to financial assets of similar characteristics and therefore make use of significant non-observable market input.

Project Unicorn (Alpha Life, Alpha Bank Romania)

On 23.10.2023, the Group announced its strategic partnership with UniCredit S.p.A. (“UniCredit) that involves the following two separate

transactions:

a) The sale of 90.1% of Groups’ Romanian subsidiary Alpha Bank Romania

b) UniCredit Group will acquire 51% of Alpha Life Insurance Company S.A. (“Alpha Life”) a wholly-owned life insurance subsidiary of the

Alpha Services and Holdings Group

On 4 November 2024, the sale transaction of Alpha Bank Romania was completed, by transferring 90.1% of subsidiaries’ shares to Unicredit S.p.A

for: i) € 254 cash consideration, ii) Unicredit Romania shares valued at € 272, which correspond to 9.9% of the companies’ Share Capital and iii)

Alpha Bank Romania shares valued at € 58 which corresponds to 9.9% of the companies’ Share Capital. Taking into consideration the transaction

costs the Group recognised a profit from sale of € 7.

As regards to Alpha Life, the transaction is expected to be completed within H1 2025. From the valuation of the assets and liabilities at the lower

between their carrying amount and fair value less costs to sell, no impairment loss was required.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

390 | ANNUAL FINANCIAL REPORT

The assets, liabilities and specific components of equity of the subsidiaries are presented in the following table: ASSETS Alpha Life Investment securities - Measured at fair value through other comprehensive income 478 - Measured at amortized cost 146 - Measured at fair value through profit or loss 553 Deferred tax assets 13 Other assets 2 Total Assets 1,192 LIABILITIES Alpha Life Due to customers 581 Insurance contract liabilities 561 Other liabilities 10 Provisions - Total Liabilities 1,152 Amounts directly recognized in equity and are associated with assets classified as held for sale (14) The above assets and liabilities are included as discontinued operations in the operating segment “Retail” of note 46 “Segmental Reporting”.

Alpha Leasing Romania S.A. and Alpha Insurance Brokers S.R.L

As part of the negotiations for the Unicorn transaction, in the third quarter of 2024 it was decided that Alpha Leasing Romania and Alpha Insurance

Brokers will not be transferred to UniCredit S.p.A. ("UniCredit").

However, the Group is still pursuing on the sale of the subsidiaries and has already started seeking alternative investors. In this context, during the

fourth quarter of 2024, the due diligence review by a third-party investor was completed and the parties are now negotiating the terms of the

purchase agreement which is expected to be signed within the first quarter of 2025. Therefore, Alpha Leasing Romania and Alpha Insurance

Brokers continue to be classified as assets held for sale and more specifically as a new distinct disposal group while their results are presented as

discontinued operations.

The new disposal group was measured at the lower of carrying amount and Fair Value Less cost to sell, resulting in an impairment loss of € 2.

The net assets of the companies amount to € 31 of which € 30 concern loans and advances to customers. The assets and liabilities of the Romanian

subsidiaries are included as discontinued activities in the operating segment "International Activities" of note 46 "Segmental Reporting".

Non-performing exposure portfolio and real estate in Cyprus-Project ACAC

Following a financial offer received by an investor, the Executive Committee approved on 28.6.2024 the disposal of Cyprus non-performing loans

with a total GBV of € 135., which also include loans from the previous Sky transaction with NBV of € 39. As a result, impairment losses of € 24 were

recognised. The transaction is expected to be completed within the first half of 2025.

The above loans portfolio is included in the operating segment “Non – Performing Assets” of note 46 “Segmental Reporting”.

Non-performing exposure portfolio and real estate - Project Leasing

In the first half of 2022, the Group initiated the process for the sale of leasing portfolio. On 29.6.2022 the Executive Committee approved the sale

of this portfolio to the preferred investor and as a result the Group classified the loan portfolio as “Assets Held for Sale” on 30.6.2022. The

transaction will be completed once the Group proceeds with the corporate transformation of Alpha Leasing which will be structured in a way that

takes advantage of the provisions of the newly reformed demerger laws and will be subject to regulatory approvals. Furthermore, there is a

lengthy legalization process in order for the properties to be ready to be transferred to the investor, upon the request of the investor. For these

reasons, the transaction will take longer to be completed, however the parties remain committed to the sale. The binding agreement with the

investor was signed on 19.6.2024 and in December 2024 an application to the Bank of Greece was submitted for the corporate transformation.

The process of legalization of the properties of the perimeter has already begun and is executed simultaneously with the process of the corporate

transformation.

Taking into account the above, it is expected that the transaction will be completed within the first half of 2025 upon completion of the required

corporate transformation and real estate audits.

As a result, the portfolio remained classified under "Assets for Sale". On 31.12.2024, the NBV of the loan portfolio amounted to € 16 (31.12.2023: €

49) and of real estate to €3 (31.12.2023: €7). In 2024, additional impairment losses of € 3 (31.12.2023: € 5) related to the loan portfolio were

recognized.

The aforementioned loan portfolio is included in “Non-Performing Assets” segment for operating segment disclosure purposes (note 46).

Other non-performing loans portfolio

Loan portfolio – Project Hermes

On 25.5.2023, the Group completed the sale of the Hermes transaction, from which specific loans of book value at 31.12.2023 € 12 (Hermes tail)

were excluded, which present operational and business particularities for their transfer. In the fourth quarter of 2024, the Group decided not to

continue the effort to transfer the loans to the investor, with the result that book value loans at 31.12.2024 of € 5 were no longer classified as

assets for sale, while certain loans with a book value of €7 were transferred to the Solar transaction perimeter and remained classified under

"Assets for Sale".

Loan portfolio – Project Solar

In the first half of 2022, the Bank commenced the process for the sale of a portfolio consisting of syndicated secured corporate non-performing

loans. The transaction included a state guarantee through the Hercules III program and in December 2022 binding offers took place by investors,

whereas the preferred investor’s decision came in April 2024 from the Executive Committee. In the fourth quarter of 2024, Executive Committee

decided not to bring the transaction of Hercules III program to completion, instead they proceeded to bilateral negotiations with the investor for

the direct sale of the portfolio with a potential increase in the perimeter. As a result of the above, the Group classified this loan portfolio as “Assets

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

391 | ANNUAL FINANCIAL REPORT

Held for sale”. The net carrying amount of the loan portfolio as at 31.12.2024 was € 48 (31.12.2023: € 47). In 2024 additional impairment losses of

€ 4 (31.12.2023: € 9) related to loan portfolio were recognized.

The aforementioned loan portfolio is included in “Non-Performing Assets” segment for operating segment disclosure purposes (note 46).

Loan portfolio – Project Gaia I and Gaia II

In the fourth quarter of 2023, the Group initiated the process of selling a portfolio mainly consisting of non-performing secured mortgage

loans (Gaia I transaction). The Executive Committee approved the commencement of bilateral discussions with a preferred investor in

December 2023 to finalize the agreement. Taking the above into account, the Bank classified the loan portfolio, with a carrying value as of

31.12.2023 of € 224 as “Assets held for sale”. On 25.6.2024, the Executive Committee approved the expansion of the GAIA I perimeter with an

additional non-performing mortgage loans with a carrying value before impairments as of 31.12.2024 of € 464.

The Bank received a binding offer from the investor in September 2024, and following approval by the Bank's Board of Directors on

12.12.2024, the parties completed negotiations and finalized the contractual documents for the transaction.

Simultaneously, within the framework of ongoing negotiations for Gaia I Transaction, the Bank initiated bilateral negotiations with the investor

for the sale of Non-Performing Loans (mainly Small and Medium Enterprises) with a carrying value before impairments as of 31.12.2024 of €

565 million (Gaia II transaction). The investor submitted a binding offer for Gaia II in December (exercising the right of first offer). Following the

decisions of the Executive Committee and the Board of Directors on 3.12.2024 and 13.12.2024, the investor's offer was approved, and an

agreement was concluded on substantially similar terms to Gaia I.

The two transactions are expected to be completed in 2025 through securitization, with the Bank retaining the senior notes for which an

application has been submitted for their inclusion in the 'Credit Institution Securitization Guarantee Program' under Law 4649/2019 (HAPs-III

Program).

The carrying amount before impairments of the Gaia I & II portfolios as of 31.12.2024 amounted to € 1,029, while the NBV as of the same date

was € 445.

Impairment losses of € 175 were recognized in 2024 (2023: €83 million) as a result of the classification of the portfolios as held for sale. The

aforementioned loan portfolio is included in “Non-Performing Assets” segment for operating segment disclosure purposes (note 46).

Other loans portfolios

As at 31.12.2023, the Group has classified as “Assets Held for sale” a portfolio of loans with a net carrying amount of € 29. In February 2024, a loan

with net book value of € 6 was sold to a third party, for the remainning loan portfolio with book value of € 16 as at 31.12.2024 (31.12.2023: € 23)

an additional loss os € 7 was recognised in 2024.

The aforementioned loan portfolio is included in “Non-Performing Assets” segment for operating segment disclosure purposes (note 46).

Real Estate portfolio

Project Skyline

In July 2022, the Group commenced the process for the sale of a portfolio of investment and owned-occupied properties as well as assets classified

in “Other Assets”. On 6.2.2023, the Group and the joint venture Dimand S.A. - Premia Properties REIC signed a binding agreement for the

formation of a partnership in real estate investment through the sale of an amount of € 438 real estate portfolio.

The agreement provided for the acquisition of the real estate portfolio through successive transfers to Skyline Group company Akinita Single

Member, SA ("Skyline") and the acquisition of a majority stake of 65% of Skyline by a consortium of the investor. The properties were classified

under "Assets for Sale" as a disposal group.

The book value of the Group's disposal team as at 31.12.2023 amounted to € 408. In 2024, properties with a net book value of € 70 were excluded

from the transaction, in view of the completion of the transaction in the fourth quarter of 2024. On 20.12.2024, the sale transaction of Skyline and

its subsidiaries was completed, transferring 65% of its shares to the joint venture Dimand S.A. - Premia Properties S.A. for: i) €20 in cash, ii)

deferred consideration of €78 and iii) retention of shares in Skyline of fair value €84 corresponding to 35% of the company's share capital. From

the sale of the subsidiary, the Group recognized a profit of €23 on the line "Profits/(losses) from sale of fixed assets and participations". At the

completion of the sale of the subsidiary, properties with a net book value of €131 at 31.12.2024 had not been transferred to the scheme and

remain on the Group's balance sheet as "Assets for Sale". Their transfer to Skyline is expected to be completed for the most part in 2025.

The above real estate properties are included in the operating segment “Non-Performing Assets” of note 46 “Segmental Reporting”.

APE Investment Property S.A.

In February 2021, the Bank signed with a Consortium a Sale and Purchase Agreement, for the sale of its shares in the company. The contractual

period provided under the SPA was set to 24 months (February 2023) to cater for the Covid outbreak.

Under the SPA the Bank has the option to extend the long stop date for an additional six months. In January 2023, the Bank approved the

extension of the completion of the transaction and signed an amending contract with the buyer to extend the completion date until January 31,

2025. However, as the fulfillment of regulatory conditions for the completion of the transaction is still pending, the parties are considering

further extending the final date until the end of 2025, with the removal of certain conditions and the payment of part of the price.

The counterparties remain committed to the transaction and discuss the possible extension of the long stop date until 31.12.2025, which will be

accompanied by the lifting of specific regulatory requirements and the payment of part of the price. Therefore, the company remains under

"Assets for sale". The company is included in the "Non-performing Assets" segment for operating segment disclosure purposes. (note 46).

Investment properties Alpha Leasing S.A.

This category includes investment properties of Alpha Leasing S.A. which meet the criteria to be classified as held for sale in accordance with IFRS

5. The net book value of the properties as of 31.12.2024 amounts to € 11 (31.12.2023: € 5). Within 2024 properties with book value € 6 were sold

for a gain of € 2 recognised in line “Gains/(Losses) on disposal of fixed assets and equity investments”.

It is noted that the aforementioned properties of Alpha Leasing are included in “Non-Performing Assets” segment for operating segment

disclosure purposes (note 46).

Other real estate properties

Other real estate properties classified as “Assets held for Sale” include assets with net carrying amount of € 2 (31.12.2023: € 3). Within 2024, the

Group completed the sale of the properties belonging to the Group's subsidiary AGI-BRE Participations 4 EOOD for a price of € 1 without significant

profit.

The properties are included in “Non-Performing Assets” segment for operating segment disclosure purposes. (note 46).

Investment securities

In the fourth quarter of 2023, the Executive Committee of the Bank approved the sale of shares measured either at fair value through profit and

loss or fair value through other comprehensive income. The fair value of the shares was determined based on offers received from investors at

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

392 | ANNUAL FINANCIAL REPORT

total of €14 resulting to the recognition of gains on financial transactions of € 7 and a gain recognized directly in Equity of € 4. The sales of the

shares were completed in February 2024.

53. Corporate events relating to the Group structure

a. 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 € 11.9 mil.

was paid in cash. It is noted that during the second quarter of 2024 the acquisition date fair value of the intangible assets acquired was re-evaluated.

More specifically, the valuation assumptions used in the first quarter were re-estimated, taking also into account the provisions included in the SPA

with UniCredit for Orange Money business. It is noted that, under the SPA, Orange Money business will be eventually transferred as part of the

Unicorn project and since the signing of the SPA is very close to the acquisition of the business by Alpha Bank Romania it was considered that the

provisions included in the SPA is an indication of the acquisition date fair value. As a result of the above re-evaluation, which led to the change of

the provisional amounts recognized in the first quarter, negative goodwill was retrospectively adjusted from € 6.6 mil. to € 0.7mil. and is recognised

in the line “Discontinued Operations” of the Consolidated Income Statement for the period ended 31.12.2024. The finalized acquisition date fair

value of the identifiable net assets acquired is presented below:

Acquisition Date Fair Value on 30.9.2024 ASSETS Cash and balances with central banks 2 Loans and advances to customers (credit cards) 11 Goodwill and other intangible assets 2 TOTAL ASSETS 15 LIABILITIES Due to customers (2) TOTAL ASSETS & LIABILITIES 13 Consideration (12) Negative goodwill 1 The fair value of Credit cards at the acquisition date of € 11.1 mil. corresponds to a contractual receivable of € 12.3 mil. decreased by the amount of

the contractual cash flows not expected to be collected of € 1.3 mil..

b. On 25.1.2024 the Bank, together with the National Bank of Greece S.A., Eurobank S.A., and Piraeus Bank S.A., established the company

Reoco Solar S.A.

c. On 20.6.2024, Alpha Services and Holdings S.A. announced the reorganization of Alpha Leasing Single Member Société Anonyme (“Alpha

Leasing”) to be effectuated by a common demerger of Alpha Leasing (the “Demerger”). The completion of the Demerger will entail :

i. the contribution of the performing leasing contracts along with the relevant real estate interests to Alpha Ereunas Agoras Single

Member S.A., a newly-established Group’s entity that will remain part of the Group and will be licensed as leasing company,

ii. the contribution of a perimeter of non-performing financial leases along with the related real estate interests with a Gross Book Value

of app. Euro 0.24 billion ("Andros portfolio"), to Hellas Capital Leasing Single Member Societe Anonyme, a Greek leasing company,

wholly owned by funds managed or advised by Bain Capital ( “HCL”),

iii. the contribution of the repossessed real estate properties of Alpha Leasing which form part of Skyline perimeter to newly established

SPV(s) and

iv. the contribution of remaining repossessed real estate properties of Alpha Leasing to newly established SPV which will remain part of

the Group.

To this end, on 19.6.2024, Alpha Leasing and its sole shareholder Alpha Holding S.A. (“Alpha Holding”) entered into a binding agreement with HCL

and its shareholder, for the disposal by Alpha Holding S.A. to HCL’s shareholder of the shareholding interest that Alpha Holding S.A. will acquire in

HCL upon completion of the Demerger, against the transfer of the Andros Portfolio to HCL.

d. On 18.6.2024 Groups’ subsidiary company Office Park I was liquidated.

e. On 27.6.2024 Group’s subsidiary company Alpha Group Real Estate Ltd, proceeded to the sale of its subsidiary AGI BRE Participations 2BG

EOOD.

f. On 28.6.2024, the joint venture of Alpha Bank Group together with Piraeus Bank Group, AEP Eleonas S.A. completed a share capital

increase partly through capitalization of debt obligations amounting to € 115,683 and partly through cash payment of € 380, i.e. through the issuance

of new shares of a total amount of € 116,064. Following the completion of the said share capital increase and the entry of the Creditor Banks into

the share capital of AEP Eleonas S.A., the participation of the shareholders in the share capital of AEP Eleonas S.A.. is as follows: New Shareholders

Alpha Bank S.A. and Piraues Bank S.A. 43.72% each, while the old Shareholders Alpha Group Investments Limited, a subsidiary company of Alpha

Bank Group and Trieris Two Real Estate Limited, a subsidiary company of Piraeus Bank Group 6.27% each. The above restructuring of AEP Eleonas'

existing bank lending was carried out in accordance with the private agreement dated 14/06/2024 between AEP Eleonas and the parties Alpha Bank

S.A., Piraeus Bank S.A., Alpha Group Investments Limited and Trieris Two Real Estate Limited.

g. On 19.8.2024 Groups’ subsidiary company Chardash Trading E.O.O.D. was sold.

h. On 4.11.2024, Alpha International Holdings S.M.S.A. ("AIH"), a wholly-owned subsidiary of Alpha Bank S.A., completed the sale of 90.1%

of Alpha Bank Romania S.A. to UniCredit S.p.A. Under the terms of the transaction, AIH acquired 9.9% of the share capital of UniCredit Bank S.A.

("UniCredit Romania"). At a later stage, Alpha Bank Romania S.A. will merge with UniCredit Romania, forming a single banking entity in which AIH

will hold 9,9%.

i. On 4.11.2024, Alpha International Holdings S.M.S.A. ("AIH"), a wholly-owned subsidiary of Alpha Bank S.A., acquired the 1% stake held by

Alpha Bank Romania S.A. in Alpha Leasing Romania IFN S.A., paying an amount of € 15,6 thds.

j. On 13.12.2024 Alpha Services and Holdings S.A. announced the initiation of the merger process by way of which Alpha Bank S.A. shall

proceed with a merger by absorption of Alpha Services and Holdings S.A. Upon completion, Alpha Bank S.A. will retain its licence as a credit

institution, succeeding by force of law and by way of a universal succession the Company in any and all of its assets and liabilities. Prior to the

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

393 | ANNUAL FINANCIAL REPORT

Merger completion, the shares of Alpha Bank, the surviving entity of the Merger, will be admitted to listing on the Athens Exchange and its

shares will be delivered upon Merger completion to the Shareholders of the Company in exchange for their shares in the Company. The

December 31, 2023 has been set as the Transformation Balance Sheet date of the Merger . On 27.2.2025 the Board of Directors of Alpha Bank

S.A and the Board of Directors of Alpha Services and Holdings approved and agreed with the publication of the Merger Documents (the Draft

Merger Agreement, the BoD Reports, the Transformation Balance Sheet and (without approval) the Independent Auditor’s Reports) and

amended the Transformation Balance Sheet date to 31.12.2024 compared to 31.12.2023 previously.

k. On 19.12.2024, the Bank established its wholly-owned subsidiary company "ABINVEST II Single Member S.A." based in Greece, paying

a share capital of Euro 52 thsd.

l. On 19.12.2024 the sale of Pernik Logistics Park E.O.O.D., AGI-BRE Bistrica E.O.O.D., AGI-BRE Vasil Levski E.O.O.D. and AGI-BRE Ekzarh

Yosif E.O.O.D. was completed.

m. On 20.12.2024, the Bank's subsidiary, Alpha Group Investments Ltd completed the sale of its 65% participation in SKYLINE REAL ESTATE

S.A. to P&E Investments Real Estate Development and Development Societe Anonyme ("P&E"), an investment company under the control of

Dimand S.A., Premia Properties REIC and the European Bank for Reconstruction and Development in the context of the SKYLINE transaction. This

transaction includes a portfolio of multi-purpose properties, including offices, commercial, residential, industrial or logistics properties,

amounting to EUR 0,3 billion. approximately (460 properties).

n. On 20.12.2024 the Bank entered into a binding agreement with a company funded by investment funds managed by companies

affiliated with Davidson Kempner Capital Management LP (the "Davidson Kempner") regarding the sale of 95% of the mezzanine and junior notes

to be issued in the context of the securitizations of two portfolios of Non-Performing Exposures with a total Gross Book Value of Euro 1,1 billion.

(the "GAIA I and GAIA II Securitisations"), serviced by "Cepal Hellas Financial Services Single Member Societe Anonyme. The Bank will hold 100%

of the senior bonds, benefiting from the provisions of the “Hercules” program, namely the Hellenic Asset Protection Scheme (“HAPS”), as well

as 5% of the medium and low senior bonds.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

394 | ANNUAL FINANCIAL REPORT

54. Discontinued Operations

The results of Alpha Bank Romania, besides the results of loans that will not be in the sale perimeter, and Alpha Life for which there is an

agreement with Unicredit are characterized as discontinued operations. Furthermore, the figures for discontinued operations also include the

results of the subsidiaries Alpha Insurance Brokers S.R.L. and Alpha Leasing Romania. Although the two subsidiaries will not be transferred to

UniCredit S.p.A., the Group is still working on the sale of the two subsidiaries and has already started seeking alternative investors. As a result

Alpha Leasing Romania and Alpha Insurance Brokers continue to be classified as held for sale and more specifically as a new distinct disposal

group, with their results presented as discontinued operations. The results arising from the said four subsidiaries are presented on aggregate

as results from discontinued operations in a separate line of the Income Statement and of the Statement of Comprehensive Income.

From 1 January to 31.12.2024 From 1 January to 31.12.2023 Alpha Alpha Alpha Alpha Alpha Alpha Alpha Insurance Alpha Insurance Total Bank Leasing Total Bank Leasing Life Brokers Life Brokers Romania Romania Romania Romania S.R.L. S.R.L. Interest and similar income 18 261 3 282 15 268 3 286 Interest expense and similar charges (8) (131) (139) (7) (116) (123) Net interest income 10 130 - 3 143 8 152 - 3 163 Fee and commission income 35 35 38 38 Commission expense (1) (9) (10) (10) (10) Net fee and commission income (1) 26 - - 25 - 28 - - 28 Dividend income - Gains less losses on derecognition of financial assets measured at - amortised cost Gains less losses on financial transactions 36 15 51 25 10 35 Other income 1 1 2 1 1 Total income from banking operations 45 172 - 4 221 33 191 - 3 227 Income from insurance contracts 9 9 5 5 Expense from insurance contracts (3) (3) (2) (2) Financial income/(expense) from insurance contracts (32) (32) (23) (23) Total income from insurance operations (26) - - - (26) (20) - - - (20) Total income from banking and insurance operations 19 172 - 4 195 13 191 - 3 207 Staff costs (57) (1) (58) (54) (54) General administrative expenses (2) (60) (62) (1) (51) (52) Depreciation and amortization - (15) (15) Total expenses (2) (117) - (1) (120) (1) (120) - - (121) Impairment losses and provisions to cover credit risk (5) (1) (6) (7) (7) Impairment losses of fixed assets and equity investments (7) (7) (15) (15) Gains/(Losses) on disposal of fixed assets and equity investments 2 2 - Provisions (14) (14) 1 1 Profit/(loss) before income tax 17 31 - 2 50 13 49 - 3 65 Income tax 7 (6) 1 1 (2) (1) Net profit/(loss) from discontinuing operations for the period after 24 25 - 2 51 14 47 - 3 64 income tax Valuation gain/(loss) after income tax 7 (1) 6 - Net profit/(loss) for the period after income tax from discontinued 24 32 - 1 57 14 47 - 3 64 operationsOther Comprehensive Income Net change in the reserve of bonds valued at fair value through the 9 3 12 36 5 41 other comprehensive income Foreign currency translation net of investment hedges of foreign 34 34 - operations Income tax (1) 8 7 (8) (1) (9) Net profit/(loss) after income tax 8 45 - - 53 28 4 - - 32

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

395 | ANNUAL FINANCIAL REPORT

55. Insurance Contract Liabilities

The following table shows the reconciliation from the opening to the closing balances of the net liability for the remaining coverage and the

liability for incurred claims for insurance contracts. It should be noted that the amounts relate to the activity of the Group's subsidiary, Alpha

Life, all of whose Assets and Liabilities are included in the balance sheet lines " Assets classified as held for sale " and “Liabilities related to

assets classified as held for sale”.

Liability for remaining Liability for Total coverage incurred claims Assets 1.1.2024 Liabilitites 1.1.2024 416 1 417 Net liability 1.1.2024 416 1 417 Changes in the statement of profit or loss New contracts and contracts measured under the full retrospective approach at transition (9) (9) Insurance revenue (9) (9) Insurance service expenses - - - Incurred claims and other insurance service expenses 2 2 Insurance service result (9) 2 (7) Insurance finance income or expenses from insurance contracts recognised in profit or loss 32 32 Total changes in the statement of profit or loss 23 2 25 Investment components excluded from insurance revenue and insurance service expenses (42) 42 - Premiums received (a) 162 162 Insurance acquisition cash flows (b) 2 2 Claims and other insurance service expenses paid (c) (44) (44) Total cash flows (a)+(b)+(c) 164 (44) 120 Net liability 31.12.2024 561 1 562 Assets 31.12.2024 Liabilitites 31.12.2024 561 1 562 Transfer from/(to) Liabilities related to assets classified as held for sale (561) (1) (562) Net liability 31.12.2024 - - - Liability for Liability for remaining incurred Total coverage claims Assets 1.1.2023 Liabilitites 1.1.2023 247 247 Net liability 1.1.2023 247 247 Changes in the statement of profit or loss New contracts and contracts measured under the full retrospective approach at transition (5) (5) Insurance revenue (5) - (5) Insurance service expenses Incurred claims and other insurance service expenses 1 1 Insurance service result (5) - (5) Insurance finance income or expenses from insurance contracts recognised in profit or loss 24 24 Total changes in the statement of profit or loss 19 1 20 Investment components excluded from insurance revenue and insurance service expenses (11) 11 - Premiums received (a) 170 170 Insurance acquisition cash flows (b) (9) (9) Claims and other insurance service expenses paid (c) (11) (11) Total cash flows (a)+(b)+(c) 161 (11) 150 Net liability 31.12.2023 416 1 417 Assets 31.12.2023 Liabilitites 31.12.2023 416 1 417 Transfer from/(to) Liabilities related to assets classified as held for sale (416) (1) (417) Net liability 31.12.2023 - - - There is no asset for insurance acquisition cashflow and no onerous contract with regards to liability for remaining coverage.

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

396 | ANNUAL FINANCIAL REPORT

The following table shows the reconciliation from the opening to the closing balances of the net insurance contract liability analysed by

components: Estimates Risk New contracts and contracts of PV of adjustment measured under the full Total future cash for non-retrospective approach at flows financial risk transition (CSM) Assets 1.1.2024 Liabilitites 1.1.2024 387 1 28 416 Net liability 1.1.2024 387 1 28 416 Changes in the statement of profit or loss - CSM recognised for services provided (3) (3) Contracts initially recognised in the year 8 - (8) - Adjustments to liabilities for incurred claims (13) 1 12 - Insurance service result (5) 1 1 (3) Insurance finance expenses from insurance contracts recognised in profit or loss 32 32 Total changes in the statement of profit or loss 27 1 1 29 Premiums received 162 162 Insurance acquisition cash flows paid (2) (2) Claims and other insurance service expenses paid (44) (44) Net Liability 31.12.2024 530 2 29 561 Assets 31.12.2024 - - - - Liabilitites 31.12.2024 531 2 30 563 Transfer from/(to) Liabilities related to assets classified as held for sale (531) (2) (30) (563) Net Liability 31.12.2024 - - - - Estimates Risk New contracts and contracts of PV of adjustment measured under the full Total future cash for non-retrospective approach at flows financial risk transition (CSM) Assets 1.1.2023 - Liabilitites 1.1.2023 225 1 21 247 Net liability 1.1.2023 225 1 21 247 Changes in the statement of profit or loss CSM recognised for services provided (4) (4) Contracts initially recognised in the year (12) 12 - Changes in estimates that adjust the CSM 1 (1) - Insurance service result (11) - 7 (4) Insurance finance expenses from insurance contracts recognised in profit or loss 23 23 Total changes in the statement of profit or loss 12 1 7 20 Cash flows - - Premiums received 170 170 Insurance acquisition cash flows paid (9) (9) Claims and other insurance service expenses paid (11) (11) Net Liability 31.12.2023 387 - 28 416 Assets 31.12.2023 - - - - Liabilitites 31.12.2023 387 1 28 416 Transfer from/(to) Liabilities related to assets classified as held for sale (387) (1) (28) (416) Net Liability 31.12.2023 - - - -

Τhe underlying items of the insurance contracts are held by the subsidiary company Alpha Life and consist of investments in mutual funds.

Insurance finance expense comprise the return on these underlying investments, that is fully attributable to the policyholders of that

contracts. Both investment return and insurance finance expense on the relating contracts are directly recognised in the income statement. Fair Value 31.12.2024 31.12.2023 Financial assets mandatorily measured at FVTPL 540 402 Total 540 402

The following table present an analysis of the insurance revenue recognised in the period. From 1 January to 31.12.2024 31.12.2023 Direct participating contracts Amounts relating to changes in liabilities for remaining coverage Expected incurred claims and other insurance service expenses 2 1 CSM recognised for services provided 6 4 Recovery of insurance acquisition cash flows 1 1 Total Insurance revenue 9 6

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

397 | ANNUAL FINANCIAL REPORT

Profitable Insurance contracts issued 31.12.2024 31.12.2023 Insurance acquisition cash flows (a) 6 2 Claims and other directly attributable expenses (b) 272 216 Estimates of present value of future cash inflows (a)+(b) 291 218 Estimates of present value of future cash inflows (291) (230) Risk adjustment for non-financial risk 595 528 Contractual Service Margin 12 12

56. Strategic Plan

The Group aims 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 priority areas from the Strategic Plan remain relevant, focusing on profits enhancement, 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.

Profitability improvement is expected across all business units elevating profits at the Group level. Favorable dynamics around net interest

income and higher Fees and Commissions will continue to drive revenues, while meticulous cost management will act as a mitigant factor

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 activities 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)

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.

The key financial priorities are summarized as per below:

Profitability

▪ Significant business profitability improvement across Business units; continuous balance sheet de-risking allows for

capital re-allocation from NPA Unit to other businesses with significant profit generation potentials

▪ Revenues increase on the back of a) strong NII performance, largely attributed to NII growth driven by volume

expansion and favorable rates and b) growing fees and commissions on the back of product penetration initiatives and

recents partnerships announced (Generali, UniCredit).

▪ Cost management limiting inflation impact, and OpEx reduction through specific levels

Balance sheet

▪ Diversified and resilient balance sheet

▪ Structural NPE reduction through organic and inorganic levels, lowering NPE ratio and improving coverage while

further de-escalating cost of risk

▪ Diversified, granular and resilient deposit base

▪ Channel liquidity to non-commercial book expansion exploring real estate and investment securities opportunities

Capital generation and distribution

▪ Healthy capital generation on the back of strong returns

▪ Maintain solid fully loaded capital ratios (FL CET1) across the period

▪ Gradual payouts increase to average European Banking levels

CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2024

398 | ANNUAL FINANCIAL REPORT

57. Events after the balance sheet date

• Under article 48 of Law 5167/2024, pricing amendments are implemented for outgoing and incoming SEPA (Single Euro Payment Area)

transfers. More specifically, a lower price list should apply per transfer order, up to a daily transfer amount limit. Additionally, all bill

payments and direct debits towards Public sector/Insurance funds, Water supply companies, Municipalities, Energy and natural gas

providers, Internet and telephony providers, Insurance companies should be free of charge. The impact of the above is estimated to be a

decrease in income of € 21 mil. annually.

• In the context of the stock option plan for the year 2020, during the exercising period of the stock options and in specific during the period

2.1.2025 until 15.1.2025, 697,462 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. The purchase amount of the above shares was paid in cash and amounted to

a total of € 0.2. On 10.2.2025 the share capital increase was registered in General Electronic Commercial Registry’s (GEMI) while on

14.2.2025 the above 697,462 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 € 683, divided into 2,353,674,756 common, nominal,

voting shares with a nominal value of € 0.29 each.

• In January 2025 the Company repurchased 5,649,854 shares with a cost of € 10 mil. and as a result the share buyback program in the