National Bank of Greece S A : 3rd PRB Report 2024

UNEP FI

Principles for Responsible Banking 3rd Self-Assessment &

Progress Report

May 2024

Contents
Introduction	4
Our purpose, vision and values	4
Our PRB roadmap	5
Principle 1: Alignment	6
1.1 Business model	6
1.2 Strategy alignment	7
Principle 2: Impact and Target Setting	10
2.1 Impact Analysis (Key Step 1)	10
2.2 Target Setting (Key Step 2)	19
2.3 Target implementation and monitoring (Key Step 2)	31
Principle 3: Clients and Customers	32
3.1 Client engagement	32
3.2 Business opportunities	35
Principle 4: Stakeholders	38
4.1 Stakeholder identification and consultation	38
Principle 5: Governance & Culture	40
5.1 Governance Structure for Implementation of the Principles	40
5.2 Promoting a culture of responsible banking:	46
5.3 Policies and due diligence processes	49
Principle 6: Transparency & Accountability	52
6.1 Assurance	52
6.2 Reporting on other frameworks	52
6.3 Outlook	53
6.4 Challenges	54
Annex	59

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Our vision is to be the "Bank of First Choice" for customers, talent, and investors.

A trustworthy, human, responsive bank, that acts as a catalyst for sustainable growth and unlocks potential for households, businesses, communities, and our employees.

Together we create Future

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Introduction

Our purpose, vision and values

In NBG, our purpose statement is "Together we create Future". Our vision is to be the "Bank of First Choice" for customers, talent, and investors. A trustworthy, human, responsive bank, that acts as a catalyst for sustainable growth, and unlocks potential for households, businesses, communities, and our people.

NBG possesses a strong legacy and resilience record of over 183 years, fostering continuous innovation and excellence in financial services. Fully aware of the significance of our role, we aim high, work as a team and strive everyday to deliver tangible results and create a more prosperous and sustainable future for all.

Looking ahead, and in line with our purpose, vision, and values, NBG is committed to embedding ESG into its business strategy, operating model, and corporate culture, in order to drive positive change in terms of environmental protection, social progress, and long-term socioeconomic stability.

We are:

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Our PRB roadmap

In September 2020, National Bank of Greece S.A. (hereinafter "NBG" or "the Bank") endorsed UNEP FI's Principles for Responsible Banking (RRB or Principles), recognizing the significance of responsible practices in ensuring the sustainability of its own operation, as well as in creating value for its customers, shareholders, employees, and the community at large. Through the Principles, NBG aims to align its strategy with the UN Sustainable Development Goals, the Paris Climate Agreement, and all ensuing European and Greek legislative frameworks. To effectively adopt the Principles within the designated four-year time frame, NBG has taken on decisive actions, as highlighted hereunder:

• Alignment: we have integrated ESG considerations into NBG's strategy and business model, articulating 9 ESG strategic themes under the E-S-G pillars, pursuing its execution via the Bank's
  Transformation Program, and monitoring its effect on the Bank's Business Plan
• Impact & target setting: following a trail of annual measurements of own operational and financed emissions footprint, and a solid understanding of key impact areas, we have set a first set of science-based targets for emissions reductions by 2030 in selected portfolios
• Clients & Customers: we have enhanced our products and services in line with our ESG strategy and goals, enabling our clients/customers with financing solutions (subsidized or not) to transition their own business models and enhance the quality of everyday life
• Stakeholders: we have maintained continuous interaction with and anticipation of our stakeholders' demands via multiple channels, as well as via regular and ad-hoc engagement instances, regarding them as the bearers of our socio-economic environment's pulse
• Governance & Culture: we have strengthened our governance framework (incl. dedicated committees, new teams/functions) to ensure effective oversight of responsible lending and investing; at the same time, training, performance management and remuneration initiatives keep enhancing internal awareness and culture around sustainability
• Transparency & accountability: we have enhanced and expanded our set of non-financial and sustainability disclosures , including a higher degree of external assurance, as in the current report

This 3rd Self-Assessment and Progress Report outlines the Bank's progress towards adoption of the Principles. More information about our ESG Strategy and underpinning actions can be found in the Annual Report FY2023, the ESG Report 2022, our public site, and other sources referenced specifically throughout this document.

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Principle 1:

Alignment

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

1.1 Business model

Describe (high-level) your bank's business model, including the main customer segments served, types of products and services provided, the main sectors and types of activities across the main geographies in which your bank operates or provides products and services. Please also quantify the information by disclosing e.g. the distribution of your bank's portfolio (%) in terms of geographies, segments (i.e. by balance sheet and/or off-balance sheet) or by disclosing the number of customers and clients served.

Response

Corporate Profile

NBG was founded in 1841 and its shares have been listed on the Athens Exchange since 1880. The Bank's headquarters are located at 86 Eolou Street, 10559 Athens, Greece. Backed by its strong tradition and noteworthy contribution to the economic transformation of Greece, and by the trust of its shareholders, customers, depositors and employees, NBG serves as a pillar of stability for the Greek economy. The Bank is one of the four systemic banks in Greece and one of the largest Greek financial institutions by market capitalization. The Bank and its subsidiaries (hereinafter the "NBG Group" or the "Group") provide a range of universal financial services including mainly retail, corporate and investment banking, transactional banking, leasing, factoring, brokerage, asset management, real estate and insurance related services.

The Group operates mainly in Greece but also abroad, through its banking subsidiaries in North Macedonia (Stopanska Banka) and in Cyprus (NBG Cyprus), with a workforce of 7.889 employees as at 31 December 2023 (of which 6.725 in Greece). As at 31 December 2023, the Bank had a total of 327 Units: 313 Branches including 18 Retail i-bank Tellerless, and 14 Transaction Offices. Through its 1,462 ATMs it offers an extensive network coverage - even in the most remote areas of the country.

The Group's domestic operations accounted for 95.1% of its total lending activities as at 31 December 2023 (the Domestic Banking gross loans) and for 96.5% of its deposits (the Domestic Banking deposits).

Links and references

NBG Annual Financial Report 2023

• NBG at a Glance, page 5
• Economic and Financial Review, pages 35-39
• Non-FinancialStatement, page 94
• Statement of Financial Position, page 184

NBG ESG Report 2022

About NBG Group, pages 21 - 27

More information is also available at NBG public

portal - ESG

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1.2 Strategy alignment

Does your corporate strategy identify and reflect sustainability as strategic priority/ies for your bank?

• Yes

• No

Please describe how your bank has aligned and/or is planning to align its strategy to be consistent with the Sustainable Development Goals (SDGs), the Paris Climate Agreement, and relevant national and regional frameworks.

Does your bank also reference any of the following frameworks or sustainability regulatory reportingrequirements in its strategic priorities or policies to implement these?

• UN Guiding Principles on Business and Human Rights

• International Labour Organization fundamental conventions

• UN Global Compact

• UN Declaration on the Rights of Indigenous Peoples

• Any applicable regulatory reporting requirements on environmental risk assessments, e.g. onclimate risk - please specify which ones: ESG Pillar III, EU Taxonomy (Regulation EU 2020/852 of the European Parliament and of the Council)
• Any applicable regulatory reporting requirements on social risk assessments, e.g. on modernslavery - please specify which ones: ESG Pillar III

☐ None of the above

Response	Links and references
NBG is aware of its growing responsibility to contribute to the	NBG Annual
achievement of Greece's long-term sustainability objectives, and to ensure	Financial Report
compliance at all times with the regulatory framework, as well as with its	2023
own voluntary-strategic commitments, including adherence to the PRB.	▪ Our Values, page 6
Endowed with a long-standing banking legacy and its capacity to channel	▪ Non-Financial Statement,
capital towards sustainable initiatives, NBG is uniquely positioned to	pages 2 - 12
contribute to the objectives of the Paris Agreement and to the Sustainable	▪ EU Taxonomy
Development Goals (SDGs), by acting upon its commitment towards an	Disclosures, page 138
inclusive society founded on human dignity, equality and sustainable	NBG ESG Report 2022
natural resource use.
	▪ Letter from the CEO,
ESG (sustainability) strategy	pages 5 - 7
▪ ESG Strategy, pages 32 -
The Bank has taken into consideration relevant ESG risks and	33
opportunities, and has integrated into its business strategy 9 actionable
ESG strategic themes. Each of these themes serves specific SDGs (as	NBG Sustainable
depicted below), while altogether serving the Bank and Group's	Development Policy
Sustainable Development Policy.
In the area of 'E', specifically, NBG has actively embarked on a journey to	Pillar III disclosures -
December 2023
sustainable, low-carbon and resilient development. As depicted in NBG's
2022 ESG Report, the Bank set and disclosed its first set of Net Zero
targets, aiming to support Greece's decarbonization agenda in line with the

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country's revised National Energy and Climate Plan, playing a pivotal role in the economy's green transition.

ESG	ESG Strategic	ESG Commitments	Our core	Sustainable
Pillar	Themes		values	Development
				Goals

Environmental

Social

	Pioneer sustainable
	bond issuing in the
	Greek market
Lead the market	Growth
in sustainable
energy financing	Lead the
	development of the
	renewable energy
	sector
	Support green
	transition of
Accelerate	corporates	Growth
transition to a
sustainable	Lead green retail	Responsive
economy	financing &	-ness
	sustainable
	investments
	Establish a carbon-
Role-model	neutral NBG
footprint
environmentally
responsible
Protect biodiversity
practices
and ecosystem
	health
	Establish equality in
Champion	the workplace
diversity &
inclusion	Promote inclusion
	in the society
	Protect the health
	and family life of
Enable public	our people
health & well-
being	Enable public
	health, well-being
	and sports
	Lead the	Human -
	preservation of	Centricity
	Greek cultural
Promote Greek	heritage
heritage, culture
& creativity	Promote
	contemporary
	Greek culture and
	creativity
	Foster
	entrepreneurship
Foster	and innovation
entrepreneurship
& innovation	Motivate public
	contribution to
	new projects

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Governance

	Encourage lifelong
Support	learning in and out
of the workplace
prosperity
through learning	Champion digital
& digital literacy
literacy across age
	groups
	Ensure best-in-
	class corporate
Adhere to the	governance
highest		Trust
governance	Ensure
standards	transparency in
	disclosures and
	reporting

Sustainable Development (Sustainability) Policy

NBG constantly seeks to ensure that it substantially and positively impacts the economies and societies where it operates, through its activities (i.e., the provision of its products and services), its role as an employer, as well as via deploying its Corporate Social Responsibility ("CSR") actions. NBG's Bank

• Group Sustainability Policy defines the direction to maximising economic, environmental, social and governance benefit, while setting the framework for managing economic, environmental, social and governance impacts of the Bank and the Group, via:

1. reducing and, where possible, offsetting climate and environmental impacts from financing and investing, and from own operations
2. generating long-term value for stakeholders, the economy at large, and the communities where NBG's Group companies operate in Greece and abroad
3. undertaking initiative in the fields of Corporate Governance, Corporate Social Responsibility and Business Ethics, in addition to ensuring compliance with the legal and regulatory framework for these issues
4. protecting the reputation and reliability of the Group and strengthening
   NBG's renewed value system.

Other applicable regulatory reporting on C&E risks

NBG adheres to regulatory reporting and relevant disclosures requirements, such as the recurring Pillar III disclosures, in particular the dedicated ESG Risks chapter and respective tables, as per EBA's ITS guidelines. In parallel NBG is preparing for the full adoption of the EU Taxonomy (and all related Delegated Acts), in the meantime issuing -as required, via a phased-in approach- its first 2 Taxonomy indicators: GAR based on Turnover and GAR based on Capex.

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Principle 2:

Impact and Target Setting

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

2.1 Impact Analysis (Key Step 1)

Show that your bank has performed an impact analysis of its portfolio/s to identify its most significantimpact areas and determine priority areas for target-setting.The impact analysis shall be updated regularly1 and fulfil the following requirements/elements (a-d)2:

1. Scope:What is the scope of your bank's impact analysis? Please describe which parts of the bank's core business areas, products/services across the main geographies that the bank operates in (as described under 1.1) have been considered in the impact analysis. Please also describe which areas have not yet been included, and why.

Response

PRB Portfolio Impact Analysis

We recognize the importance of comprehending the impacts of our financing activity on our socio-economic environment, as a mechanism of informing and steering our overall ESG strategy. Therefore, per our commitment to the PRB, we are regularly conducting an in-depth impact analysis to identify positive and negative impacts of our Corporate, Business and Retail lending.

Similarly to previous reports, we are using the Portfolio Impact Analysis Tools for Banks. In this 3rd self-assessment report, we have increased the

scope of conducting impact analysis with portfolio data (exposures) in NBG Factors and NBG Leasing, in Cyprus, and in North Macedonia.

It is noted that NBG's activities in Greece include the Bank's domestic operations, Ethniki Leasing S.A and Ethniki Factors S.A., with the Group's domestic operations accounting for 95.1% of total lending activities, as at 31 December 2023.

The investment banking business was considered, but not included in the analysis, as its incremental impact would not differentiate the results. It will be reconsidered in future analyses.

Links and references

NBG Annual Financial Report 2023

• Business Overview, p.36- 40
• Activities outside Greece, p.51

1. Portfolio composition:Has your bank considered the composition of its portfolio (in %) in the analysis? Please provide proportional composition of your portfolio globally and per geographical scope
2. 1. by sectors & industries3 for business, corporate and investment banking portfolios (i.e. sector exposure or industry breakdown in %), and/or
   2. by products & services and by types of customers for consumer and retail banking portfolios.

1. That means that where the initial impact analysis has been carried out in a previous period, the information should be updated accordingly, the scope expanded as well as the quality of the impact analysis improved over time.
2. Further guidance can be found in theInteractive Guidance on impact analysis and target setting.
3. 'Key sectors' relative to different impact areas, i.e. those sectors whose positive and negative impacts are particularly strong, are particularly relevant here.

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