ANNUAL FINANCIAL REPORT
FOR THE YEAR ENDED
31 DECEMBER 2025
According to
Article 4 of the Law 3556/2007
Table of Contents
Index to the Annual Financial Report
Page
A.
Statements of members of the Board of Directors
3
B.
Report of the Directors for the year ended 31 December 2025
4
Attachments to the Report of the Directors
I.
Corporate Governance Statement
30
II.
Sustainability Statement
114
III.
Additional information related to sustainability
336
C.
Audit Committee Activity Report
340
D.
Financial Statements for the year ended 31 December 2025
I.
Consolidated Financial Statements of the Bank
351
II.
Financial Statements οf the Bank
535
E. Auditor’s reports
I.
Ιndependent Auditor’s Report
680
II.
Independent Auditor’s Limited Assurance Report on
Sustainability Statement
691
F.
Information of Eurobank S.Α. group for the year ended 31
December
2025
pursuant to article 6 of l. 4374/2016
695
Statements of Members of the Board of Directors
(according to the article 4 par. 2 of the Law 3556/2007)
We declare that to the best of our knowledge:
●
the annual financial statements for the fiscal year ended 31 December 2025, which have been
prepared in accordance with the applicable set of accounting standards, honestly and accurately
reflect the assets and liabilities, the equity and the annual results of operations of Eurobank S.A.,
as well as the companies included in the consolidation considered as a whole, and
●
the report of the Board of Directors fairly reflects the development and performance of the
business and the position of Eurobank S.A., as well as the companies included in the consolidation
considered as a whole, along with a description of the main risks and uncertainties they face. The
sustainability statement attached to the report of the Board of Directors has been prepared in
accordance with the sustainability reporting standards referred to in Article 154A of Law 4548/2018
and with the specifications approved pursuant to paragraph 4 of Article 8 of Regulation (EU)
2020/852 of the European Parliament and of the Council of 18 June 2020, establishing a framework
to facilitate sustainable investments and amending Regulation (EU) 2019/2088.
Athens, 5 March 2026
Georgios P. Zanias
I.D. No A 02555306
CHAIRMAN
OF THE BOARD OF
DIRECTORS
Fokion C. Karavias
I.D. No Α 02555309
CHIEF EXECUTIVE OFFICER
Stavros E. Ioannou
I.D. No A 00546500
DEPUTY
CHIEF EXECUTIVE OFFICER
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The Directors present their report together with the financial statements for the year ended 31 December 2025.
1. General information
In December 2025, the merger by absorption of “Eurobank Ergasias Services and Holdings S.A.” (Eurobank Holdings or the Company)
by “Eurobank S.A.” (Eurobank or the Bank) was completed and Eurobank S.A. became the ultimate parent company of the Group
(further information is provided in section 8 below). The Bank along with its subsidiaries (the Group) are active in retail and corporate
banking, asset management and private banking, treasury and capital markets, investment property and insurance services, and
operate mainly in Greece, Bulgaria, Cyprus and Luxembourg. The Bank is incorporated in Greece, and its shares are listed on the
Athens Stock Exchange and the Cyprus Stock Exchange.
2. Financial Results Review and Outlook
2.1 Financial Review
In 2025, the macroeconomic backdrop remained positive across the Group’s three core markets - Greece, Cyprus and Bulgaria- despite
prevailing global risks and a volatile international environment. The Group further expanded its business footprint, including through
the acquisition of CNP Cyprus Insurance, and continued to deliver solid performance across most areas. It demonstrated strong core
profitability, increased its loan and deposit portfolios, and maintained resilient capital adequacy, a strong liquidity position, and high
asset quality, while also rewarding its shareholders and contributing to local economies and society.
As at 31 December 2025, the Group’s total assets increased by €6.8bn to €108bn (Dec. 2024: €101.2bn), with gross customer loans
amounting to €56bn (Dec. 2024: €52.3bn) and investment securities reaching €24.9bn (Dec. 2024: €22.2bn). Out of the total loan
portfolio, €33.4bn has been originated from Greek operations (Dec. 2024: €30.5bn), €18.6bn from international operations (Dec.
2024: €17.4bn) and €4bn refer to notes from securitizations of loans originated by the Group (Dec. 2024: €4.4bn). Business (wholesale
and small business) loans stood at €34.3bn (Dec. 2024: €30.9bn) and accounted for 61% of total Group loans, while loans to
households reached €17.7bn (Dec. 2024: €17bn), of which 73% is the mortgage portfolio and the rest are consumer loans. Group
deposits stood at €82.7bn (Dec. 2024: €78.6bn) with those from Greek operations amounting to €45.2bn (Dec. 2024: €43.3bn), while
international operations contributed with €37.5bn (Dec. 2024: €35.3bn). As a result, the (net) loan –to–deposit (L/D) ratio stood at
66.1% for the Group (Dec. 2024: 64.8%) and at 80.3% for Greek operations (Dec. 2024: 77.8%).
During the year, as part of the medium-term strategy to ensure ongoing compliance with the Minimum Requirements for Eligible
Own Funds and Eligible Liabilities (MREL) as well as capital adequacy requirements, in January 2025 the Company issued €0.6bn
subordinated Tier 2 notes, including €189m issued pursuant to the exchange offer for the outstanding Tier 2 notes of former Hellenic
Bank (currently Eurobank Limited). In February 2025 the Bank issued €350m senior preferred notes through a private placement,
while in the third quarter 2025, it proceeded with a €700m issuance of senior preferred notes, including an additional issue of €200m
through private placement. In September 2025, the Group proceeded with the early redemption of the Tier 2 capital instruments of
€950m issued to Hellenic Republic in 2018. More recently, in January 2026, the Bank completed the issue of a €400m subordinated
Tier II debt instrument (note 4 and 33 to the consolidated financial statements). In parallel, in line with Group’s strategy to further
optimize its capital structure and enhance its capacity to support future strategic initiatives, Eurobank Holdings proceeded with the
issuance of €500m and €600m fixed rate reset Additional Tier 1 perpetual contingent temporary write-down notes in June and
November 2025, respectively (note 4 and 40 to the consolidated financial statements). The Group Liquidity Coverage Ratio (LCR)
stood at 172.2% (31 December 2024: 188.2%). The Bank’s LCR reached 187.8% (31 December 2024: 180.5%).
Pre-provision Income (PPI) amounted to €2,145m or €2,114m excluding the €58m gain on acquisition of former CNP Cyprus subgroup
(currently
ERB Cyprus Insurance Holdings Ltd and its subsidiaries)
infrastructure projects primarily related to the school renovation program (2024: €2,242m or €2,170m excluding a) the €99.5m gain
on acquisition of an additional shareholding in Hellenic Bank and b) the €27m estimated cost for contribution mainly to the school
renovations program), while core pre-provision income (Core PPI) slightly decreased by 1.9% year-on-year to €2,034m or €2,061m
excluding the €27m contribution as above (2024: €2,074m or 2,101m excluding the €27m contribution as above). Net interest income
(NII) increased slightly by 1.7% to €2,549m (2024: €2,507m), primarily attributable to the consolidation of former Hellenic Bank
(currently Eurobank Limited) from the third quarter of 2024 and supported by loan growth and increased positions in investment
bonds, partially offset by the lower average interest rates. Net interest margin (NIM) stood at 2.48% (2024: 2.73%) with the fourth
quarter reaching 2.45%. Fees and commissions expanded by 15.7% to €770m (2024: €666m), of which a) banking fees and
commissions by 12.5% to €631m (2024: €561m), mainly due to the consolidation of Hellenic Bank, as above, and the increased fees
from asset management, capital markets activity and credit/debit cards business, b) net insurance income of €44m (2024: €8m)
attributed to the consolidation of the insurance entities of Hellenic Bank from the third quarter of 2024 and former CNP Cyprus
1
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subgroup as of the second quarter of 2025 and c) rental income from real estate properties of €95m (2024: €97m). Fees and
commissions over assets accounted for 75bps (2024: 73bps) with the fourth quarter reaching 81bps. Operating expenses, excluding
the €27m contribution as above, increased by 17.4% to €1,258m (2024: €1,071m) due to the impact of Hellenic Bank consolidation
from the third quarter of 2024, the higher staff costs, the inflationary pressures and the higher IT investments. Costs from
international operations amounted to €544m (2024: €408m), while in Greece increased by 7.7% to €714m (2024: €663m). The cost
to income (C/I) ratio for the Group reached 37.3%, excluding the €58m gain on acquisition and the €27m contribution, as mentioned
above (2024: 33%, excluding the €99.5m gain on acquisition and the €27m contribution, as mentioned above), while the international
operations C/I ratio stood at 35.9% (2024: 32.4%). The cost to core income ratio, excluding the contribution to Greek State’s
infrastructure projects, for the Group stood at 37.9% (2024: 33.8%).
Trading and other activities recorded net income of €111m (2024: €168m net income) of which a) €70m gains on investment securities
(2024: €13m gains) (note 9 to the consolidated financial statements), b) €28m loss from derivative financial instruments within net
trading income (2024: €84m gain) (note 9 to the consolidated financial statements), and c) €67m net other income (2024: €61m net
other income, of which €99.5m gain on acquisition stated above), including inter alia i) the €58m gain on acquisition of the
CNP Cyprus
Insurance Holdings Ltd
, ii) the €34m fair value gains on investment property, iii) the €30m derecognition loss on loans measured at
amortized cost, iv) the €26m claimed amount related to the Special Defence Contribution (SDC) that had been withheld and paid in
Cyprus by Hellenic Bank, and v) the €10m buy-back loss for the Hellenic Bank subordinated Tier 2 notes (note 10 to the consolidated
financial statements)
During the year, the Group’s NPE formation was positive by €147m (31 December 2024: €222m positive). In total, the Group’s NPE
stock stood at €1.4bn (31 December 2024: €1.5bn, excluding the €0.2bn NPE of Hellenic Bank covered by the Asset Protection Scheme
(APS)) with the NPE ratio standing at 2.6% (31 December 2024: 2.9%). In December 2025, in the context of the NPE deleveraging
strategy, the Group initiated the disposal process for a secured retail NPE portfolio of €126m (note 20 to the consolidated financial
statements). The loan provisions (charge), excluding the €71m impairments for held for sale loans-related projects reached €308m
and corresponded to 0.59% of average net loans (2024: €319m which corresponded to 0.69% of average net loans), while the NPE
coverage ratio improved to 95.2% (31 December 2024: 88.4%). As a result, “net” NPEs amounted to €69m (31 December 2024:
€177m).
The Group recognized in 2025 restructuring costs and other impairments amounting to €97m (2024: €228m, including €161m VES-
related), of which €38m for Voluntary Exit Schemes (VES) and related costs, mainly referring to the scheme that was launched by
Hellenic Bank in February 2025 for employees of the bank and its insurance subsidiaries, while €18m related to the Group’s corporate
reorganization and integration of its business operations in Cyprus (note 12 to the consolidated financial statements). Moreover, it
recognized a loss of €13m (€9m net of tax) in relation to the sale of a Bank’s former subsidiary, previously presented as a discontinued
operation, pursuant to specific indemnity clauses included in the relevant Sale Purchase Agreement (2024: €7m loss net of tax) (note
30 to the consolidated financial statements). The Group’s share of results from associates/JVs amounted to €47m income (2024:
€161m income) (note 24 to the consolidated financial statements), while the special tax levy applicable to the Group’s banking entities
in Cyprus stood at €35m (2024: €22m). In accordance with the Pillar Two legislation, the Group has also recognized a current tax
expense of €17m (2024: €22m) related to the top up tax applicable on the profits earned for its operations in Bulgaria and Cyprus
(note 13 to the consolidated financial statements).
Profit or Loss
Overall, in 2025, the net profit attributable to equity holders of the parent company amounted to €1,362m (2024: €1,448m profit),
as set out in the consolidated income statement, while the Bank’s net profit amounted to €675m (2024: €669m). The adjusted net
profit, which excludes a) the €55m restructuring costs (after tax), mainly related to VES, b) the €58m gain on acquisition of the CNP
Cyprus subgroup, c) the €50m impairment (after tax) for the HFS loans-related projects, d) the €19m estimated cost (after tax) for the
contribution to Greek State’s infrastructure projects primarily related to the school renovation program, e) the €25m income related
to recognition of deferred tax asset on previous years temporary differences, and f) the €9m net loss (after tax) from discontinued
operations, amounted to €1,412m (2024: €1,484m). The contribution of international operations to the adjusted net profit amounted
to €741m (2024: €709m profit).
Based on the Group’s profits for 2025, the Basic Earnings per Share (EPS) reached €0.37 (2024: €0.40) and the Return (adjusted profit)
on Tangible Book Value (RoTBV) amounted to 16% (2024: 18.5%).
Capital adequacy
As at 31 December 2025, the Group’s Total Regulatory Capital amounted to €10.4bn (31 December 2024: €9.1bn), including, inter
alia, the impact of (a) the accrual for profit payout (subject to regulatory and AGM approvals in relation to 2025 financial year) and
(b) the issuance of €500m and €600m of AT1 Capital instruments in June and November 2025, respectively and accounted for 19.5%
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(total CAD) of Risk Weighted Assets (RWA) (Dec. 2024: 18.2%), compared to the CAD Overall Capital Requirements (OCR
) ratio of
15.28%. Respectively, the Common Equity Tier 1 (CET1) stood at 15.2% of RWA (Dec. 2024: 15.4%) compared to the CET1 OCR ratio
of 10.53% or 10.98%, including the Tier 2 capital shortfall. Pro-forma for the completion of the project “Sun (ex-Solar)”and the “Wave
III” upsize, the total CAD and CET1 ratios would be 20% and 15.6%, respectively (note 4 to the consolidated financial statements). At
the same date, the total CAD and CET1 ratios of the Bank stood at 19.8% (Dec. 2024: 19.8%) compared to CAD OCR ratio of 11.94%
and 13.9% (Dec.2024: 16.3%) compared to CET1 OCR ratio of 8.44%, respectively.
As at 31 December 2025, the Bank’s MREL ratio at consolidated level stands at 29.39% of RWAs, after deducting the payout accrual
(Dec. 2024: 27.36%). Pro-forma with the completion of the project “Sun (ex-Solar)” and the “Wave III” upsize, the Bank’s MREL ratio
at consolidated level stands at 30.17% of RWAs (note 4 to the consolidated financial statements).
Pursuant to the Regulation (EU) No 575/2013 (CRR), the deferred tax assets (DTAs) that rely on future profitability and exceed certain
limits shall be deducted in the calculation of the CET1 capital. This deduction should be applied gradually by 2025. The enactment of
the article 27A of Law 4172/2013, as in force, provided for the Greek credit institutions that the eligible DTAs are accounted on a) the
losses from the Private Sector Involvement (PSI) and the Greek State Debt Buyback Program and b) on the sum of (i) the unamortized
part of the crystallized loan losses from write-offs and disposals, (ii) the accounting debt write-offs and (iii) the remaining accumulated
provisions and other losses in general due to credit risk recorded up to 30 June 2015 and can be converted into directly enforceable
claims (tax credits) against the Greek State, provided that the Bank’s after tax accounting result for the period is a loss. This legislative
provision enabled the Greek credit institutions, including the Bank, not to deduct the eligible DTAs from CET1 capital but recognise
them as a 100% risk-weighted asset, with a positive effect on the capital position. A potential change in the regulatory treatment of
eligible DTAs as tax credits may have an adverse effect in the Group’s capital position.
As of 31 December 2025, in line with the Bank's initiative to enhance the quality of its regulatory capital, the amortisation of Deferred
tax credits (DTC) against the Greek State amounting to €2,832m at the end of the year (31 December 2024: €3,022m), has been
accelerated for regulatory purposes. As a result, as at 31 December 2025, the DTC included in the calculation of the Group’s capital
ratios stand at €2,624m representing 32.3% of CET 1 capital.
Law 5264/25 for loans denominated in CHF
On 19 December 2025, Law 5264/25 was voted by the Greek parliament, giving the option to performing retail borrowers to convert
their lending exposures denominated in CHF to Euro, under favorable terms that vary based on the borrowers’ financial profile. In
particular, the lending exposures will be converted to Euro at a preferential exchange rate (ie. a discount to the current market
exchange rate will be applied that ranges between 15%-50%), whereas following the conversion into Euro, the loans will bear a fixed
interest rate that ranges between 2.3%-2.9%. In addition, upon borrowers' request, the repayment of the converted loan exposures
may be extended by 5yrs. The Law is immediately effective for borrowers eligible for a 15% discount in exchange rate and 2.9% fixed
interest rate, whereas for the remaining categories it is enacted in February 2026.
As at 31 December 2025, the gross carrying amount of the Group’s retail loans denominated in CHF that may receive the Law’s
beneficial terms amounted to ca. €1,580m with provisions coverage in Greece reaching 19%. Further information is provided in note
20 to the consolidated financial statements.
2.2. Financial Outlook and Objectives
Going forward, the Group pursues its key financial objectives outlined in the business plan for the period 2026-2028, including the
delivery of a sustainable RoTBV of at least 16% and 17% in 2028 and the generation of sufficient organic capital to a) support business
growth, b) maintain adequate capital buffers and improve capital quality through accelerated DTC amortization, c) further enhance
shareholders reward with a payout ratio above 50% over the next years, subject to regulatory approval, and d) finance strategic
initiatives in banking, insurance and asset management. These financial objectives will be achieved mainly through the following
initiatives and actions:
a)
Maintain high NII mainly driven by the organic loan growth in all three core markets and across segments (households and
business) and by utilizing excess liquidity through investment in high quality debt securities, which may offset the pressures
from the increasing competition for good quality corporate customers and the issuance of MREL eligible senior and Tier 2
notes,
b)
Strengthening core markets presence and increasing earnings and volumes contribution by international activities, which
will be further supported by the full realization of synergies arising from the Hellenic Bank - Eurobank Cyprus and the Cypriot
insurance companies’ mergers over the coming years (see section 4),
2
The ‘Overall capital requirement (OCR) is the sum of the total SREP capital requirement (TSCR) and the combined buffer requirement (CBR).
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c)
Growth of fee and commission income in a number of fee business segments and mainly asset management, insurance,
bancassurance and wealth management activities, which will be enhanced through the 100% acquisition and consolidation
of Eurolife FFH life Insurance,
d)
Discipline to operating expenses’ targets mainly expressed in the form of cost to income through initiatives for cost
containment of “run the bank” activities, and further simplification and digitalization in Greece and abroad, and despite the
higher staff costs including the talent retention cost, the inflationary pressures, and the “grow the bank” needs including
higher IT investments,
e)
Maintaining low NPE ratios across all core markets in which the Group has a presence, which may be challenged mainly by
the behavior of legacy portfolio,
f)
Major transformation initiatives introduced in the context of the Group’s transformation plan “Eurobank 2030” (see below
section 3),
The geopolitical and macroeconomic risks set a number of challenges to the achievement of the Group’s 2026-2028 Business Plan.
These challenges mainly related to economic growth resilience in Greece post RRF, lending margins, deposit rates, asset quality and
operating costs. The headwinds coming from the geopolitical upheaval and the macroeconomic environment are likely to be mitigated
by:
a)
The growth of GDP in Group’s core markets at levels higher than EU average, supported by the positive impact of the efficient
mobilization of EU funding from sources other than the RRF,
b)
The further decrease of the unemployment rate in Greece in 2026, which is expected to reach close to historical lows as well
as its continued low levels in both Bulgaria and Cyprus,
c)
The positive developments in the tourism sector and the strong investment inflows in Greece and Cyprus,
d)
The fiscal discipline in Greece and the ongoing reduction in debt to GDP ratio, both of which support a solid fiscal outlook
for the coming years,
e)
The investment grade rating of the Greek sovereign by the five Eurosystem-approved External Credit Assessment
Institutions,
f)
The euro adoption in Bulgaria and the related investment upside, macroeconomic improvement and financial stability,
g)
The enhanced role of Cyprus in the context of recent geopolitical developments in the region.
(see also further information in the section 7 “Macroeconomic Outlook and Risks”)
Agreement with Fairfax for the acquisition of Eurolife FFH Life Insurance and the partial disposal of ERB Asfalistiki Ltd
On 13 October 2025, Eurobank Holdings and the Bank, announced that Eurobank Holdings has signed a term sheet with Fairfax
Financial Holdings Limited (“Fairfax”) pursuant to which Eurobank shall acquire 80% of the life insurance business (“Eurolife Life”)
(the Transaction) for a cash consideration of €813m. Following this acquisition, Eurobank will hold 100% of Eurolife Life and will retain
its 20% interest in Eurolife Holdings’ general insurance business (“Eurolife General Insurance”). Eurolife Life stands as a leading life
insurer in Greece, holding a market share of c. 21%, while for 2025, it is projected to achieve gross written premiums of c. €600m.
The Transaction will enable Eurobank to enhance its profitability base by fully consolidating Eurolife Life’s financial results, further
diversify its revenue streams through increased fees and commissions, and maximize the potential of its bancassurance platform.
In addition to the aforementioned Transaction, Fairfax shall procure that certain affiliates of Fairfax will acquire 45% of the share
capital of ERB Asfalistiki (“ERBA”), the non-life (property and casualty) insurance company of Eurobank Limited in Cyprus, for a cash
consideration of €59m. Fairfax will also have the right to acquire the remaining 55% of the share capital of ERBA over time. This
strategic partnership will allow both companies to combine their strengths in underwriting, risk management, and product
development, driving greater operational efficiency and unlocking new market opportunities in Greece and Cyprus.
The above transactions are expected to increase Eurobank Group’s fees and commissions by c. 12%, driving the contribution of asset
management and insurance to total fees, in excess of 30%.
The signing of both share purchase agreements is expected within the first quarter of 2026, whilst their completion within the second
quarter of 2026 subject to the required approvals from the relevant authorities and the process for related party transactions.
Further information is available in the relevant announcement on the Bank’s website.
3. Group’s transformation plan “Eurobank 2030”
The “Eurobank 2030” Transformation Program was established to pivot focus towards business growth, capitalize on the anticipated
Greek economic recovery and the Bank’s strengths in its core market, and address the major opportunities and challenges faced by
banks globally to enhance Eurobank’s competitive position.
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Having completed the first 3-year cycle of the program, the Bank concluded a strategic review (Transformation 2.0) and continues its
transformation, focusing on developing its digital offering to serve customers and deepen relationships, build new business via
ecosystem partnerships, deploy AI and GenAI solutions to drive efficiency and effectiveness, optimize the operating model to
accelerate time to market, and modernize its core IT systems.
2025 was the first full year of Transformation 2.0, with strong momentum across key strategic initiatives. Major accomplishments
include:
a)
Establishment of the Digital Leader Incubator, enabling accelerated release cycles and delivery of market-leading digital
features
b)
Formation of a dedicated Embedded Banking unit, with partnerships and commercial collaborations underway
c)
Initial steps in CIB international expansion and exploration of new models for cross-border growth
d)
Set up of AI Factory and hub & spoke model, and launch of the EVA customer digital assistant
e)
Approval of core architecture modernization strategy and vendor selection for next generation platforms
f)
Establishment of initial “value streams” implementing a new operating model in selected business areas, and design of a
revamped CIB service model.
In parallel, key initiatives from the first transformation cycle were completed, including the launch of several new digital offerings
(e.g., new mobile application for under-18s, Personal Financial Management platform, virtual debit card, mass-segment investment
offering via the Everyday Invest product), technology enhancements in internal processes (e.g. new mortgage loan origination
platform), and completion of the planned migration to cloud for in-scope IT applications.
A structured governance framework is in place to manage the Transformation program implementation, coordinated by a central
Transformation Office. The Chief Transformation Officer reports directly to the CEO, who is actively leading efforts and sets the tone
to the entire organization.
In parallel, transformative initiatives are underway in Luxemburg, Cyprus and Bulgaria:
a)
In Luxemburg, Salamis is a front-to-back business transformation program to replace legacy IT systems with new state-of-
the-art banking applications that will allow the Bank to achieve its business objectives. The new platform went live in 2025,
and post Salamis go-live optimizations are now underway.
b)
In Cyprus, following the legal mergers between Hellenic Bank and Eurobank Cyprus and between the insurance companies
of Hellenic Bank and CNP (section 4 below), operational merger implementation is currently underway to provide unified
platforms to the new entities.
c)
In Bulgaria, Postbank completed successfully the migration to the euro and has launched a digital transformation program
to empower customers with innovative, fully integrated digital financial solutions.
4. International Operations
The Group has a significant presence in three countries apart from Greece. In Cyprus, Eurobank Ltd (see below) operates in total a
network of 71 branches and business centres. Eurobank Ltd offers a comprehensive suite of financial products and services, leveraging
diverse expertise and capabilities. The financial offerings are designed to address both corporate and retail client needs, ensuring that
both individuals and businesses have access to comprehensive and tailored solutions, covering everyday banking requirements as
well as advanced investment management strategies.
In Luxembourg, Eurobank Private Bank Luxembourg S.A. in parallel to its operations in Luxembourg, also maintains a branch in London
and in Athens. The bank offers an extensive range of products and services in Private Banking, Wealth Management & Investment
Fund Services, as well as selected Corporate Banking services. In Bulgaria, Eurobank Bulgaria AD (Postbank), is a fully fledged multi
service bank, with an extensive branch network, advanced digital service channels and a substantial client base of individuals,
businesses and institutions. Postbank holds strong positions in retail and wholesale banking, offering a broad spectrum of products
and services, through its network of 196 branches and business centres.
The Eurobank’s subsidiaries operate with the highest standards of transparency and credibility, underpinned by robust and
contemporary corporate governance frameworks. Driven by a customer-centric philosophy, they are dedicated to delivering
exceptional products and services that support both individual and business clients, while simultaneously contributing to broader
economic advancement. Their commitment to continuous improvement ensures that they remain agile and responsive, proactively
embracing the challenges of a dynamic environment by accelerating digital transformation and promoting the green transition, all
with a clear focus on sustainable and responsible growth.
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International operations are strategically positioned at the forefront of technological innovation, leveraging state-of-the-art systems
and pioneering digital solutions to address the evolving needs of clients and set new benchmarks in customer experience.
International operations are not only a cornerstone of the Group’s competitive edge but also serve as key pillar supporting Group
profitability. Their strategic vision is founded on the principles of adaptability, growth, and long-term profitability, all while fostering
sustainable prosperity within local communities and generating value for clients, employees, shareholders, and society as a whole.
In response to the gradual eastward shift of global trade and economic activity, the Group is selectively monitoring and assessing
developments across the Eastern Mediterranean, Middle East and South Asia, as part of its overall strategy for international activities.
The aim is to expand to strategic markets intending to unlock new growth opportunities by attracting new clients and further diversify
its geographic footprint.
Hellenic Bank Public Company Ltd, Cyprus (“Hellenic Bank”)
Hellenic Bank group, which was accounted for as a Group’s associate under the equity method from April 2023 until 30 June 2024,
was included in the Eurobank Holdings’ consolidated financial statements from the beginning of the third quarter of 2024 (detailed
information is provided in note 23.2 of the consolidated financial statements for the year ended 31 December 2024).
On 11 February 2025, after the receipt of the relevant regulatory approvals, the acquisition of a total 37.51% stake in Hellenic Bank
was completed resulting in the Bank’s total holding in Hellenic Bank at 93.47%.
Following that and pursuant to the provisions of the Takeover Bids Law in Cyprus, the Bank also announced the submission of a
Mandatory Takeover Bid to the shareholders of Hellenic Bank for the acquisition of up to 100% of its issued share capital for a
consideration of € 4.843 per share. The acceptance period of the Takeover Bid commenced on 11 March 2025 and ended on 9 April
2025.
On 25 April 2025, the Bank announced that the total percentage of acceptance of the Takeover Bid reached 4.525%, as the valid
Acceptance and Transfer Forms submitted were for 18,678,262 shares resulting in the Bank’s total participation of 97.994% in the
issued share capital of Hellenic Bank. Moreover, on 28 April 2025, the Bank applied to the Cyprus Securities and Exchange Commission
for the exercise of the Squeeze Out right provided by Article 36 of the Takeover Bids Law, for the acquisition of the remaining shares
of Hellenic Bank.
On 11 June 2025, the Bank announced the completion of the Squeeze Out procedure. It acquired the remaining 8,279,967 shares of
Hellenic Bank, representing 2.006% of its issued share capital, at the price of € 4.843 per share. Following this transaction, the Bank’s
holding in the company’s share capital reached 100%.
Detailed information about the corporate actions in relation to Hellenic Bank is provided in note 23.3 to the consolidated financial
statements.
Acquisition of CNP Cyprus Insurance Holdings Limited
On 16 April 2025, Hellenic Bank announced that following the receipt of all relevant regulatory approvals, the acquisition of the entire
share capital of CNP Cyprus Insurance Holdings Limited from CNP Assurances (the “Transaction”) was completed, for a total cash
consideration of €182m. As of May 2025, the acquired entity has been renamed ERB Cyprus Insurance Holdings Limited.
The Transaction is in line with Eurobank’s strategic objective to expand in the Cypriot insurance market. The acquired entity
’s
subsidiaries hold a leading position in Cyprus in the insurance sector and offer life and general insurance products and services
through a large network of independent agents. The Transaction is expected to further expand and strengthen Hellenic Bank’s existing
position in the insurance market, increasing significantly its market shares in the life and general insurance sectors.
Detailed information in relation to the acquisition of CNP Cyprus Insurance Holdings Limited is provided in note 23.4 to the
consolidated financial statements.
Merger of Hellenic Bank Public Company Limited and Eurobank Cyprus Ltd, Cyprus
On 29 August 2025, the Bank announced the receipt of all required regulatory approvals for the merger of its wholly owned
subsidiaries in Cyprus, i.e. Hellenic Bank and Eurobank Cyprus. Effective 1 September 2025, and in accordance with the Cyprio
t
Transfer of Banking Business and Collateral Law of 1997, all assets and liabilities of Eurobank Cyprus were transferred to Hellenic
Bank. The transaction was executed through the issuance of new common shares by Hellenic Bank to Eurobank Cyprus, representing
36.15% of its share capital, while the remaining 63.85% was held by Eurobank S.A. Following the transaction, Eurobank Cyprus Ltd
was renamed to ERB Cyprus Holdings Ltd and Hellenic Bank Public Company Limited was renamed to Eurobank Limited.
On 3 December 2025, the merger of the two organizations was completed. On the same date, the share capital of Eurobank Limited
was reduced by €116.8m corresponding to the shares held by ERB Cyprus Holdings, which were cancelled and b) increased by the
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same amount through the issuance of an equivalent number of shares allocated to Eurobank S.A.. As a result of these corporate
actions, Eurobank S.A. became the sole shareholder of Eurobank Limited and ERB Cyprus Holdings Ltd was dissolved.
The merger of the two organizations is in line with the Bank’s strategy to create a single, strong and modern financial institution,
which will be able to provide upgraded banking and insurance services to its customers, contributing to the development of the
Cypriot economy.
Merger of Group’s Cypriot insurance companies
In October 2025, the merger of the Group’s Cypriot insurance companies was completed. This involved the transfer of all insurance
portfolios, assets, and liabilities of Hellenic Life Insurance Company Ltd and Pancyprian Insurance Ltd to ERB Cyprialife Ltd and ERB
Asfalistiki Ltd, respectively.
5. Risk management
The Group acknowledges that taking risks is an integral part of its operations in order to achieve its business objectives. Therefore,
the Group’s management sets adequate mechanisms to identify those risks at an early stage and assesses their potential impact on
the achievement of these objectives.
Due to the fact that economic, industry, regulatory and operating conditions will continue to change, risk management mechanisms
are set in a manner that enable the Group to identify and deal with the risks associated with those changes. The Group’s structure,
internal processes and existing control mechanisms ensure both the independence principle and the exercise of sufficient supervision.
The Group's Management considers effective risk management as a top priority, as well as a major competitive advantage, for the
organization. As such, the Group has allocated significant resources for upgrading and maintaining its policies, methods and
infrastructure up to date, in order to ensure compliance with the requirements of the European Central Bank (ECB) and of the Single
Resolution Board (SRB), the guidelines of the European Banking Authority (EBA) and the Basel Committee for Banking Supervision as
well as the best international banking practices. The Group implements a well-structured credit approval process, independent credit
reviews and effective risk management policies for all material risks it is exposed to, both in Greece and in each country of its
international operations. The risk management policies implemented by the Group are reviewed on a regular basis.
Risk culture is a foundational element of the Group’s operations, encompassing the norms, attitudes, and behaviors that guide risk
awareness, risk-taking, and risk management. The Group is committed to fostering a robust risk culture that prioritizes the proactive
identification, assessment, management and mitigation of all financial and non-financial risks. The Risk Management function
provides a comprehensive framework, procedures, and guidance to enable all employees to proactively identify, manage and monitor
the risks in their own areas, and improve the control and coordination of risk-taking across their business. This includes ongoing
education and focused training throughout the organisation on risk management principles, communication and awareness
initiatives, taking place via dedicated learning programs, monthly meetings, and the sharing of best practices. A strong risk culture is
reinforced by the Group’s Board of Directors and Senior Management, who set the appropriate “Tone from the Top” to align risk
practices with strategic objectives.
Risk culture is also embedded in the Group’s product governance. A dedicated policy is in place to address risks associated with the
introduction, significant modifications, and periodic monitoring of products and services. The Group operates a robust governance
framework throughout the product and service lifecycle, where material financial and non-financial risks are assessed by the relevant
Group Risk Management units and other Second Line of Defence functions.
The amount of risk which the Group is willing to assume in the pursuit of its strategic objectives is articulated via a set of quantitative
and qualitative statements for risks assessed as material, that are described in the Group’s Risk Appetite Framework. The objectives
are to support the Group’s business growth, balance a strong capital position with higher returns on equity and to ensure the Group’s
adherence to regulatory requirements. The Risk Appetite that is clearly communicated throughout the Group determines risk culture
and forms the basis on which risk policies and risk limits are established at Group and regional level. Aiming to identify relevant and
material risks the Bank maintains a well-defined Risk Identification and Materiality Assessment (RIMA) Framework. The identification
and the assessment of all risks is the cornerstone for the effective Risk Management. The Group aiming to ensure a collective view
on the risks linked to the execution of its strategy, acknowledges the new developments at an early stage and assesses the potential
impact.
The Board Risk Committee (BRC) is a committee of the Board of Directors (BoD) and its task is to advise and support the BoD regarding
the monitoring of Group’s overall actual and future risk appetite and strategy, taking into account all types of risks to ensure that they
are in line with the business strategy, objectives, corporate culture and values of the institution. The BRC assists the BoD in overseeing
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the implementation of Group’s risk strategy and the corresponding limits set. It also oversees the implementation of the strategies
for capital and liquidity risk management as well as for all material risks,including financial and non-financial risks, indicatively credit
risk, market risk, interest rate risk and credit spread risk in the banking book, counterparty risk, operational risk, climate risk, country
risk, reputational risks, conduct risk, risks stemming from strategic projects, in order to assess their adequacy against the approved
risk appetite limits. The BRC consists of five (5) non-executive directors, meets at least 10 times per year and reports to the BoD on a
quarterly basis and on ad hoc instances if it is needed.
The Management Risk Committee (MRC) is a management committee established by the Chief Executive Officer (CEO) and its main
responsibility is to oversee the risk management framework of the Bank. As part of its responsibilities, the MRC facilitates reporting
to the BRC on the range of risk-related topics under its purview. The MRC proactively supports the Group Chief Risk Officer, Chairman
of the MRC, to identify material risks, in addition to those identified independently by the Group CRO and the Group Risk
Management, and to promptly escalate them to the BRC and assists the Group CRO in ensuring that the necessary policies and
procedures are in place to prudently manage risk and to comply with regulatory requirements.
The Group’s Risk Management which is headed by the Group Chief Risk Officer (GCRO), operates independently from the business
units and is responsible for the identification, assessment, monitoring, measurement and management of the risks that the Group is
exposed to. It comprises the Group Credit (GC), the Group Credit Control (GCC), the Group Credit Risk Capital Adequacy Contro
l
(GCRCAC), the Group Market and Counterparty Risk (GMCR), the Group Operational and Non-Financial Risks (GONFR), the Group
Model and Data Validation (GMDV), the Group Risk Management Strategy & Oversight (GRMS&O), the Group Sustainability Risk
(GSR), the Supervisory Relations and Resolution Planning (SRRP), and the Risk Analytics (RA) Units.
The Group applies the elements of the Three Lines of Defense model for the effective management of all types of risk. The Three
Lines of Defense Model enhances risk management and control by clarifying roles and responsibilities within the organization. Under
the oversight and direction of the Management Body, the responsibilities of each of these lines of defense are:
Line 1 - Own and manage risk and controls. The front line business and operations are accountable for this responsibility as they own
the rewards and are the primary risk takers,
Line 2 - Monitor risk and controls in support of Executive Management, providing oversight, challenge, advice and group-wide
direction. These mainly include the Risk and Compliance Units,
Line 3 - Provide independent assurance to the Board and Executive Management concerning the effectiveness of risk and control
management. This refers to Internal Audit.
Furthermore, the Group continues the process of aligning the former Hellenic Bank (currently Eurobank Ltd) risk management policies
and practices with those of the Group across key risk types, following the acquisition of control in the third quarter of 2024 and the
completion of the Take Over Bid process in the first half of 2025 which resulted in the acquisition of 100% of the entity’s shares. This
is in line with the policies alignment process that takes place with all international subsidiaries and includes harmonizing key risk
policies, standardizing regulatory as well as internal risk reporting, and aligning risk methodologies.
The most important types of risk that are addressed by the risk management functions of the Group are:
Credit Risk
Credit risk is the risk that a counterparty will be unable to fulfil its payment obligations in full when due. Credit risk is also related with
country risk and settlement risk. Credit risk arises principally from the wholesale and retail lending activities of the Group, as well as
from credit enhancements provided, such as financial guarantees and letters of credit. The Group is also exposed to credit risk arising
from other activities such as investments in debt securities, trading, capital markets and settlement activities. Taking into account
that credit risk is the primary risk the Group is exposed to, it is very closely managed and monitored by specialised risk units, reporting
to the GCRO.
The credit review and approval processes are centralized both in Greece and in the International operations following the “four-eyes”
principle and specific guidelines stipulated in the Credit Policy Manual and the Risk Appetite Framework. The segregation of duties
ensures independence among executives responsible for the customer relationship, the approval process and the loan disbursement,
as well as monitoring of the loan during its lifecycle. The credit approval process in Corporate Banking is centralized through the
establishment of Credit Committees with escalating Credit Approval Levels, which assess and limit to the extent possible the corporate
credit risk. Rating models are used in order to calculate the credit rating of corporate customers, reflecting the underlying credit risk.
The most significant ones are the MRA (Moody’s Risk Analyst) applied for companies -mostly- with industrial and commercial activity,
the RiskCalc (international rating model) used for assessing the creditworthiness of international lending - primarily companies
located and operating abroad - and the slotting rating models, used for specialised lending portfolios (shipping, real estate and project
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finance) with ring-fenced transactions. Credit risk assessment is performed by Group Credit (GC), which assesses the credit requests
submitted by the Business Units, a procedure including the evaluation of the operational and financial profile of the customer, the
validation of the borrower’s rating and the identification of potential risk factors for the Bank.
The credit review and approval processes for loans to Small Businesses (turnover up to €5m which will be increased to €10m in 2026)
are also centralised following specific guidelines and applying the ‘four-eyes’ principle. The assessment is primarily based on the
analysis of the borrower's operational characteristics and financial position. The same applies for Individual Banking (consumer and
mortgage loans), where the credit risk assessment is based on criteria related to the characteristics of the retail portfolio, such as the
financial position of the borrower, the payment behaviour, the existence of real estate property and the type and quality of securities.
The ongoing monitoring of the portfolio quality and of any deviations that may arise, lead to an immediate adjustment of the credit
policy and procedures, when deemed necessary. The quality of the Group’s loan portfolios (business, consumer and mortgage in
Greece and abroad) is monitored and assessed by the Group Credit Control (GCC) via field, desktop, thematic reviews as well as
statistical analysis in order to timely identify emerging risks, vulnerabilities, compliance to credit policies and consistency in
underwriting. Furthermore, the GCC assumes oversight and supervisory responsibilities for proper operation of credit rating and
impairment models in co-operation with GCRCAC. Moreover, GCC regularly reviews the adequacy of provisions of all loan portfolios.
The Unit also formulates Group’s credit policies, reviews policies developed by other units and participates in the development of
new loan products. In addition, GCC contributes to the overall credit risk management strategy of the Group, ensuring alignment with
business objectives and regulatory requirements. It also prepares and submits regular reports to senior management and relevant
committees, providing insights on portfolio quality, emerging risks and policy effectiveness. Finally, it monitors regulatory
developments, emerging trends and best practices proposing relevant policy updates or product enhancements when necessary. GCC
operates independently from all the business units of the Bank and reports directly to the GCRO.
The measurement, monitoring and periodic reporting of the Group’s exposure to counterparty risk (issuer risk and market driven
counterparty risk), which is the risk of loss due to the customer’s failure to meet its contractual obligations in the context of treasury
positions, such as debt securities, derivatives, repos, reverse repos, interbank placings, etc. are performed by the Group Market and
Counterparty Risk (GMCR). The Group sets limits on the level of counterparty risk that are based mainly on the counterparty’s credit
rating, as provided by international rating agencies, the product type and the maturity of the transaction (e.g. control limits on net
open derivative positions by both amount and term, sovereign bonds exposure, corporate securities, asset backed securities, etc.).
GMCR maintains and updates the limits’ monitoring systems and ensures the correctness and compliance of all financial institutions
limits with the Bank’s policies as approved by the Group’s relevant bodies. The utilization of the abovementioned limits, any excess
of them, as well as the aggregate exposure per Group’s entity, counterparty and product type are monitored by GMCR on a daily
basis. The Group applies the regulatory framework for the counterparty risk from derivatives Standardised Approach for measuring
counterparty credit risk (SA-CCR).
Market Risk
The Group has exposure to market risk, which is the risk of potential financial loss due to an adverse change in market variables.
Changes in interest rates, foreign exchange rates, credit spreads, equity prices and other relevant factors, such as the implied
volatilities, can affect the Group’s income or the fair value of its financial instruments. The market risks, the Group is exposed to, are
monitored, controlled and estimated by GMCR. GMCR is responsible for the measurement, monitoring, control and reporting of the
exposure on market risks including the Interest Rate Risk and the Credit Spread Risk in the Banking Book (IRRBB/CSRBB) of the Group.
The GMCR reports to the GCRO. The exposures and the utilisation of the limits are reported to the Board Risk Committee and to the
BoD.
Market risk in Greece and International Subsidiaries is managed and monitored mainly using Value at Risk (VaR) methodology,
sensitivity and stress test analysis. VaR is a methodology used in measuring financial risk by estimating the potential negative change
in the market value of a portfolio at a given confidence level and over a specified time horizon. The VaR that the Group measures is
an estimate based upon a 99% confidence level and a holding period of 1 day and the methodology used for the calculation is Monte
Carlo simulation (full re-pricing of the positions is performed). Since VaR constitutes an integral part of the Group's market risk control
regime, VaR limits have been established for all portfolios (trading and investment) measured at fair value and actual exposure is
monitored daily by management. However, the use of this approach does not prevent losses outside of these limits in the event of
extraordinary market movements. For that reason, the Group uses additional monitoring metrics such as: Stressed VaR, Expected
Shortfall and Stress Tests. Finally, the Group already monitors the impact from the new regulatory framework for market risk
(Fundamental Review of the Trading Book-FRTB) and monitors the evolution of the relevant capital charges until its official application
(2027) based on a set of established systems and procedures.
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Interest Rate Risk in the Banking Book (IRRBB)
The IRRBB is defined as the current and the prospective risk of a negative impact to the institution’s economic value of equity, or to
the institution’s net interest income, taking market value changes into account as appropriate, which arise from adverse movements
in interest rates affecting interest rate sensitive instruments, including gap risk, basis risk and option risk.
GMCR is the unit responsible for the monitoring, control, reporting and estimation of IRRBB on a group level. Both the Economic
Value of Equity (EVE) and NII sensitivity to a number of stresses on interest rates are estimated on a periodic basis and are compared
with the approved BoD Risk Appetite Statements (RAS) thresholds. IRRBB analysis currently uses the established Asset and Liability
Management (ALM) tools within each entity. The plan is to expand the use of the ALM tool applied on a solo level (in Greece) for the
future Group-level IRRBB analysis. The CSRBB analysis is conducted on a Group level by a centralized tool. Furthermore, the Group
already applies a set of extra stress test analysis for specific parts of its Banking Book for the assessment to the exposure on Mark-to-
Market (MTM) volatility on both OCI and Amortised Cost portfolios of investment securities and for the assessment of the CSRBB
(Credit Spread Risk in the Banking Book). The policy for the management of IRRBB as approved by BRC and BoD provides a clear
description of the methodologies, the governance, the limits that are used for the management of IRRBB & CSRBB.
Liquidity Risk
The Group is exposed on a daily basis to liquidity risk due to deposits withdrawals, maturity of medium or long term notes, maturity
of secured or unsecured funding (interbank repos and money market takings), collateral revaluation as a result of market movements,
loan draw-downs and forfeiture of guarantees. The Board Risk Committee and the BoD sets in the RAS Framework the liquidity risk
thresholds to ensure that sufficient funds are available to meet all of these contingencies under any scenario. The Group monitors on
a continuous basis the level of liquidity risk using regulatory and internal metrics and methodologies (Liquidity Coverage Ratio/LCR,
Net Stable Funding Ratio/NSFR, Liquidity Buffer analysis, cash flow analysis, short-term and medium-term stress test etc.).
BRC’s role is to approve all strategic liquidity risk management decisions and monitor the quantitative and qualitative aspects of
liquidity risk. Group Assets and Liabilities Committee (G-ALCO) has the mandate to form and implement the liquidity policies and
guidelines in conformity with Group's risk appetite, and to review at least monthly the overall liquidity position of the Group. Group
Treasury is responsible for the implementation of the Group's liquidity strategy, the daily management of the Group’s liquidity and
for the preparation and monitoring of the Group’s liquidity budget, while GMCR is responsible for measuring, control, monitoring and
reporting the liquidity of the Group to the G-ALCO, BRC, BoD and to the regulatory bodies.
Operational & Non-Financial Risks (NFRs)
Non-Financial Risks include operational risks as well as specific additional risks such as business, strategic and reputational risk.
Operational risk is defined by Basel III as the risk of loss resulting from inadequate or failed internal processes, people and systems or
from external events.
Governance responsibility for Non-Financial Risks management stems from the Board of Directors (BoD), through the Executive Board
and Senior Management, and passes down to the Heads and staff of every business unit. The BoD establishes the mechanisms used
by the Group to manage NFRs, sets the tone and expectations, and delegates relevant responsibilities. The Board Risk Committee and
the Audit Committee monitor the NFR levels and profile, including relevant events.
NFR management comprises risk identification, assessment, and mitigation while employing independent oversight and an effective
risk culture to ensure that business objectives are met within the NFR appetite that is reflected in the Group’s Policies and Guidelines.
The Heads of each business unit (the risk owners) are primarily responsible for the day-to-day management of NFRs and the
adherence to relevant controls. Each Business Unit appoints an Operational Risk Partner (OpRisk Partner) or an Operational Ri
sk
Management Unit (ORMU) depending on the size of the business unit, which is responsible for coordinating the internal risk
management efforts of the business unit while forming the link between Line 1 and Line 2.
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Eurobank has adopted a Themes-based risk taxonomy, developed along the lines of the industry reference taxonomies, for risk
management and reporting purposes. Each Risk Themes is overseen by Theme Coordinators (Second Line of Defense Units). The Risk
Themes which fall within the scope of NFR are the following:
Group Operational and Non-Financial Risks Unit (GONFR) is responsible for establishing an effective operational and non-financial risk
management framework for the Group, aligned with best practices, and for overseeing its implementation across the Group. GONFR
acts as an overlaying framework coordinator for all Non-Financial Risks (NFRs). GONFR’s overlaying responsibilities aim to harmonize
the Second Line of Defense Units’ activities across the Group and to holistically ensure the effective, consistent application of the Risk
Appetite Framework. The 2LoD Units maintain their responsibilities for specific Risk Theme(s) owned.
The Group has fully implemented the Risk Appetite Framework across the Group to cover NFRs. The Group’s Risk Appetite Framework
addresses NFRs by defining acceptable risk limits and ensuring the risk profile stays within those boundaries.
Additionally, GONFR, as the owner of the Products & Services Governance Policy, is responsible for overseeing and ensuring the
effective implementation of the governance framework for all products and services throughout their lifecycle across the Group. This
framework supports the comprehensive assessment of both financial and nonfinancial risks, while also incorporating financial
performance considerations. The Policy sets out the review process for products and services, including the evaluation of climate-
related and environmental risks, as well as their alignment with the Bank’s Sustainable Finance Framework (SFF).
Sustainability risks
Sustainability risks are neither new nor stand-alone risks, rather they are transverse risks, manifesting through existing risk types.
Overall, they comprise: (i) climate -related and environmental risks, (ii) social risks, and (iii) governance risks. As sustainability risks
interact with other risks and result in direct distributional impacts and indirect macroeconomic impacts, the Group understands that
careful consideration of the cross-cutting nature thereof is necessary to ensure the optimal implementation of adaptation activities.
Specifically, sustainability risks are defined as potential losses arising from any negative financial impact for the Group, stemming
from current or prospective impacts of any climate-related & environmental, social or governance factors on the Group’s
counterparties or invested assets.
The Group is adopting a strategic approach towards sustainability and climate related risk management, signifying the great
importance that is given in the risks and opportunities arising from the transitioning to a low-carbon and more circular economy. In
this context, the Bank has approved and implements its Financed Impact Strategy, which focuses on:
a)
Client engagement and awareness – Helping clients transition to more sustainable business models by raising awareness of
climate change challenges and opportunities.
b)
Supporting clients in transition – Facilitating the transition of clients towards sustainable practices by offering eligible
financing solutions under the Bank’s SFF.
c)
Enablers and tools for sustainable financing – Providing frameworks, tools, and products to underpin sustainable financing.
d)
Assessment and management of sustainability-related risks – Identifying and managing the sustainability-related risks within
its loan and investment portfolios, including assessing exposure to transition and physical risks linked to climate change.
The Group has developed a Sustainable Finance Framework (SFF) to define eligible green and social assets as well as classify
sustainable lending solutions. Additionally, its Sustainable Investment Framework (SIF) sets out sustainable investment strat egies,
selection criteria and monitoring practices aligned with international market practices.
Furthermore, the Group maintains its Sustainability Governance structure with clearly defined roles and responsibilities supporting
the roll-out of the Sustainability Strategy and the integration of sustainability risks, through the involvement of various key
stakeholders (i.e. Business & Risk Units, Committees, etc.). The Group applies an established model of defined roles and
responsibilities regarding the management of Sustainability risks and aspects across the 3 Lines of Defense.
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The Group also maintains a Sustainability Risk Management Policy which aims at fostering a holistic understanding of the effects of
sustainability risks on its business model, as well as support decision-making regarding these matters and provide a robust governance
under its Risk Management Framework. The purpose of the Policy is to provide an overview and a common understanding of Group’s
main governance arrangements, as well as roles & responsibilities undertaken by the Group Sustainability Risk (GSR), in the context
of the Group’s overall Sustainability risks management activities.
The GSR has the overall responsibility for overseeing, monitoring, and managing sustainability risks. More specifically, the GSR
prepares and maintains the Group’s sustainability risk management policies, processes and methodologies, in collaboration with the
Group Sustainability Unit, and the Business and Risk Units. In addition, it leads the development and implementation of the
sustainability risk related framework, policies and processes as well as acts, monitors and reports to the Group Senior Sustainability
Officer (GSSO) the progress of the implementation of the Climate Risk action plan and reports the progress of the implementation of
the developed climate risk action plan, and reports to the Board for Sustainability Risk matters. The GSR monitors and challenges the
involved stakeholders in setting Net Zero targets and the Financed Impact Strategy, and reports financing targets and KPIs. The GSR
also leads the 2nd line of defense independent sustainable lending re-assessment process against the Sustainable Finance criteria,
including the classification of Retail Portfolio products as sustainable. Additionally, the Unit reviews and confirms the ESG Risk
Assessment and challenges the mitigation actions. Furthermore, the GSR develops and maintains the Climate Risk Stress Testing
(CRST) Framework, as well as the Scenario Analysis and Stress Testing methodologies, and coordinates the performance of
sustainability risk scenario analysis and relevant stress test exercises at Group level.
Further information on the Group’s financial risk management objectives and policies, including the policy for hedging each major
type of transaction for which hedge accounting is used is set out in the notes 2, 5 and 19 to the consolidated financial statements for
the year ended 31 December 2025 and as regards sustainability risks is provided in the Group’s Sustainability Statement as at 31
December 2025. Information on insurance risks and the risk management governance of the Group insurance entities is set out in the
note 35.2 to the consolidated financial statements for the year ended 31 December 2025.
6. Non Performing Exposures (NPE) management
The Bank realizes the NPE Strategy Plan through its implementation by doValue Greece for the assigned portfolio and the
securitization transactions.
Troubled Assets Committee
The Troubled Assets Committee (TAC) is established according to the regulatory provisions and its main purpose is to act as an
independent body, closely monitoring the Bank’s troubled assets portfolio and the execution of its NPE Management Strategy.
Remedial and Servicing Strategy (RSS)
The Remedial Servicing and Strategy (RSS) is responsible for:
a) the management of the non-performing and early arrears loans of Eurobank and the relevant communication with the regulator
b) structured transactions which create capital (such as Synthetic SRT STS securitizations) and/or offer credit protection and c)
cooperation with the other units of Group Strategy for other transactions initiatives and (d) communication cooperation with the
regulators on all relevant matters always in conjunction with the other relevant units of the Bank such as Group Risk and Group
Finance.
RSS is closely monitoring the overall performance of the NPE portfolio as well as the relationship of the Bank with doValue Greece.
Furthermore, following Eurobank’s commitments to preserve significant risk transfer (SRT) through the monitoring of regulatory
requirements pertaining to Bank’s concluded transactions, RSS has a pivotal role in ensuring that relevant process is performed
smoothly and in a timely manner and that any shortcomings are appropriately resolved, while providing any required clarifications or
additional material required by the regulatory authorities. The Head of RSS reports to the General Manager of Group Strategy.
In this context, RSS has been assigned inter alia with the following responsibilities:
a)
Sourcing new transactions and performing the execution of any transaction processes, by also establishing negotiation of
Commercial / Legal Terms as well monitoring of these transactions,
b)
Develop and actively monitor the NPE targets and reduction plan,
c)
Set the strategic principles, priorities, policy framework and KPIs under which doValue Greece is servicing the portfolio,
d)
Closely monitor the execution of the approved strategies, as well as all contractual provisions under the relevant contractual
agreements for Eurobank’s portfolio assigned to doValue Greece including the securitized portfolio of ERB Recovery DAC,
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e)
Monitoring of the performance of the senior notes of the securitizations in collaboration with Group Risk so as to ensure
compliance to significant risk transfer (SRT) and to the Hellenic Asset Protection Scheme (HAPS),
f)
Budget and monitor the Bank’s expenses and revenues associated with the assigned portfolio,
g)
Cooperate closely with doValue Greece on a daily basis in achieving the Group’s objectives,
h)
Maintain supervisory dialogue
Project Sun (ex - Solar)
In the context of its NPE management strategy, the Group had participated, since 2018, in a joint initiative with the other Greek
systemic banks, to structure an NPE securitization transaction (project ‘Solar’) under the provisions of Hellenic Asset Protection
Scheme (HAPS), that was finally abandoned in the first half of 2025. As Management remained committed to its plan to recover the
carrying amount of the respective loan portfolio through its disposal, the Group retained the classification of the underlying loans as
held for sale. In December 2025, the negotiations with potential investors regarding the sale of the portfolio were concluded and the
sale and legal transfer is expected to be completed within the first half of 2026. At 31 December 2025, the carrying amount of the
“Sun” loan portfolio reached €18 m.
Project Moon
In December 2025, the Group, as part of its ongoing NPE deleveraging strategy, initiated a structured process for the disposal of a
portfolio of secured non-performing retail exposures of gross carrying amount of ca. €126m. As at the reporting date, given the
Management’s commitment to the abovementioned portfolio’s disposal plan that is expected to be completed by the end of 2026,
the Group classified the respective loans as held for sale. At 31 December 2025, the carrying amount of the “Moon” loan portfolio
reached €61m.
Project Leon
With regard to project “Leon”, in December 2023, the Group, in the context of its NPE reduction plan, initiated the sale process of a
mixed NPE loan portfolio that was concluded on 13 September 2024 via a securitization structure (SPV-LEON CAPITAL FINANCE DAC)
under the requirements of Hellenic Asset Protection Scheme law.
Accordingly, as of the aforementioned date, the Group
derecognized the underlying loan portfolio and recognized the retained notes on its balance sheet, i.e. 100% of the senior and 5% of
the mezzanine and junior notes of Leon securitization, at fair value, which as at 31 December 2025 stood at €274m (31 December
2024: €276m). In April 2025, the Group obtained the HAPS approval for the senior note and in June 2025 the confirmation by EC
B
regarding the significant risk transfer (SRT) recognition for the “Leon” loan portfolio.
Other loans held for sale
As of 31 December 2025, the Group classified its loan exposure to the Avramar Group, of €68m carrying amount, as held for sale, on
the grounds that it considers the sale highly probable given the existence of an active disposal plan, jointly undertaken by all syndicate
lenders, and the ongoing negotiations with potential investors. The sale transaction is expected to be completed within the first half
of 2026.
Eurobank Limited agreement with KEDIPES
In April 2025, Eurobank Limited (former Hellenic Bank) announced that it has signed a pre-settlement agreement with the Cyprus
Asset Management Company Limited (“KEDIPES”) for the buyback by KEDIPES of a portfolio of non-performing exposures of net
carrying amount €192m (with reference date 30 September 2024) at a consideration of €180m, the termination of the Asset
Protection Scheme (“APS”) which was granted in 2018 as part of the acquisition of a loan portfolio of the former Cyprus Cooperative
Bank (“CCB”) for an amount of €17.5m payable to Eurobank Limited, and the settlement of disputes arising from the agreement to
acquire certain assets and liabilities of CCB for an amount of €10 m payable to Eurobank Limited (the “Transaction”). In September
2025, the respective Transaction agreements between Eurobank Limited and KEDIPES were signed, following the approvals granted
by the Ministry of Finance and the Directorate-General for Competition. The Transaction was subject to customary approvals including
the Cyprus Commission for the Protection of Competition. Since 30 September 2025, the loan portfolio under sale and the
corresponding indemnification asset arising from the APS in total, were classified as held for sale. At 31 December 2025, the carrying
amount of the loan portfolio reached €108m. On 30 January 2026, following the receipt of the remaining customary regulatory
approvals, the Transaction between KEDIPES and Eurobank Limited was completed resulting in the non-performing loans’
derecognition and the termination of APS scheme.
Further information regarding the aforementioned loan-related initiatives and transactions is provided in note 20 to the consolidated
financial statements.
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7. Macroeconomic Outlook and Risks
Global economic environment in 2025
In a volatile international environment in 2025, macroeconomic conditions remained supportive in the Group’s three core markets.
In the first three quarters of 2025 the economies of Greece, Bulgaria and Cyprus exhibited remarkable resilience, sustaining their
expansionary momentum and overperforming compared to most of their European Union (EU) peers.
Global growth held up despite restrictive elevated geopolitical risk and renewed trade frictions. The United States remained the main
anchor of global activity, supported by robust household balance sheets, fiscal support and a surge in AI-related capital expenditure,
even as job growth slowed and inflation proved sticky. Europe experienced uneven but improving momentum, with domestic demand
gradually strengthening against a backdrop of easing inflation and monetary relaxation (ECB cut its deposit facility rate by an
additional 100 basis points), while structural and fiscal constraints continued to cap upside in some economies. China remained an
important component of global growth but was beset by structural challenges: weak property markets, subdued domestic demand
and deflationary pressures were only partially offset by strong exports and industrial competitiveness. Across regions, 2025 was
marked by a gradual shift away from synchronized global cycles toward greater divergence, with AI investment, fiscal policy choices
and trade dynamics increasingly determining relative economic performance.
Greece
According to Hellenic Statistical Authority (ELSTAT) provisional estimates, the real GDP of Greece grew by 2.0% on an annual basis in
the first three quarters of 2025 –versus 1.5% in the euro area (Eurostat)– driven by household consumption (+2.5% year-on-year,
contributing 1.8 percentage points to the GDP growth rate) and net exports (-16.6% year-on-year, contributing 1.4 percentage points
to the GDP growth rate). The average annual inflation rate based on the Harmonized Index of Consumer Prices (HICP) stood at 2.9%
in 2025, broadly unchanged from 3.0% in 2024. The average unemployment rate declined to a 17-year low of 8.8% in 2025, from
10.1% in 2024.
In its Autumn Economic Forecasts (November 2025), the European Commission (EC) expects a real GDP growth of 2.1% in 2025 and
2.2% in 2026 (2024: 2.1%). In 2026, inflation is expected to decelerate to 2.3%, and the unemployment rate to decline to 8.6%. On
the fiscal front, the EC forecasts a primary surplus of 4.3% of GDP in 2025 and 3.4% in 2026, from 4.7% of GDP in 2024. The gross
public debt-to-GDP ratio, following a sizeable increase in nominal GDP due to the combination of real GDP growth and inflation, is
expected to decline to 147.6% in 2025 and 142.1% in 2026, from 154.2% in 2024 (Table 1).
Table 1
2024A
2025E
2026E
GDP growth (real, %)
2.1
2.1
2.2
Inflation (HICP, avg % change)
3.0
2.3
Unemployment (% labor force, avg)
10.1
9.3
8.6
General Govt Primary Balance (%GDP)
4.7
4.3
3.4
Gross Public Debt (%GDP)
154.2
147.6
142.1
*actual.
Sources: Eurostat, European Commission (European Economic Forecasts, Autumn 2025)
According to Bank of Greece (BoG) data, the stock of credit to the non-financial private sector amounted to €119.8bn at the end of
2025, up from €113.3bn a year earlier, marking a gross annual increase of 5.7%. Adjusted for write-offs, reclassifications and foreign
exchange fluctuations, the annual growth rate of domestic credit to the non-financial sector stood at 8.0%. On the other side of the
ledger, domestic non-financial private sector deposits were up by 4.9% year-on-year, standing at €209.2bn at the end of 2025, from
€199.4bn at the end of 2024. On real estate market developments, BoG data shows that residential real estate prices recorded
an
annual increase of 7.5% in the first three quarters of 2025, and commercial real estate prices an annual increase of 5.2% in the first
half of 2025.
Growth in Greece as well as in Bulgaria and Cyprus is expected to receive a significant boost from EU-funded investment projects and
reforms. Greece is to receive €36bn (€18.2bn in grants and €17.7bn in loans) up to 2026 through the Recovery and Resilience Facility
(RRF), Next Generation EU’s (NGEU) largest instrument, out of which €23.4bn (€12.0bn in grants and €11.4bn in loans) had been
disbursed by the EU as of end-January 2026. A further €40bn is due through EU’s long-term budget (MFF), out of which €20.9bn is to
fund the National Strategic Reference Frameworks (ESPA 2021–2027).
In 2025, the Greek government raised €7.7bn from the international financial markets through the Public Debt Management Agency
(PDMA) by issuing a new 10-year bond at a yield of 3.637% --that subsequently reopened twice– and reopening three outstanding
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issues with maturities ranging from 5 to 30 years. At the end of 2025, the cash reserves of the Greek government stood close to
€39bn. Following a series of sovereign rating upgrades between 2023 and 2025, the Greek government long-term debt securities
were rated as investment grade by all five Eurosystem-accepted External Credit Assessment Institutions as of end-January 2026: DBRS
(BBB, stable outlook); Fitch (BBB, stable outlook); Moody’s (Βaa3, stable outlook); Scope (BBB, positive outlook); and S&P (BBB, stable
outlook).
Bulgaria
Political uncertainty re-intensified in late 2025, following the resignation of the government on 11 December amid widespread
protests against the proposed 2026 budget, paving the way for another parliamentary election. This development did not affect
Bulgaria’s euro area accession on 1 January 2026.Parliamentary elections are most likely to be held in the second half of March or the
first half of April. Real economic growth remained resilient through the first three quarters of 2025, reaching 3.4%, compared with
3% in the previous year. GDP growth was driven primarily by domestic demand. Household consumption expanded by 8.2%,
supported by an exceptionally tight labour market, with the unemployment rate declining to 3.5%—the lowest level in at least 23
years. Gross capital formation increased by 9%, underpinned by strong credit growth, with lending to non-financial corporates up
5.5% and housing credit rising by 26.8% in January–September. By contrast, net exports weighed on growth, as imports increased by
3.5% while exports contracted by 4.6%. According to the European Commission’s Autumn Economic Forecast, GDP growth is expected
to decelerate to 3% in 2025 and 2.7% in 2026, from 3.4% in 2024. Private consumption growth is projected to moderate, reflecting
slower growth in wages and social transfers. In contrast, private investment is expected to remain supportive of economic activity,
driven by improving business confidence in the context of euro adoption and by the acceleration in EU funds absorption that began
in the fourth quarter of 2025. Export growth is forecast to resume toward the end of 2025 and continue into 2026; however, imports
are also expected to rise, reflecting strong domestic demand and higher defence-related spending under the EU Security Action for
Europe (SAFE) programme. In December, Scope Ratings affirmed Bulgaria’s sovereign rating at A-, maintaining a stable outlook.
Adoption of the euro in Bulgaria in 2026
Following the approval on 8 July 2025 by the Economic and Financial Affairs Council of three legislative acts confirming Bulgaria’s
accession to the single currency, the country became the 21st member of the euro area on 1 January 2026. Ahead of the formal
approval of euro area entry, headline inflation began to accelerate moderately from May 2025, reaching 3.4% in July, up from 2.8%
in April. In response, amendments to the euro adoption law were passed in early August, introducing enhanced price-monitoring
measures through July 2026. Notably, the revised framework granted the Council of Ministers the authority to implement additional
anti-speculation measures targeting essential goods and services, if necessary, without requiring parliamentary approval. Following
the full implementation of the anti-speculation measures in October, inflation entered a mild decelerating trend in fourth quarter
2025, easing to 3.5% in December. Furthermore, in the first month after the euro adoption, inflation decelerated to 2.3%, a 13-month
low, according to the flash estimate. The slowdown in January is mainly due to energy deflation, by 1.8%, versus a mild inflationary
trend in the fourth quarter of 2025 (+2.0%), and food disinflation (4.7% vs. 6.2% in the fourth quarter). Provided that the January
inflation is sustained in the following months or weakens further, in combination with the 12.6% increase in the minimum wage and
the decided by the ministerial council 5% raise in civil servants salaries from January 1, 2026, it will support household real disposable
income.
Table 2
2024A
2025E
2026E
GDP growth (real, %)
3.4
3.0
2.7
Inflation (HICP, avg % change)
2.6
3.5*
2.9
Unemployment (% labor force, avg)
4.2
3.5
3.7
General Govt Primary Balance (%GDP)
-2.5
-2.1
-1.6
Gross Public Debt (%GDP)
23.8
28.5
30.6
*actual.
Sources: Eurostat, European Commission (European Economic Forecasts, Autumn 2025)
Cyprus
In Cyprus, according to real GDP data for the first nine months of 2025 by the country’s Statistical Service, the annual GDP growth
stood at 3.5%, mildly below the 4% pace in the same period of 2024. Growth was primarily driven by higher exports, which rose by
5%, and a significant household consumption increase, by 3.5%, as employment grew also by 3.5% in the same period and wages rose
by 4.5%. Despite an increase in imports of the same magnitude with that in exports, the external balance marginally improved. Gross
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fixed capital formation expanded by 6.5%, however due to a smaller share to GDP than exports and household spending, its
contribution to GDP growth was smaller. In its Autumn Economic Forecasts (November 2025), the EC forecast a deceleration of the
GDP increase in 2025 and 2026 relative to 2024, to 3.4% and 2.6% respectively, down from 3.9% in the latter year. Private
consumption is expected to remain the main driver of growth, though its momentum is set to ease as real income growth moderates,
and the inflow of foreign workers whose relocation typically supports household spending, slows. This moderation is expected to be
partially offset by stronger investment, supported by the implementation of the RRF by 2026, and sustained inflows of inward FDI,
especially in real estate activities, where the volume of sales rose by 13.8% in January-November 2025, resulting in an 18-year high
already since this month. Exports are also set to remain strong thanks to a solid tourist outlook, with tourist arrivals rising by 12% in
January-November, leading to a new all -time high already from October onwards, and buoyant ICT activity. On the other hand, the
global trade slowdown due to higher tariffs, is already having a negative impact on the outlook for the shipping sector, expected to
be sustained in 2026. Headline inflation stood at 0.8% in 2025 from 2.3% in 2024, before rising to 1.5% by 2026, as the impact of the
VAT reduction in April 2025 fades. Scope Ratings affirmed in October Cyprus’s sovereign rating to A- and revised the outlook to
positive. In November, Standard & Poor’s also affirmed Cyprus’s sovereign rating at A- and upgraded the outlook from stable to
positive.
Table 3
2024A
2025E
2026E
GDP growth (real, %)
3.9
3.4
2.6
Inflation (HICP, avg % change)
2.3
0.8*
1.5
Unemployment (% labor force, avg)
4.9
4.7
4.5
General Govt Primary Balance (%GDP)
5.4
4.6
4.3
Gross Public Debt (%GDP)
62.8
56.4
51.0
*actual.
Sources: Eurostat, European Commission (European Economic Forecasts, Autumn 2025)
Macroeconomic risks for 2026
Regarding the outlook for the next 12 months, the major macroeconomic risks and uncertainties in Greece and our region are
associated with: (a) the geopolitical tensions caused by the war in Ukraine and the fragile situation in the Middle East, especially due
to the war between Iran and USA/Israel in the region. The latter development has drastically raised geopolitical and economic
uncertainty globally, but particularly in nearby countries caused disruptions in maritime trade through major Middle Eastern
waterways, especially of energy goods, and amplified financial volatility; if prolonged, the ensuing supply bottlenecks are likely to
exert inflationary pressures globally, and, in an adverse scenario, even disrupt the deflationary trend of the past two years in many
economies; (b) the elevated geopolitical and economic uncertainty stemming from US foreign and trade policy decisions, and their
repercussions, immediate (e.g., increased financial volatility in equity and fixed income markets) and subsequent ones (e.g.,
retaliatory tariffs by US trading partners, weaker US demand for EU goods and services); (c) the timeline of the monetary policy
decisions by the ECB and the Federal Reserve Bank, especially in the light of the protectionist trade policies adopted by the US
government and the upcoming changes in the Fed leadership; (d) the persistently above-target inflation driven primarily by the
services sector, and its impact on household budgets, firms’ production costs, competitiveness and external trade, as well as any
potential social and/or political ramifications this may entail; (e) the capacity to absorb NGEU and MFF funds and attract new
investments in the countries of presence given delays in certain RRF-funded projects and slower-than-planned disbursement of RRF
loans in Greece, with the deadline to meet RRF milestones and targets expiring in August 2026; (f) the effective and timely
implementation of the reform agenda required to meet the RRF milestones and targets and boost productivity, competitiveness, and
resilience; (g) the risk of Greece’s and Bulgaria’s major trade partners, primarily the euro area, remaining stagnant or even facing a
downturn, reducing external demand for goods and services, (h) the persistently large current account deficit that seems to have
become once again a structural feature of the Greek economic growth model, and (i) the exacerbation of natural disasters linked to
climate change and their effect on GDP, employment, fiscal balance and sustainable development in the long run.
Materialization of the above risks would have potentially adverse effects on the fiscal planning of the Greek government, as it could
decelerate the pace of expected growth and on the liquidity, asset quality, solvency and profitability of the Greek banking sector. In
this context, the Group’s Management and Board are continuously monitoring the developments on the macroeconomic, financial
and geopolitical fronts as well as the evolution of the Group’s asset quality and liquidity KPIs and have maintained a high level of
readiness, so as to accommodate decisions, initiatives and policies to protect the Group’s capital, asset quality and liquidity standing
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as well as the fulfilment, to the maximum possible degree, of its strategic and business goals in accordance with the business plan for
2026 - 2028.
8. Merger between Eurobank Ergasias Services and Holdings S.A. and Eurobank S.A
On 19 December 2024, Eurobank Holdings announced that, at its meeting held on 18 December 2024, its Board of Directors resolved
to initiate the process for the merger by absorption of Eurobank Holdings by the Bank, with a view to achieving operational efficiencies
and a leaner group structure.
On 30 April 2025, the Boards of Directors of both companies approved the draft merger agreement. On 19 May 2025, the companies
announced the completion of the publicity formalities relating to the Draft Merger Agreement, pursuant to which Eurobank S.A.
would absorb Eurobank Holdings, in accordance with the provisions of the applicable laws. Further information is provided in note
23.1 of the consolidated financial statements for the year ended 31 December 2025.
General Meeting decisions
On 22 October 2025, the Extraordinary General Meeting (EGM) of the shareholders of the Bank approved:
●
The merger of “Eurobank S.A.” with “Eurobank Ergasias Services and Holdings S.A.” by absorption of the latter by the former,
in accordance with the provisions of Articles 6–21, 30–34 and 140 of Law 4601/2019, Article 16 of Law 2515/1997 and the
applicable provisions of Law 4548/2018, as in force, as well as the Draft Merger Agreement and the remaining documents
relating to the Merger.
●
The amendment of Article 5 of the Bank’s Articles of Association to reflect the following changes to the Bank’s share capital
as a result of the merger:
(i) the increase of the Bank’s share capital by € 798,932,376.22 through the issuance of 3,631,510,801 ordinary,
dematerialized, registered voting shares, each having a nominal value of € 0.22; and
(ii) the decrease of the Bank’s share capital by € 3,941,071,968.10 through the cancellation of 3,683,244,830 shares of the
Bank, each having a nominal value of € 1.07.
Following the above, the share capital of the Bank amounts to € 798,932,376.22, divided into 3,631,510,801 ordinary, dematerialized,
registered voting shares, each having a nominal value of € 0.22.
●
The continuation of the implementation of the share buyback programme originally established by Eurobank Holdings
(section 10), subject to the relevant approval by the European Central Bank, following completion of the merger by
absorption of Eurobank Holdings by the Bank and the commencement of trading of the Bank’s shares on the Athens
Exchange. The total cost of the Programme will not exceed € 122,919,881.27, corresponding to the remaining amount of
the existing Programme.
●
The continuation of the stock options plan originally established by Eurobank Holdings pursuant to the resolution of its
Annual General Meeting dated 28 July 2020 (see section 9).
On 3 December 2025, the Extraordinary General Meeting (EGM) of the shareholders of Eurobank Holdings approved the merger of
“Eurobank S.A.” with “Eurobank Ergasias Services and Holdings S.A.” by absorption of the latter by the former, in accordance with the
provisions of the relevant articles of the applicable laws, as in force, as mentioned above, as well as the merger documentation.
Completion of the Merger
On 12 December 2025, following the approvals granted by the Extraordinary General Meetings of the shareholders of both Companies
(as referred to above) and the receipt of all necessary permits and approvals from the competent authorities, Eurobank announced
that the merger had been completed and that the following effects occurred automatically and simultaneously, both as between
Eurobank and the Company and vis-à-vis third parties:
●
Pursuant to Article 16 of Law 2515/1997 and Article 18(2) of Law 4601/2019, as in force, Eurobank succeeded, by operation
of law and through universal succession, to the entirety of the assets and liabilities of Eurobank Holdings, as reflected in the
transformation balance sheet dated 31.12.2024 and as subsequently evolved until the completion of the merger. Any
pending litigation involving Eurobank Holdings continues automatically in the name of Eurobank, without any further
procedural formalities, in accordance with Article 16 of Law 2515/1997 and Article 18(3) of Law 4601/2019, as in force.
●
Eurobank Holdings was dissolved without liquidation and ceased to exist, and its shares were delisted from the ATHEX.
●
The shareholders of Eurobank Holdings became shareholders of Eurobank on the basis of the agreed exchange ratio,
whereby for each existing common registered share with voting rights of Eurobank Holdings, with a nominal value of € 0.22,
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its holder received one new common registered dematerialized share with voting rights of Eurobank, with a nominal value
of € 0.22, in the share capital of Eurobank as formed in the context of the Merger. Accordingly, following the Merger,
shareholders retained the same number of shares as they held prior to the Merger.
The 3,631,510,801 new common registered shares of Eurobank issued in the context of the Merger commenced trading on the Main
Market of the ATHEX on 15 December 2025 and on the Cyprus Stock Exchange (CSE) on 19 December 2025.
The parallel listing of the Bank’s shares on the CSE forms part of its long-term strategic planning to consolidate its regional presence,
further strengthen its position in the Cypriot economy and support the interconnection of the Greek and Cypriot markets in an
environment of enhanced convergence of regional economic interests. In particular, following the completion of the acquisition of
100% of Hellenic Bank and the delisting of its shares from the CSE, the parallel listing of Eurobank’s shares on the CSE confirms the
latter’s strategic commitment to the Cypriot economy and its support for the development and strengthening of the local capital
market.
9. Share Capital
As at 31 December 2025:
a)
The total share capital of the Bank amounted to € 798,932,376.22, divided into 3,631,510,801 common voting shares with
a nominal value of € 0.22 each. All shares are registered, listed on the Athens Stock Exchange and the Cyprus Stock Exchange,
and incorporate all rights and obligations provided for under Greek and Cypriot legislation.
b)
The number of the Bank’s shares held by the Bank pursuant to the Share Buyback Programme was 3,546,449.
c)
The number of the Bank’s shares held by the Group’s subsidiaries in the ordinary course of their business was 3,869,292
(see note 37 to the consolidated financial statements).
Share options
Under the five-year share award plan approved in 2020 and initiated in 2021, originally established by Eurobank Holdings and
subsequently continued by Eurobank (see section 8), Eurobank grants share option rights to its employees and to the employees of
its affiliated companies, with new shares being issued and a corresponding share capital increase effected upon the exercise of the
options. The maximum number of rights that may be granted was set at 55,637,000, each corresponding to one new share with an
exercise price of € 0.23. The final terms and the implementation of the share options plan are defined and approved annually by the
Board of Directors in accordance with the applicable legal and regulatory framework and the Group’s policies.
The options are exercisable annually in series during a period from one to five years. Each series may be exercised in whole or in part
and converted into shares at the employees’ discretion, provided that they remain employed by the Group until the first available
exercise date. Each series is treated as a separate award, with a distinct vesting period and fair value. Corporate actions affecting the
number and price of shares result in corresponding adjustments to the share options.
Events prior to or at the merger
a)
Share capital increase of Eurobank Holdings
Following the exercise of share options granted to Group executives under the aforementioned share options plan and pursuant to
the decision of the Board of Directors of Eurobank Holdings dated 29 August 2025, the share capital of Eurobank Holdings increased
by € 1,980,630.52 through the issuance of 9,002,866 new common voting shares with a nominal value of € 0.22 per share and an
exercise price of € 0.23 per share. The total amount of the difference above par, net of expenses directly attributable to the equity
transaction, amounted to € 71 thousand and was recorded in the “Share premium” account. The new shares were listed on the Athens
Exchange on 11 September 2025.
b)
Cancellation of own shares
Pursuant to Article 18(5)(b) of Greek Law 4601/2019, any own shares held by the Absorbed Company are not exchanged for new
shares in the Absorbing Company and are automatically cancelled upon completion of the Merger. Accordingly, on 12 December
2025, being the date of completion of the Merger, 54,228,394 ordinary shares of Eurobank Holdings, each with a nominal value of €
0.22, were automatically cancelled, resulting in a reduction of the Company’s share capital by € 11,930,246.68.
Further information is provided in note 37 to the consolidated financial statements.
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10. Shareholders’ remuneration
Dividends
On 29 April 2025, Eurobank Holdings received approval from the European Central Bank (ECB) to remunerate its shareholders in the
total amount of € 674m for the financial year 2024, through a combination of cash distribution and share buyback, corresponding to
a 50% payout ratio of the Group’s net profit for 2024, excluding the gain of € 99.5m arising from the acquisition of a shareholding in
Hellenic Bank.
Following the above, on 30 April 2025, the Annual General Meeting (AGM) of the shareholders of Eurobank Holdings, inter alia,
approved:
●
The distribution of a cash dividend of € 386,057,314.55 from the “Special Reserves” account, corresponding to a gross
dividend of € 0.105 per share.
●
A share buyback programme (“Programme”), as described below.
●
The distribution of € 437 thousand to executives and employees of the Company from the “Special Reserves” account.
In
addition, it was noted at the AGM that the respective amount approved for distribution to executives and employees of the
Bank amounted to € 31m.
In May 2025, the Bank, further to the distribution of € 240m in December 2024, proceeded with the distribution of an additional €
405m from its non-mandatory reserves, as part of the Bank’s overall contribution to its sole shareholder, Eurobank Holdings, in order
to enable the latter to remunerate its shareholders on the basis of the profits for the financial year 2024.
In October 2025, the Board of Directors of Eurobank Holdings approved, in accordance with the provisions of paragraph 3 of Article
162 of Law 4548/2018 and in line with its shareholders’ remuneration policy, the distribution of an interim cash dividend of €170m
for the financial year 2025 from its non-mandatory reserves. Eurobank Holdings obtained the necessary approval from the ECB in late
October and proceeded with the payment of the interim dividend to its shareholders on 12 November 2025.
Based on the Group’s financial performance for the financial year 2025, the Bank intends to remunerate its shareholders with a total
amount of € 717m, of which €170m has already been distributed in the form of an interim dividend, as noted above. This corresponds
to a 55% payout ratio of the Group’s net profit for 2025 less the € 58m gain on acquisition of the CNP Cyprus subgroup and is subject
to approval of the Annual General Meeting of its shareholders and the regulatory authorities. The final remuneration will be delivered
through a combination of a cash dividend and a share buyback programme.
Share Buyback - Own shares
On 7 May 2025, Eurobank Holdings announced the commencement of the implementation of the share buyback programme (the
“Programme”), as approved by the Annual General Meeting of its shareholders held on 30 April 2025. The Programme was conducted
in accordance with Article 49 of Law 4548/2018 and under the following terms: (i) the total cost of the Programme would not exceed
€ 287,942,685.45 and, in any event, the own shares to be acquired would not exceed 10% of the Company’s paid-in share capital in
accordance with the applicable legislation; (ii) the duration of the Programme would not exceed twelve months, i.e. it would remain
in force until 29 April 2026; and (iii) the minimum and maximum acquisition price per share under the Programme would be the
nominal value of the share (€ 0.22) and € 10, respectively.
The buyback of own shares by Eurobank Holdings would be suspended prior to the convocation of the General Meeting of Eurobank
Holdings’ shareholders for the approval of the Merger (section 8) of Eurobank Holdings with the Bank (“Phase A”). The Bank, as the
universal successor of Eurobank Holdings, would continue the implementation of the Programme following completion of the Merger.
The own shares acquired by the Company during Phase A would be cancelled with a corresponding reduction of share capital.
On 23 October 2025, Eurobank Holdings announced that the share buyback Programme had been suspended as of 21 October 2025.
Up to that date, Eurobank Holdings had acquired 54,228,394 shares at a total cost of € 165m.
On 15 December 2025, following the completion of the merger with Eurobank Holdings and in accordance with the terms of the
Programme referred to above, the Bank commenced the continuation of the implementation of the Share Buyback Programme
originally established by Eurobank Holdings (section 8).
The Bank intends to use the own shares it acquires following the completion of the Merger in order to reduce its share capital in
accordance with Article 49 of Law 4548/2018 and/or for distribution to the Company’s employees and/or members of its
management and/or its affiliated companies, and/or for any other purposes permitted under applicable law.
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11. Major Shareholders
Based on the most recent notifications that Eurobank has received from shareholders holding 5% or more of Eurobank’s voting rights,
the significant shareholder is the following:
“Fairfax Financial Holdings Limited” (“Fairfax”), which holds 32.67% of Eurobank’s total voting rights, corresponding to 1,186,363,895
voting rights of the Eurobank’s ordinary shares (effective as of 12 December 2025). Specifically, on 19 December 2025, Eurobank
announced, following the relevant notification received from Fairfax, that upon completion of the Merger the previously disclosed
holdings of Fairfax and its subsidiaries in Eurobank Holdings had become holdings in Eurobank and that the percentage of voting
rights in Eurobank held directly and indirectly by Fairfax as at 12 December 2025 remained unchanged, amounting to 32.67% of
Eurobank’s total voting rights, with no change in the relevant percentage.
12. Sundry information required under Law 3556/2007 (article 4, par.7)
According to the Articles of Association:
a) there are no restrictions on the transfer of Eurobank’s shares;
b) there are no Eurobank shares carrying special control or voting rights;
c) there are no restrictions on voting rights;
d) the rules governing the appointment and replacement of directors, as well as the amendment of the Articles of Association,
are in accordance with the applicable provisions of company law.
Eurobank is not aware of any shareholders’ agreements resulting in restrictions in the transfer of its shares or in the exercise of the
shares’ voting rights. There are no significant agreements that enter into force, are amended or expire if there is change in the control
of Eurobank following a public offer. There are no agreements between Eurobank and the Directors or the staff for compensation in
the event of departure as a result of a public offer.
13. Board of Directors
The Board of Directors (BoD) was elected by the Annual General Meeting of the Shareholders (AGM) held on 23 July 2024 for a three
- year term of office that will expire on 23 July 2027, prolonged until the end of the period the AGM for the year 2027 will take place.
Furthermore, on 18 June 2025, Mr. Jawaid Mirza, Non-Executive Independent Member of the Boards of Directors of Eurobank
Holdings and Eurobank, submitted his resignation, effective as of 27 June 2025, as he no longer fulfilled the independence criteria set
out in Article 9 of Law 4706/2020, having cumulatively served nine (9) years as a member of the Boards of Directors of Eurobank
Holdings and the Bank.
The composition of the BoD of Eurobank is presented in note 48 to the consolidated financial statements. Personal details of the
Directors are available on Eurobank’s website (
www.eurobank.gr
).
14. Information required under Law 4548/2018 (article 97, par.1 (b))
According to article 97 par. 1 (b) of Law 4548/2018 the BoD members owe to disclose in a timely and adequate manner to the other
members of the BoD their own interests, which may arise from the company's transactions, which fall within their duties, as well as
any conflict of their interests with those of the company or its related companies. In such case and in line with the provisions of article
97 par 3 of the same law, the member of the BoD is not entitled to vote on issues in which there is a conflict of interest with his own
company or persons with whom he is a related party. In these cases, decisions are taken by the other BoD members.
For the year 2025, the following cases were identified in which a conflict of interest with Eurobank arose:
For the purposes of (a) the approval of the distribution of net profits to senior management and employees and (b) approvals pursuant
to Article 86 of Law 4261/2014, the Chief Executive Officer, Mr. Karavias, and the Deputy Chief Executive Officers, Messrs. Ioannou
and Vassiliou , did not participate in the voting, in accordance with Article 97 paragraph 3 of Law 4548/2018, due to a conflict of
interest.
In relation to decisions concerning the remuneration adjustment of the Chief Executive Officer, Mr. Karavias did not participate in the
voting, in accordance with Article 97 paragraph 3 of Law 4548/2018, due to a conflict of interest.
15. Related party transactions
As at 31 December 2025, the Group’s outstanding balances of the transactions and the relating net income / expense for 2025 with
(a) the key management personnel (KMP) and the entities controlled or jointly controlled by KMP are: receivables €6.3m, liabilities
€26.4m, net expense €0.1m (b) the Fairfax group (excluding Eurolife FFH Insurance Group Holdings S.A., which is also a Group’s
associate) are: receivables €146.9m, liabilities €44.6m, guarantees issued €2m, net income €11.9m and (c) the associates and joint
REPORT OF THE DIRECTORS
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€ million
Assets
Liabilities
Income
Expenses
Guarantees
(Net)
A. SUBSIDIARIES
Eurobank Equities S.A.
372
144
12
(0)
3
Eurobank Asset Management Mutual Fund Mngt Company S.A.
2
14
17
(5)
Eurobank Factors S.A.
824
7
35
0
Eurobank Bulgaria A.D.
835
465
60
(47)
2
Eurobank Fund Mngt Co. (Lux) S.A.
5
0
31
0
ERB New Europe Holding B.V.
-
-
6
-
Eurobank Private Bank Luxembourg S.A.
1,479
251
54
(22)
381
Piraeus Port Plaza 3
35
15
1
(2)
Tenberco Real Estate Single Member S.A.
-
7
1
-
Eurobank Leasing Single Member S.A.
298
0
8
(1)
Eurobank Limited (ex Hellenic Bank)
271
2,203
235
(116)
1
Severdor Ltd
-
-
14
-
Insignio Single Member S.A.
41
2
2
(0)
B. ASSOCIATES
Eurolife FFH Insurance Group Holdings S.A. (consolidated)
13
71
24
(28)
Avramar Aquaculture Group
67
1
0
34
doValue Greece Loans and Credits Claim Management S.A.
82
50
2
(53)
ventures and the Eurobank Group’s personnel occupational insurance fund
are: receivables €166.3m, liabilities €127.2m, net expense
€32.2m.
Key management personnel are entitled to compensation in the form of short-term employee benefits amounting to €11.9m (2024:
€11.8m) including €2.1m in upfront variable remuneration awarded as profit sharing, and long-term employee benefits amounting
to €5m (2024: €5.3m) including €2.8m in deferred variable remuneration awarded as profit sharing and payable in equal instalments
over the next 4-5 years (2024: €3.2m). In addition, KMP have been granted €4.9m in variable remuneration through share options
(2024: €5.5m), €2.9m of which relates to options exercisable in equal portions over the next 4-5 years (2024: €3.3m). The variable
remuneration was awarded following the Annual General Meetings of the shareholders of Eurobank Holdings and the Bank taken
place on 30 April 2025, in accordance with the Eurobank Holdings’ and the Bank’s remuneration policy.
At the same date, the Bank’s outstanding balances of the transactions and the relating net income/expense for 2025 with (a) the key
management personnel (KMP) and the entities controlled or jointly controlled by KMP are: receivables €6.3m, liabilities €15.1m, net
expense €0.1m, (b) the Fairfax group (excluding Eurolife FFH Insurance Group Holdings S.A., which is also a Group’s associate) are:
receivables €146.9m, liabilities €10m, guarantees issued €2m, net income €11.9m, (c) the associates and joint ventures the Eurobank
Group’s personnel occupational insurance fund are: receivables €166.3m, liabilities €123.9m, net expense €21.4m, guarantees issued
€0.5m (d) the Eurobank Holdings S.A.: net expense €124.2m and (e) the subsidiaries are: receivables €4,200m, liabilities €3,145m,
guarantees issued €386m, net income €284m.
Key management personnel of the Bank are entitled to compensation in the form of short-term employee benefits of €10.9m (2024:
€10.4m) including €2m (2024: €1.9m) in upfront variable remuneration awarded as profit sharing, and long-term employee benefits
amounting to €4.6m (2024: €4.7m) including €2.6m in deferred variable remuneration awarded as profit sharing and payable in equal
instalments over the next 4-5 years (2024: € 2.8m). In addition, KMP have been granted €4.6m in variable remuneration through
share options (2024: €5.5m), €2.7m of which relates to options exercisable in equal portions over the next 4-5 years (2024: €3.3m).
The major balances of the Bank’s transactions with (a) its subsidiaries and (b) its associates are presented in the below table:
All transactions with related parties are entered into the normal course of business and are conducted on an arm's length basis.
Further information is provided in the note 46 to the consolidated financial statements and note 44 to the financial statements of the
Bank.
3
Exceeding an amount of €100m in assets/liabilities or €1m in income/expenses for the Bank’s transactions with its subsidiaries and associates.
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16. External Auditors
The Annual General Meeting of Eurobank’s shareholders held on 30 April 2025 approved the appointment of KPMG as statutory
auditor for the separate and consolidated financial statements for the year ending 31 December 2025.
During 2025, the Audit Committee reviewed KPMG’s independence and effectiveness, as well as its annual audit plan. In addition, the
Audit Committee ensured, on a quarterly basis, that (a) any non-audit services assigned to KPMG were reviewed and approved as
required, and (b) an appropriate balance was maintained between the audit and non-audit fees paid to KPMG, in accordance with
the relevant provisions of the Group’s Policy on External Auditors’ Independence (note 47 to the consolidated financial statements).
17. Corporate Governance Statement
Eurobank has adopted the Hellenic Corporate Governance Code issued by the Hellenic Corporate Governance Council, which is
available on its website (
www.eurobank.gr
). The Corporate Governance Statement for the year 2025, attached hereto, forms an
integral part of the Directors’ Report.
18. Sustainability Statement
Pursuant to Directive (EU) 2022/2464 and Commission Delegated Directive (EU) 2023/2775, as in force, which were transposed into
Greek legislation by Law 5164/2024, as in force, the Sustainability Statement for the year 2025, attached hereto, forms an integral
part of the Directors’ Report and provides the necessary information to understand the impact of the Group’s activities on
sustainability, as well as the impact of sustainability matters on the Group’s progress, performance and position. Furthermore,
Eurobank activities and initiatives for 2025 in the areas of (a) supplier relations and sustainable procurement and (b) corporate social
responsibility, are outlined in the attached report titled ‘Additional Information Related to Sustainability’.
Georgios Zanias Fokion Karavias
Chairman Chief Executive Officer
5 March 2026
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€ = Euro m = million bn = billion
APPENDIX
Definition of Alternative Performance Measures (APMs) in accordance with European Securities and Markets Authority (ESMA)
guidelines, which are included in the Report of Directors/Financial Statements:
a)
Loans to Deposits ratio:
reported period,
b)
Pre-Provision Income (PPI):
period,
c)
Core income:
for the reported period,
d)
Core Pre-provision Income (Core PPI):
e)
Net Interest Margin (NIM):
continued operations’ total assets (the arithmetic average of total assets, excluding those related to discontinued operations’,
at the end of the reported period, at the end of interim quarters and at the end of the previous period),
f)
Fees and commissions:
reported period,
g)
Fees and commissions over assets ratio:
The Fees and commissions of the reported period, annualised and divided by the
average balance of continued operations’ total assets (the arithmetic average of total assets, excluding those related to
discontinued operations’, at the end of the reported period, at the end of interim quarters and at the end of the previous period),
h)
Income from trading and other activities
: The total of net trading income, gains less losses from investment securities and other
income/ (expenses) of the reported period,
i)
Cost to Income ratio:
j)
Cost to core income ratio:
Total operating expenses divided by total core income,
k)
Adjusted net profit:
Net profit/loss attributable to equity holders οf the parent company excluding restructuring costs, goodwill
impairment/ gain on acquisition, gains/losses related to the transformation and NPE reduction plans, contribution to Greek
State’s infrastructure projects, net loss from discontinued operations and income tax adjustments,
l)
Non-performing exposures (NPE):
than 90 days past-due or for which the debtor is assessed as unlikely to pay its credit obligations in full without realization of
collateral, regardless of the existence of any past due amount or the number of days past due. The NPE, as reported herein, refer
to the gross loans at amortised cost except for those that have been classified as held for sale,
m)
NPE ratio:
n)
NPE formation:
movements,
o)
NPE Coverage ratio:
commitments (off balance sheet items), divided by NPE at the end of the reported period,
p)
Provisions (charge) to average net loans ratio (Cost of Risk):
reported period, excluding the amount associated with loans and advances to customers at amortized cost classified as held for
sale, annualised and divided by the average balance of loans and advances to customers at amortised cost (the arithmetic average
of loans and advances to customers at amortised cost, at the end of the reported period, at the end of interim quarters and at
the end of the previous period),
q)
Return on tangible book value (RoTBV):
Adjusted net profit, post coupon payment to AT1 capital holders, divided by average
tangible book value. Tangible book value is the total equity excluding preference shares, AT1 capital instruments and non
controlling interests minus intangible assets.
Definition of capital and other selected ratios in accordance with the regulatory framework, which are included in the Report of
Directors/Financial Statements:
a)
Total Capital Adequacy ratio:
by total Risk Weighted Assets (RWA). The
RWA
are the Group’s assets and off-balance-sheet exposures, weighted according to
risk factors based on Regulation (EU) No 575/2013, taking into account credit, market and operational risk,
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b)
Common Equity Tier 1 (CET1) ratio:
regulatory capital divided by total Risk Weighted Assets (RWA),
c)
Total Tier 1 Capital ratio (Tier 1) ratio:
divided by total Risk Weighted Assets (RWA),
d)
Liquidity Coverage Ratio (LCR):
stress period,
e)
Minimum Requirements for Eligible Own Funds and Eligible Liabilities (MREL) ratio:
The sum of i) total regulatory capital (at
Eurobank S.A. consolidated level) as defined by Regulation (EU) No 575/2013 as in force, based on the transitional rules for the
reported period ii) part of any Tier 2 instruments to the extent that it does not qualify as Tier 2 capital (amortized part counts
towards MREL), and iii) liabilities issued by Eurobank S.A. that meet the MREL-eligibility criteria set out in Regulation (EU) No
575/2013 as in force, divided by RWA.
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The following table presents the components of the calculation of the above APMs, which are derived from the Eurobank’s
consolidated financial statements for the year ended 31 December 2025 and Eurobank Holdings’ consolidated financial statements
for the year ended 31 December 2024:
Components of Alternative Performance Measures
€ million
FY 2025
FY 2024
Net Interest Income ⁽¹⁾
2,549
2,507
Fees and commissions⁽¹⁾
770
666
Total Operating income
3,430
3,341
Total Operating income, excluding the gain on (i) acquisition of CNP Cyprus subgroup in
2025, (ii) investment in Hellenic Bank in 2024⁽²⁾
3,372
3,242
Total Core income
3,319
3,173
Total Operating expenses
(1,285)
(1,099)
Total Operating expenses excluding the contribution to Greek State’s infrastructure
projects ⁽³⁾
(1,258)
(1,071)
Pre-provision income (PPI)
2,145
2,242
Pre-provision income (PPI), excluding the contribution to Greek State’s infrastructure
projects and the gain on (i) acquisition of CNP Cyprus subgroup in 2025, (ii) investment in
Hellenic Bank in 2024
2,114
2,170
Core Pre-provision income (Core PPI)
2,034
2,074
Core Pre-provision income (Core PPI) excluding the contribution to Greek State’s
infrastructure projects
2,061
2,101
Net profit attributable to equity holders οf the parent company
1,362
1,448
Restructuring costs, before tax
(62)
(168)
Restructuring costs, after tax
(55)
(121)
Gain on (i) acquisition of CNP Cyprus subgroup in 2025 (ii) investment in Hellenic Bank in
2024
58
100
Contribution to Greek State’s infrastructure projects, before tax
(27)
(27)
Contribution to Greek State’s infrastructure projects, after tax
(19)
(19)
Impairment (loss)/reversal for the HFS loans related projects, before tax
(71)
16
Impairment (loss)/reversal for the HFS loans related projects, after tax
(50)
11
Adjustment to deferred tax
25
Net loss from discontinued operations
(9)
(7)
Adjusted net profit
1,412
1,484
Coupon payment to AT1 capital holders, after tax
(12)
Impairment losses relating to loans and advances
(379)
(303)
Impairment losses relating to loans and advances, excluding the amount associated with
HFS loans
(308)
(319)
NPE formation⁽⁴⁾
147
222
Non performing exposures (NPE)
1,434
1,719
NPE excluding Hellenic Bank NPEs covered by Asset Protection Scheme (APS) in 2024⁽⁴⁾
1,530
Due to customers
82,704
78,593
Gross Loans and advances to customers at amortized cost
55,977
52,245
Impairment allowance for loans and advances to customers
(1,309)
(1,309)
Impairment allowance for credit related commitments
(56)
(63)
Impairment allowance for NPE of Hellenic Bank covered by APS in 2024
(19)
Due to customers (Greek operations)
45,164
43,287
Gross Loans and advances to customers at amortized cost (Greek operations)
37,261
34,682
Impairment allowance for loans and advances to customers (Greek operations)
(992)
(998)
Average balance of continued operations’ total assets ⁽⁵⁾
102,950
91,721
Average balance of loans and advances to customers at amortized cost ⁽⁶⁾
52,490
46,237
Average balance of tangible book value ⁽⁷⁾
8,776
8,024
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(1)
4Q25: Net interest income (NIM) of the fourth quarter 2025 (€647m) & 4Q25 Fees and commissions (€213m)
annualised, divided by the average
balance of continued operations’ total assets (€105,473m). The average balance of continued operations’ total assets has been calculated as the
arithmetic average of their balances at the end of the reporting period (31 December 2025: €107,976m) and at the end of the previous reporting
period (30 September 2025: €102,969m).
(2)
International Operations: Operating income: €1,514m (2024: €1,260m). Greek operations: Operating income: €1,858m (2024: €1,982m).
(3)
(4)
for sale / sales €200m and other movements €(133)m.
(5)
period (31 December 2025: €107,976m), at the end of interim quarters (30 September 2025: €102,969m), (30 June 2025: €102,228m), (31 March
2025: €100,426m) and at the end of the previous period (31 December 2024: €101,150m).
The respective figures for 31 December 2024: €101,150m,
30 September 2024: €99,593m, 30 June 2024: €98,725m, 31 March 2024: €79,356m and 31 December 2023: €79,781m.
(6)
balances at the end of the reporting period (31 December 2025: €54,668m), at the end of interim quarters (30 September 2025: €52,875m), (30 June
2025: €52,253m), (31 March 2025: €51,718m), and at the end of the previous period (31 December 2024: €50,936m).
The respective figures for 31
December 2024: €50,936m, 30 September 2024: €49,095m, 30 June 2024: €48,093m, 31 March 2024: €41,546m and 31 December 2023: €41,515m.
(7)
The average balance of tangible book value, has been calculated as the arithmetic average of the total equity minus AT1 capital instruments, the
intangible assets and non controlling interests at the end of the reporting period (31 December 2025: €9,022m), at the end of interim quarters 30
September 2025: €8,929m, 30 June 2025: €8,681m, 31 March 2025: €8,764m and at the end of the previous period (31 December 2024: €8,484m).
The respective figures for 31 December 2024: €8,484m and 31 December 2023: €7,565m.
Source of financial Information
The Directors’ Report includes financial data and measures as derived from the Eurobank’s consolidated financial statements for the
year ended 31 December 2025, and Eurobank Holdings’ consolidated financial statements for the year ended 31 December 2024,
which have been prepared in accordance with International Financial Reporting Standards (IFRS). In addition, it includes information
as derived from internal information systems, consistent with the Group’s accounting policies, such as the selected financial
information for the Group’s two main reportable segments a) Greek Operations, which incorporate the business activities originated
from, the Bank and the Greek subsidiaries and b) International Operations, which incorporate the business activities originated from
the banks and the other local subsidiaries operating in Bulgaria, Cyprus and Luxembourg (as described at the relevant section on page
8).
EUROBANK S.A.
REPORT OF THE DIRECTORS / CORPORATE GOVERNANCE STATEMENT
30
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CORPORATE GOVERNANCE STATEMENT 2025
Table of Contents...................................................................................................................................................................... Page
1.
Introduction ....................................................................................................................................................................... 32
2.
Adoption of the Hellenic Corporate Governance Code .................................................................................................... 32
3.
Corporate Governance and Key Policies ........................................................................................................................... 32
3.1 Internal Governance Control Manual
3.2 Board Nomination Policy
3.3 CEO Succession Planning
3.4 Board Evaluation Policy
3.5 Board of Directors Diversity Policy
3.6 Remuneration Policy
3.7 Board and Board Committees’ Attendance Policy
3.8 Directors’ Induction and Continuous Professional Development Process
3.9 Group Governance Policy
3.10 Conflicts of interest Policy
3.11 Responsible Artificial Intelligence
3.12 Other Key Policies
4.
Shareholders’ General Meeting......................................................................................................................................... 40
4.1 Information about the Eurobank General Meetings
4.2 Information about the Eurobank Holdings General Meetings
5.
Board of Directors .............................................................................................................................................................. 44
5.1 General
5.2 Composition of the Board
5.3 CVs of Board Board members and Secretary
5.4 Diversity Profile of the Board
5.5 Re-election, Cessation, and Independence of Board Members
5.6 Division of responsibilities
5.7 Operation of the Board
5.8 Attendance of Board members in the Board and Board Committees
5.9 Directorships of Board members
5.10 Board Role and Responsibilities
5.11 Main issues the Board dealt with during 2024
5.12 Board and Board Committees overall effectiveness assessment
5.13 Directors’ Induction and Continuous Professional Development
6.
Board Committees ............................................................................................................................................................. 69
6.1 Governance and Operations of Board Committees
6.2 Audit Committee
6.3 Board Risk Committee
6.4 Remuneration Committee
6.5 Nomination and Corporate Governance Committee
6.6 Board Digital & Transformation Committee
7.
Management Committees ................................................................................................................................................. 87
7.1 Management Committees’ Policy
7.2 Executive Board (ExBo)
7.3 Strategic Planning Committee
7.4 Management Risk Committee
7.5 Group Asset and Liability Committee (G -ALCO)
7.6 Central Credit Committees
7.7 Troubled Assets Committee
7.8 Products & Services Committee (PSC)
7.9 Sustainability Management Committee (SMC)
7.10 Ethics Co
8.
Key Control Functions ........................................................................................................................................................ 98
8.1 Internal Audit
8.2 Risk Management
8.3 Compliance
8.4 Personal Data Protection
9.
System of Internal Controls ............................................................................................................................................. 106
9.1 Principles of Internal Controls
9.2 Characteristics of the System of Internal Controls (SIC)
EUROBANK S.A.
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9.3 Evaluation of the System of Internal Controls
9.4 Independent Evaluation of the HoldCo/Bank System of Internal Controls
9.5 Corporate Governance System Assessment in accordance with article 4 par. 1 of Law 4706/2020
10.
Sustainability.................................................................................................................................................................... 108
10.1 Sustainability Approach
10.2 Sustainability Policies & Frameworks
10.3 Stakeholders engagement and double materiality assessment
10.4 Reporting and Transparency
11.
Other information required by Directive 2004/25/EU ................................................................................................... 113
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REPORT OF THE DIRECTORS / CORPORATE GOVERNANCE STATEMENT
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1.
Introduction
Pursuant to Article 152(1) and Article 153(3) of Law 4548/2018, Law 4706/2020, and the Hellenic Corporate Governance Code (the
“Code”), the Report of the Board of Directors of Eurobank S.A. (“Eurobank” or the “Bank”) includes the present Corporate Governance
Statement.
The Corporate Governance Statement addresses, inter alia, the following key areas:
●
Adoption of the Hellenic Corporate Governance Code
●
Corporate Governance and Key Policies
●
Shareholders’ General Meeting
●
Board of Directors
●
Board of Directors’ Committees
●
Management Committees
●
Key Control Functions
●
System of Internal Controls
●
Sustainability
●
Additional Disclosures Required by Directive 2004/25/EU
Furthermore, taking into account that:
a) the merger of Eurobank with Eurobank Ergasias Services and Holdings S.A. (the “Company”, “Eurobank Holdings”, “Holdings”, or
“HoldCo”) by absorption of the latter by the former, as well as the subsequent listing of the Bank’s shares on the Athens Stock
Exchange, were completed on 12 December 2025, following the approvals of the General Meetings of the shareholders of both
entities and the receipt of all necessary permits and approvals from the competent authorities; and
b) until the completion of the merger and in accordance with Article 152(1) and Article 153(3) of Law 4548/2018, Law 4706/2020,
and the Code, the Report of the Board of Directors of Eurobank Holdings was required to include a Corporate Governance Statement
covering the areas described above,
the present Corporate Governance Statement sets out the manner in which the principles of the Code were implemented:
●
by Eurobank, for the entire financial year 2025; and
●
by Eurobank Holdings, for the period from 1 January 2025 until 12 December 2025.
2.
Adoption of the Hellenic Corporate Governance Code
In compliance with Article 17 of Law 4706/2020, which requires listed companies to adopt and implement a corporate governance
code issued by a recognized and reputable body, Eurobank Holdings adopted the Hellenic Corporate Governance Code (the “Code”)
in September 2021 and applied it until 12 December 2025.
The Board of Directors of Eurobank has also approved the adoption of the Code on September 2021 and continues to apply it.
The Code is available on Eurobank’s website (https://www.eurobank.gr).
3.
Corporate Governance and Key Policies
The corporate governance framework of the Bank and its subsidiaries (“Group”), aligned with applicable legal and regulatory
requirements and international best practices, ensures that the Group operates with credibility, responsibility, fairness, and
transparency, safeguarding the interests of shareholders and all other stakeholders.
In this context, the Bank has established a comprehensive set of policies and procedures, which are regularly reviewed and approved
by the Board of Directors (“BoD”) and/or the competent Board Committees, as required.
During its period of operation until 12 December 2025, Eurobank Holdings applied the same corporate governance framework and
corresponding policies and procedures, which were likewise subject to regular review and approval by its BoD and/or the competent
Board Committees.
The Key Policies governing the Bank (for 2025) and HoldCo (from 1 January 2025 until 12 December 2025) are outlined below.
EUROBANK S.A.
REPORT OF THE DIRECTORS / CORPORATE GOVERNANCE STATEMENT
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3.1
Internal Governance Control Manual
The policies and controls outlined in the Bank IGCM are designed to minimize the risk of errors or financial losses, protect the interests
of shareholders and depositors, and ensure full compliance with regulatory requirements at all times.
The Bank IGCM provides a high-level overview of control policies, while more detailed operating procedures are documented in
individual procedures and manuals maintained by their respective units. Subsidiaries are required to establish their own IGCMs and/or
procedures manuals and to adopt the Group’s policies where applicable. The principles outlined in the IGCM apply across all units
and subsidiaries, except where local circumstances or regulations necessitate deviations.
The IGCM includes a high-level organizational chart and a brief description of the key responsibilities of the main control functions
within Eurobank. It is supplemented by the procedural manuals of individual units and subsidiaries, which provide a written
description of the uppermost levels of the Group’s System of Internal Controls.
Throughout its period of operation until 12 December 2025, Eurobank Holdings had developed and maintained its own IGCM, in
compliance with applicable legal requirements and aligned with its internal governance framework.
3.2
Board Nomination Policy
The Banks’ Board Nomination Policy - that was also applicable to Eurobank Holdings during the period of its operation, until 12
December 2025 - sets out the guidelines and formal process for identifying, selecting, and nominating candidates for the Board.
It ensures that appointments are made:
(a) in compliance with legal and regulatory requirements,
(b) with due regard to the expectations of major shareholders, and
(c) based on individual merit and ability, following best practices.
Primary Objectives of the Policy
The primary objectives of this Policy are to:
•
Define the general principles that guide the Nomination and Corporate Governance Committee (NomCo) in all stages of the
nomination process,
•
Establish specific criteria and requirements for Board nominees,
•
Ensure a transparent, efficient, and fit -for-purpose nomination process, and
•
Maintain a Board structure—including succession planning—that meets high ethical standards, achieves an optimal balance
of knowledge, skills, and experience, and aligns with current regulatory requirements.
Nomination Criteria
The Board, supported by NomCo, shall nominate candidates who meet the following criteria:
1. Reputation, Honesty, Integrity, and Trust
•
Reputation: Candidates must have a strong reputation and high social esteem, demonstrating good repute in line with the
applicable regulatory framework’s standards for honesty and integrity.
•
Honesty, Integrity, and Trust: Candidates should exemplify the highest standards of ethics, honesty, fairness, and personal
discipline, as evidenced by their professional track record, personal history, and public commitments.
2. Knowledge, Skills, Experience (KSE), and General Suitability
•
Understanding of the Bank: Candidates must possess sufficient knowledge, skills, and experience (KSE) to develop a
thorough and up-to-date understanding of the business, governance structures, regulatory environment, markets,
stakeholders, and risks associated with the Bank and its subsidiaries.
•
Seniority: A candidate must have several years of experience in a recognized leadership position within their field of
expertise.
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•
Independent Mindset and Ability to Challenge: Candidates should demonstrate the ability to form and express independent
judgments on all matters before the Board, along with the candor to challenge management and other Board members
when necessary.
•
Collegiality, Teamwork, and Leadership: Candidates should contribute constructively and productively to Board discussions
and decision-making, with the capability to lead discussions as a Committee Chair, Vice-Chair, or Board Chair.
•
Additional Criteria for Executive Directors: Candidates for Executive Director positions must have demonstrated leadership
capabilities through current or previous executive roles, along with the necessary expertise to guide the Bank in achieving
its strategic objectives. They must also be willing to enter into full-time employment with the Bank.
3. Conflicts of Interest and Independence of Mind
NomCo shall assess candidates' personal, professional, financial, and political affiliations to ensure that they do not have actual,
potential, or perceived conflicts of interest that cannot be prevented, adequately mitigated, or managed under the Bank’s policies.
Candidates must be able to represent the interests of all shareholders, fulfill their responsibilities as Directors, and make sound,
objective, and independent decisions.
NomCo shall also examine candidates’ direct and indirect monetary and non-monetary interests, including their affiliations with or
membership in other organizations.
4. Time Commitment
NomCo shall ensure that all nominees can dedicate the time required to effectively discharge their responsibilities as Directors.
This includes their ability to attend and actively participate in Board and Committee meetings on a regular basis.
5. Collective Suitability
*The Board, as a whole, must have the ability to understand the institution’s activities, assess the associated risks, and make informed
decisions aligned with the institution’s business model, risk appetite, strategy, and market operations.
The composition of the Board should reflect the necessary knowledge, skills, and experience required to fulfill its responsibilities.
The Board should collectively possess expertise in:
•
The institution’s core business and its associated risks,
•
All material activities of the Bank,
•
Sector-specific and financial competencies, including financial and capital markets, solvency, risk modeling, and
environmental, social, and governance (ESG) risks,
•
Financial accounting and reporting,
•
Risk management, compliance (including AML/CFT), and internal audit,
•
Information and digital technology, including cybersecurity,
•
Local, regional, and global markets, where applicable,
•
The legal and regulatory framework,
•
Strategic planning and managerial experience,
•
Oversight of (inter)national group structures and risks related to group governance,
•
Corporate governance,
•
ESG issues, and
•
Gender representation, in accordance with the Board Diversity Policy.
Succession Planning
As part of its oversight of the nomination process, NomCo shall ensure the implementation of structured, stepwise succession
planning to maintain continuity and institutional knowledge at the Board level.
This is particularly critical in managing sudden or unexpected absences or departures of Board members.
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To this end, NomCo shall:
•
Monitor Board members’ tenures and ensure staggered appointments and retirements whenever feasible. The
reappointment of existing Board members shall be based on their continued adherence to the criteria set out in this Policy.
•
Ensure an appropriate distribution of relevant KSEs across the Board, preventing undue reliance on the expertise of a few
Directors.
•
Assess whether a sufficient number of Board members are capable of assuming leadership roles, including Board and
Committee Chair positions.
•
Periodically evaluate the availability of suitable candidates to address the Board’s future succession planning needs.
•
Consider both:
a) the objectives and targets defined in the Bank Board Diversity Policy, and
b) the findings of the Bank Board Evaluations, ensuring necessary changes in composition or skills to enhance effectiveness and
collective suitability.
The CEO Succession Planning Policy, which is supplementary to this Policy, sets out the framework for CEO succession planning.
3.3
CEO Succession Planning
The Bank’s CEO Succession Planning Policy (the Policy) - that was also applicable to Eurobank Holdings during the period of its
operation, until 12 December 2025 - plays a crucial role in ensuring a seamless leadership transition.
Key Elements of the Policy
The key elements of the Policy are as follows:
●
Qualifications for the CEO Position: The Nomination and Corporate Governance Committee (NomCo), in collaboration with the
current CEO, defines the qualifications required for the CEO role. This ensures that the successor possesses the necessary skills,
experience, and leadership attributes to guide the organization effectively.
●
Viable Pool of Candidates: NomCo ensures that a strong pipeline of candidates meets the CEO position’s requirements. This
includes evaluating internal candidates within the organization while also considering external candidates when appropriate.
●
Annual Review: NomCo reviews the qualifications and candidate pool at least annually to ensure that the succession planning
process remains aligned with the organization’s evolving needs, regulatory expectations, and strategic direction.
●
Selection Process: NomCo leads the CEO selection process, evaluating candidates based on their qualifications, leadership
capabilities, experience, and alignment with the organization’s culture and strategic objectives.
●
Tailored Induction Program: Once a new CEO is selected, NomCo approves a customized induction program to ensure a smooth
transition. This program provides the new CEO with the necessary knowledge, resources, and support to succeed in the role from
the outset.
Overall, the CEO Succession Planning Policy ensures that the organization is well-prepared for leadership transitions, maintaining
continuity, stability, and effectiveness at the highest level of management.
3.4
Board Evaluation Policy
The Board and Board Committees Evaluation Policy of Eurobank - that was also applicable to Eurobank Holdings during the period of
its operation, until 12 December 2025 - establishes the principles, framework, and process for the annual assessment of the
effectiveness of the Board of Directors and its Committees at the Bank.
The Policy aspires to align with best European banking practices while fully complying with Greek and European legal and regulatory
requirements.
Responsibilities of NomCo
Under this Policy, the Nomination and Corporate Governance Committee (NomCo) holds the overall responsibility for:
•
Assessing the structure, size, composition, and performance of the Board and its Committees,
•
Recommending to the Board any necessary changes to enhance effectiveness,
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•
Evaluating the collective suitability of the Board as a whole, as well as the suitability and contributions of individual Board
members, and
•
Reporting its findings and recommendations to the Board accordingly.
3.5
Board of Directors Diversity Policy
The Bank Board of Directors Diversity Policy - that was also applicable to Eurobank Holdings during the period of its operation, until
12 December 2025 - reflects the organization’s commitment to diversity in line with international best practices and applicable legal
requirements.
Scope of Board Diversity
According to the Policy, Board diversity encompasses multiple factors, including:
•
Skills and expertise,
•
Educational and professional background,
•
Geographical provenance (nationality),
•
Gender,
•
Age, and
•
Other relevant attributes that contribute to a well-balanced and effective Board.
The Nomination and Corporate Governance Committee is committed to fostering a diverse Board, recognizing that diversity includes
a wide range of characteristics, such as gender, race, colour, ethnic or social origin, genetic features, religion or belief, membership
of a national minority, property, birth, disability, age, sexual orientation, skills, educational background, professional background or
geographical provenance (nationality).
During the review of the Board’s collective suitability, as outlined in the Nomination Policy, and in the process of (re)appointment
and succession planning of Board members, the Committee will consider all aspects of diversity to ensure a balanced and inclusive
leadership structure.
Gender Representation Target
While the Board values diversity in all its forms, a specific and measurable objective is set for gender representation.
The Committee ensures that at least 25% (rounded to the previous integer) of the Board is composed of members of the less
represented gender, with a target to increase this representation to a minimum of 33% (rounded to the nearest integer) as soon as
practicable, and in any case no later than mid 2026.
This target aligns with legal and regulatory requirements and industry best practices and shall be maintained at all times, reflecting
evolving legal frameworks and market trends.
Additionally, if the Board includes three (3) or more executive members, at least one (1) executive member of the less represented
gender must be included in the aforementioned 33% percentage.
Compliance with this requirement is expected upon the first, after mid 2026, expiration of a term or of the next term in case of one
renewal or upon a replacement of an already serving executive member of the Board of Directors for any reason after mid 2026.
3.6
Remuneration Policy
Eurobank established a Board of Directors’ Remuneration Policy (Remuneration Policy) in accordance with the requirements of Law
4548/2018 (the Law) in 2025.
The Remuneration Policy was approved by the Bank’s Annual General Meeting of Shareholders on 25 September 2025 and has been
designed to comply with the specific provisions of Articles 110 and 111 of the Law.
It is noted that, prior to the merger of Eurobank and Eurobank Holdings, effected by the absorption of the latter by the former,
Eurobank Holdings had established a Board of Directors’ Remuneration Policy, as Eurobank Holdings—and not the Bank—was legally
responsible for establishing such policy.
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Purpose and Principles
The Remuneration Policy sets out the fundamental principles and structure governing the remuneration of Board members.
Its primary objective is to ensure that remuneration is:
•
Reasonable and aligned with market standards,
•
Gender-neutral, promoting equal treatment, and
•
Sufficiently competitive to attract and retain Directors with the necessary skills and experience to implement Eurobank
Holdings’ business strategy effectively.
Additionally, the Policy safeguards the long-term interests and sustainability of the organization by discouraging excessive risk-taking.
This is achieved through continuous monitoring of market trends and best practices at both domestic and global levels.
The Policy is informed by external and independent benchmarking analyses of remuneration in the financial and banking sectors,
both in Greece and internationally. This benchmarking ensures that the remuneration framework for Board members remains aligned
with industry best practices.
The development and implementation of the Remuneration Policy are characterized by:
•
Objectivity and transparency throughout the process, and
•
Independent judgment and discretion by the Board when approving or recommending remuneration, ensuring alignment
with both individual and Company performance.
Remuneration Report
In compliance with Article 112(3) of Law 4548/2018, Eurobank publishes an annual Remuneration Report, detailing the remuneration
and financial benefits granted to each Executive and Non-Executive Director during the financial year.
Prior to the merger of Eurobank and Eurobank Holdings, effected by the absorption of the latter by the former, Eurobank Holdings
had the legal responsibility to publish an annual Remuneration Report.
In this context, the Eurobank Holdings Remuneration Report for 2025 (https://www.eurobank.gr) was approved by the Annual
General Meeting of Eurobank Holdings on 30 April 2025 (before the completion of the merger).
The report provides comprehensive and transparent disclosure of Board remuneration, ensuring efficient communication with
shareholders and stakeholders.
Remuneration Structure
Non-Executive Directors
•
Fixed Remuneration Only: Non-Executive Directors receive fixed remuneration, which is annually approved by the Annual
General Meeting. They are not eligible for variable remuneration.
•
Board Fees: Their fixed remuneration consists of Board Fees, determined based on their roles on the Board and Committees,
their expected contribution, and the additional time and effort required for their responsibilities.
Executive Directors
•
Employment Contracts: Executive Directors are employed by the Bank under permanent, indefinite contracts. These
contracts require a three-month notice period in case of resignation.
•
Remuneration Structure:
-
Executive Directors receive remuneration under their employment contracts and do not receive additional
compensation for their role as Board members.
-
Variable Remuneration: Any variable remuneration awarded follows the provisions of the Bank’s Remuneration
Policy and is subject to approval by the Shareholders' General Meeting.
The 2025 Board and key management remuneration disclosure is included in the relevant note of the consolidated accounts of
Eurobank.
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To ensure market transparency regarding remuneration structures and associated risks, this information is publicly available on the
Eurobank website (www.eurobank.gr).
3.7
Board and Board Committees’ Attendance Policy
In accordance with the Board and Board Committees’ Attendance Policy of Eurobank – that was also applicable to Eurobank Holdings
during the period of its operation, until 12 December 2025 - Board members are expected to attend all Board and Committee
meetings to which they are appointed.
However, it is recognized that, on occasion, Board members may be unable to attend certain meetings due to conflicting
commitments or unforeseen circumstances.
To ensure active participation, each member must maintain a minimum attendance rate of 85% over the course of the calendar year.
Representation
Where a meeting is to be held with the notified absence of a Board member, the absentee has the option to be validly represented
by another Board member respectively, noting that each Member of the Board or Board Committee may validly represent only one
of the other Board or Board Committee members.
Representation in the Board and Board Committees may not be entrusted to persons other than the members thereof.
Resignation due to Unjustified Absence
Additionally, in accordance with Law 4706/2020, if a Board member is unjustifiably absent from at least two consecutive Board
meetings, they shall be considered resigned.
This resignation is formally established through a Board decision, which subsequently initiates the replacement process in accordance
with the applicable legal framework.
3.8
Directors’ Induction and Continuous Professional Development Process
All new Board members undergo a comprehensive Induction Program, designed to ensure a smooth and effective transition into their
roles.
Objectives of the Induction Program
The program aims to:
•
Communicate the vision and corporate culture of Eurobank,
•
Introduce practical and procedural responsibilities to facilitate a seamless onboarding process,
•
Accelerate productivity by reducing the time needed to familiarize new members with their roles,
•
Integrate new Directors as valued members of the Board,
•
Provide insight into the organizational structure of the Bank, and
•
Offer a comprehensive understanding of the business, strategy, market dynamics, key relationships, and leadership team of
the Bank.
Upon appointment, new Board members also receive a Manual of Obligations, which outlines their core responsibilities towards the
Supervisory Authorities and the Bank. This manual includes guidance on local regulatory requirements and Board procedures.
Additionally, newly appointed Directors participate in meetings and presentations with key executives to gain a holistic overview of
the organization.
Recognizing the importance of continuous professional development, Eurobank provides ongoing learning resources to support the
knowledge and skill enhancement of all Board members.
The above processes were applicable to Eurobank Holdings during the period of its operation, until 12 December 2025.
3.9
Group Governance Policy
In compliance with the regulatory framework, the Group Governance Policy of Eurobank (and Eurobank Holdings until 12.12.2025),
establishes general governance principles for the Group entities, sets common governance standards, and defines authorities,
responsibilities, and expectations, ensuring the Group operates as a unified entity with a cohesive strategic direction.
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Scope of the Policy
The policy integrates internal governance by clarifying the distinct roles of the parent company and its subsidiaries, while also setting
principles related to:
•
Board composition,
•
Roles and responsibilities,
•
Chairmanship,
•
Board committees,
•
Nomination processes,
•
Board diversity,
•
CEO succession planning,
•
Board evaluations,
•
Professional development,
•
Management committees,
•
Governance manuals, and
•
Corporate governance codes.
By harmonizing governance practices across the Group, the policy promotes accountability, transparency, and effective decision-
making at all levels.
3.10
Conflicts of interest Policy
Eurobank (and Eurobank Holdings until 12.12.2025) have implemented a Conflicts of Interest Policy, approved by their respective
Boards of Directors, to establish a comprehensive framework for identifying, preventing, and managing actual, potential, or perceived
conflicts of interest arising from the Group’s business activities.
This policy includes a structured set of policies, procedures, systems, and controls to uphold ethical standards and ensure transparent
decision-making.
Procedural Safeguards
To prevent conflicts of duties, the Group has implemented procedural safeguards that:
•
Segregate executive and non-executive responsibilities at the Board level, ensuring a clear distinction between the
Chairperson of the Board and the CEO’s executive functions,
•
Prevent incompatible roles and conflicts of interest among Board members, Management, and Executives, and
•
Mitigate the misuse of inside information or corporate assets.
Duties of Board Members
Board members are expected to:
•
Adhere to high ethical standards and comply with the principles set out in the Conflicts of Interest Policy,
•
Act independently, making sound, objective, and impartial decisions,
•
Disclose any personal interests that may conflict with the interests of Eurobank or the Group,
•
Maintain confidentiality of non-public information and avoid any conduct that could constitute market abuse or create a
conflict of interest.
Board members are required to disclose:
•
All external engagements, directorships, or affiliations outside the Group,
•
Any new or ongoing circumstances that could affect their independence of mind or create a conflict of interest.
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Management of Conflicts
All actual or potential conflicts of interest at the Board level must be:
•
Communicated, documented, and discussed,
•
Decided upon and managed by the Group,
•
Mitigated through specific measures for unexpected conflicts, while persistent conflicts are managed through continuous
oversight.
Board members must abstain from voting on matters where they have an identified conflict of interest, ensuring transparency,
impartiality, and effective governance.
3.11
Responsible Artificial Intelligence
In line with article 10 par. 3 of Law 4961/2022, which provides that companies preparing a corporate governance statement must
include information on the data ethics policy they apply in relation to artificial intelligence systems, Eurobank declares that it
strategically embraces Artificial Intelligence (AI) to drive innovation, operational excellence, and improve customer experience. In
doing so, the Bank remains firmly committed to upholding the highest standards of ethical conduct, regulatory compliance, and risk
governance. In accordance with its Responsible Artificial Intelligence Framework, all AI systems are developed and used in a manner
that is transparent, fair and secure. Eurobank ensures that AI enabled processes incorporate appropriate human oversight, safeguard
customer rights, and adhere to robust controls for data quality, privacy and model governance including measures to detect and
mitigate bias and to support explainability. The Bank continuously reviews and enhances these practices to reflect evolving risks,
technologies, and supervisory expectations.
3.12
Other Key Policies
In addition to the above policies, Eurobank has established, among others, the following policies, which form an integral part of their
corporate governance framework:
•
the Code of Conduct and Ethics,
•
the Anti-Bribery and Corruption Policy, and
•
the Policy for Reporting Illegal or Unethical Conduct or Violations of European Union Law.
These policies were also applicable to Eurobank Holdings during the period of its operation, until 12 December 2025.
4.
Shareholders’ General Meeting
The Shareholders’ General Meeting (General Meeting) serves as the highest authority within Eurobank – and until 12.12.2025 within
Eurobank Holdings - and is convened by the Board of Directors to address all matters concerning the entity.
Competence and Authority
It holds exclusive jurisdiction over matters specified in Article 117 of Company Law 4548/2018, including amendments to the Articles
of Association.
Every shareholder has the right to participate and vote at the General Meeting, either in person or through a legal representative, in
accordance with the prescribed legal procedures.
Quorum and Majority Requirements
For the General Meeting to reach a quorum and be considered valid, shareholders present or represented must collectively hold at
least 20% (1/5) of the paid-in share capital associated with voting shares.
Resolutions are passed by an absolute majority and are binding on both absent and dissenting shareholders.
However, for significant decisions such as share capital changes or mergers:
•
a higher quorum of at least 50% (1/2) of the paid-in share capital is required, and
•
resolutions must be approved by a two-thirds (2/3) majority.
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Annual and Extraordinary General Meetings
According to Article 119(1) of Law 4548/2018, the Annual General Meeting must be held no later than the tenth (10th) calendar day
of the ninth month following the end of the business year.
Additionally, an Extraordinary General Meeting may be convened by the Board of Directors when deemed necessary or required by
law.
Minutes and Minority Rights
Minutes of the General Meeting are authenticated by the Chairperson and the Secretary of the meeting.
The standard minority rights outlined in Company Law 4548/2018 apply.
4.1
Information about the Eurobank General Meetings
Taking into account that, until the completion of the merger on 12 December 2025, Eurobank Holdings was the sole shareholder of
Eurobank, holding 100% of its share capital and in accordance with Article 121(5) of Law 4548/2018, a formal invitation to convene a
General Meeting was not required, provided that the meeting was attended or represented by shareholders holding the entire share
capital and none objected to its convening or decision-making.
In this context, the following General Meetings of Eurobank were held.
4.1.1
Annual General Meeting (AGM) of the shareholders
The Annual General Meeting of Eurobank’s shareholders was held on April 30, 2025, in Athens, at Eurobank’s Headquarters, 12
Stadiou Street & 2 Omirou Street.
The sole shareholder, Eurobank Holdings, participated, representing 3,683,244,830 shares, corresponding to 100% of the paid-up
share capital with voting rights on the agenda items.
The Annual General Meeting:
1.
Approved the Annual Separate and Consolidated Financial Statements for the financial year 2024, along with the Directors’
and Auditors’ Reports.
2.
Approved the overall management for the financial year 2024 and the discharge of the Auditors for the same period.
3.
Appointed KPMG Certified Auditors S.A. as Auditors for the financial year 2025.
4.
Approved the dividend distribution to the sole shareholder, amounting to €405 m, from the “Special Reserves” account and
authorized the Board of Directors to do everything necessary or appropriate in the context of the implementation of this
decision of the AGM.
5.
Approved the distribution of net profits to executives and employees of the Bank.
6.
Approved, pursuant to Article 86 of Law 4261/2014, a higher than 100% maximum level of the ratio between fixed and
variable remuneration for eight executives.
7.
Approved the remuneration for the financial year 2024 and the advance payment of remuneration for the Directors for the
financial year 2025.
8.
Was informed on the Annual Activity Report of the Audit Committee for the financial year 2024.
4.1.2
Extraordinary General Meeting (EGM) of the shareholders, September 25, 2025
An Extraordinary General Meeting of Eurobank’s shareholders was held on September 25, 2025, in Athens, at Eurobank’s
Headquarters, 12 Stadiou Street & 2 Omirou Street, following the decision of the Board of Directors dated September 24th, 2025 and
pursuant to article 121, par. 5 of L. 4548/2018, as in force.
The sole shareholder, Eurobank Holdings, participated, representing 3,683,244,830 shares, corresponding to 100% of the paid-up
share capital with voting rights on the agenda items.
The Extraordinary General Meeting:
1.
Approved the listing for trading of total shares of the Bank on the Regulated Market (Main Market) of the Athens Stock
Exchange and the Cyprus Stock Exchange, authorized senior executives of the Bank to represent Eurobank and take all
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necessary actions and approved the appointment of “Eurobank Equities Single Member Investment Firm S.A.” as Listing
Advisor.
2.
Approved the amendment of the Nomination Policy of the Directors.
3.
Approved the Remuneration Policy for Directors.
4.
Approved the amendment of the Articles of Association of the Bank, with amendment, addition and renumbering of its
articles, in order to comply with the legal provisions regarding listed companies; and authorized senior executives of the
Bank to sign any related documentation and to proceed with any relevant, necessary or deliberate action to complete the
amendment of the Bank’s Articles of Association.
4.1.3
Extraordinary General Meeting (EGM) of the shareholders, October 22, 2025
An Extraordinary General Meeting of Eurobank’s shareholders was held on October 22, 2025, in Athens, at Eurobank’s Headquarters,
12 Stadiou Street & 2 Omirou Street, following the decision of the Board of Directors dated October 22nd, 2025 and pursuant to
article 121, par. 5 of L. 4548/2018, as in force.
The sole shareholder, Eurobank Holdings, participated, representing 3,683,244,830 shares, corresponding to 100% of the paid-up
share capital with voting rights on the agenda items.
The Extraordinary General Meeting, unanimously:
1.
Approved a) the Draft Merger Agreement with its annexes (including the transformation balance sheets of the Absorbed
Company and the Absorbing Company with reference date 31 December 2024), the amendment to Clause 1.6. and (b) the
Merger of “Eurobank S.A.” with “Eurobank Ergasias Services and Holdings S.A.” by absorption of the latter by the former, in
accordance with the provisions of Articles 6–21, 30–34 and 140 of Law 4601/2019, Article 16 of Law 2515/1997, and the
applicable provisions of Law 4548/2018, as in force, and under the specific terms and conditions set out in the Draft Merger
Agreement and the rest of the documents, as submitted to the General Meeting.
2.
Approved the amendment of Article 5 of the Bank’s Articles of Association, following increase and reduction of the share
capital of the Bank, as a result of the Merger, and authorized senior executives of the Bank, to sign any related
documentation and to proceed with any relevant, necessary or deliberate action to complete the amendment of the Bank’s
Articles of Association.
3.
Approved the share buyback programme (as a continuation of the programme of “Eurobank Ergasias Services and Holdings
S.A.”) and authorized the Board of Directors to determine at its discretion any other detail and take all necessary actions,
delegating the relevant authorities to the appropriate individuals for the implementation of the Programme.
4.
Approved the Stock Options Plan (as a continuation of the Stock Options Plan established by “Eurobank Ergasias Services
and Holdings S.A.”).
4.2
Information about the Eurobank Holdings General Meetings
Requirements for calling and convening the General Meetings
Until the completion of the merger on 12 December 2025, when Eurobank Holdings was absorbed by Eurobank and ceased to be
listed while Eurobank became the listed entity, all persons registered as shareholders of ordinary shares of Eurobank Holdings in the
Dematerialized Securities System (DSS), managed by Hellenic Central Securities Depository S.A., on the Record Date—specifically, at
the start of the fifth day before the General Meetings were entitled to participate and vote in the HoldCo General Meetings.
This Record Date also applied to any Repeat Meetings.
Shareholders were informed in advance about the agenda of each General Meeting, and new technologies were utilized to facilitate
their participation.
At least 20 days before the meetings, shareholders were provided with access to all necessary information, in full compliance with
Greek law.
The Notice of each General Meeting included:
•
The date, time, and place of the meeting,
•
The agenda items, presented in clarity,
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•
Participation and voting rights, along with the relevant procedures,
•
The rights of minority shareholder, and
•
The documents and information made available to shareholders.
All resolutions and related information from each General Meeting were published under the Investor Relations section of the
Eurobank Holdings website.
Participation and proxies
Eurobank Holdings facilitated shareholder participation in General Meetings.
All shareholders had the right to attend in person or appoint a proxy, provided that the proxy was designated at least 48 hours before
the meeting.
If shareholders' questions regarding agenda items were not addressed during the General Meeting, Eurobank Holdings had a
structured process in place to provide the relevant responses.
4.2.1
Annual General Meeting (AGM) of the shareholders
The Annual General Meeting of Eurobank Holdings’ shareholders was held on April 30, 2025, at 10 a.m., remotely via teleconference
in real-time.
Shareholders representing 2,895,478,195 shares out of 3,676,736,329 shares, corresponding to 78.75% of the paid-up share capital
with voting rights.
The Annual General Meeting:
1.
Approved, with a majority exceeding the minimum required by law, the Annual Separate and Consolidated Financial
Statements for the financial year 2024, along with the Directors’ and Auditors’ Reports.
2.
Approved, with a majority exceeding the minimum required by law, the overall management for the financial year 2024, as
well as the discharge of the Auditors for the same period.
3.
Approved, with a majority exceeding the minimum required by law:
(a)
The appointment of the firm KPMG Certified Auditors S.A. (KPMG) as the statutory auditor of the Annual Separate
and Consolidated Financial Statements of the Company for the financial year 2025 as well as for the audit and
assurance of the submission of the Sustainability Statement, according to the provisions of article 154C of l.
4548/2018, for the financial year 2025; and
(b)
KPMG’s fees for the statutory audit of the Annual Separate and Consolidated Financial Statements of the Company
for the financial year 2025 to amount to €0.3 m. and to €0.3 m. for the audit and assurance of the submission of
the Sustainability Statement, according to the provisions of article 154C of l. 4548/2018, for the financial year 2025.
4.
Approved, with a majority exceeding the minimum required by law, the dividend distribution to shareholders, amounting
to €386 million, from the “Special Reserves” account, and authorized the Board of Directors to undertake all necessary
actions for its implementation.
5.
Approved, with a majority exceeding the minimum required by law, the distribution of a total amount of €437,670 to
executives and employees of the Company from the “Special Reserves” account.
6.
Approved, with a majority exceeding the minimum required by law:
a) a share buyback programme (“Programme”), in accordance with the terms and conditions provided by Article 49 of Law
4548/2018, under the following terms:
(i)
the total cost of the Programme that will not exceed the amount of € 287,942,685.45, and in any case, the
own shares that will be acquired will not exceed 10% of the Company’s paid-in Share Capital, in accordance
with the legislation in force;
(ii)
the duration of the Programme, which will not exceed 12 months, starting from the day of receipt of ECB’s
decision granting supervisory permission of the Programme; and
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(iii)
the proposed range for the acquisition of the shares under the Programme, which sets as minimum price, the
nominal value of the share i.e. €0.22 and as maximum price the €10; and
b) authorized the Board of Directors to determine at its discretion any other detail and take all necessary actions, delegating
the relevant authorities to the appropriate individuals, for the implementation of the Programme.
7.
Approved, with a majority exceeding the minimum required by law, in accordance with Article 86 of Law 4261/2014, a higher
than 100% maximum level of the ratio between fixed and variable remuneration for the CEO, Deputy CEO Group Chief
Οperating Οfficer & International Activities, Deputy CEO Head of Corporate & Investment Banking, Deputy CEO Head of
Retail & Digital Banking, General Manager Group Risk Management, the General Manager Group Finance, the General
Manager Group Strategy and the General Manager Markets.
8.
Approved, with a majority exceeding the minimum required by law, the amendment of the Remuneration Policy for
Directors of the Company.
9.
Approved, with a majority exceeding the minimum required by law, the remuneration paid to Board members for the
financial year 2024, for their duties as Board members and Board Committees members, and the payment of the
remuneration for the financial year 2025.
10.
Casted a positive vote on the Remuneration Report for the financial year 2024.
11.
Approved, with a majority exceeding the minimum required by law, the amendment of Article 12 of the Company’s Articles
of Association by updating paragraph 2 of article 12.
12.
Was informed on the Annual Activity Report of the Audit Committee for the financial year 2024.
13.
Was informed on the Independent Non-Executive Directors’ Report.
All information regarding the AGM of Eurobank Holdings can be found on the Eurobank website.
4.2.2
Extraordinary General Meeting (EGM) of the shareholders, December 3, 2025
The Extraordinary General Meeting of Eurobank Holdings’ shareholders was held on December 3, 2025, at 10 a.m. in a hybrid manner,
namely, with the physical presence of Shareholders in the Conference Hall of Nea Ionia, at 8 Iolkou Street, Building H, Nea Ionia, GR
14234, and with the participation of Shareholders remotely, in real time, via teleconference.
Shareholders representing 2,891,575,831 shares out of 3,631,510,801 corresponding to 79.62% of the paid-up share capital with
voting rights.
The Extraordinary General Meeting:
1.
Approved the Draft Merger Agreement with its annexes (including the transformation balance sheets of “Eurobank Ergasias
Services and Holdings S.A.” and “Eurobank S.A.”, with reference date 31 December 2024), with the amendment to Clause
1.6.
2.
Approved the Merger of the Bank with the Company by absorption of the latter by the former, in accordance with the
provisions of Articles 6–21, 30–34 and 140 of Law 4601/2019, Article 16 of Law 2515/1997, and the applicable provisions of
Law 4548/2018, as in force, and under the specific terms and conditions set out in the Draft Merger Agreement, as approved
above, and the rest of the documents, as submitted to the General Meeting.
3.
Authorized senior executives to appear before a notary public and, on behalf of the Absorbed Company, execute the notarial
deed of merger of the Bank with the Company by absorption of the latter by the former, determining the specific terms of
the notarial merger deed within the framework of the approved Draft Merger Agreement, and to sign any other document,
application, declaration, or certificate etc. as may be required for the completion of the Merger.
4.
Authorized the Board of Directors to resolve any matter that may arise in connection with the approved Merger, at its
absolute discretion.
5.
Board of Directors
5.1
The Bank is managed by the Board of Directors (Board or BoD), which bears collective responsibility for its long-term success.
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The Board exercises its duties in compliance with Greek legislation, international best practices, its Articles of Association, and the
legitimate decisions of the shareholders’ General Meetings.
The Board’s role is to provide entrepreneurial leadership to the Group within a framework of prudent and effective controls, enabling
the identification, assessment, and management of risks.
It establishes the Group's strategic objectives, ensures the availability of financial and human resources necessary to achieve these
objectives, and evaluates management performance.
Additionally, the Board defines the Group’s values and standards, ensuring that its responsibilities towards shareholders and other
stakeholders are recognized and fulfilled.
All Board members are required to act in the best interests of the Group, in full alignment with their legal duties.
The same principles were also applied to Eurobank Holdings and its Board of Directors throughout their period of operation, up to 12
December 2025.
5.2
Composition of the Board
The members of the Eurobank Board are elected by the General Meeting of Eurobank, which determines the exact number of
directors and their term of office, in accordance with legal provisions and the Articles of Association of both entities.
The General Meeting also designates the independent non-executive directors.
The above principles were also applicable to HoldCo and its Board throughout their period of operation, up to 12 December 2025.
For efficiency reasons, the composition of HoldCo’s BoD was identical to that of Eurobank’s BoD throughout its period of operation,
up to 12 December 2025.
Election and Term
The Boards of HoldCo and Eurobank were elected by the AGMs of HoldCo and Eurobank respectively on July 23, 2024, for a three-
year term, extending until the AGMs of 2027.
The AGMs also designated the independent non-executive members of the Boards.
The new BoDs, in accordance with the BoD decisions dated May 30, 2024, and June 28, 2024, following the NomCos'
recommendations on May 28, 2024, and June 26, 2024, comprised:
•
twelve (12) re-elected previous Board members, and
•
one (1) newly elected member, Mr. Evangelos Kotsovinos.
In accordance with the above AGM decisions and the NomCos’ recommendations dated May 28, 2024, and June 26, 2024, the new
BoDs, in their meeting of July 23, 2024, decided on:
•
their constitution,
•
the appointment of the Chief Executive Officer (CEO) and Deputy Chief Executive Officers (DCEOs), and
•
the designation of executive and non-executive directors.
Resignation of Independent Director
On 18 June 2025, Mr. Jawaid Mirza, Non-Executive Independent Member of the Boards of Directors of Eurobank Holdings and
Eurobank, submitted his resignation, effective as of 27 June 2025.
The resignation was due to no longer fulfilling the independence criteria of Article 9 of Law 4706/2020, as he had cumulatively served
nine (9) years as a member of the Company’s and the Bank’s BoDs.
Composition as at 12 December 2025
Following these developments:
•
as of the completion of the merger on 12 December 2025, the HoldCo BoD; and
•
as of the date of approval of this Statement, the Bank Board,
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consisted of twelve (12) directors, categorized as follows:
•
Three (3) executive directors – representing 25% of the Board,
•
Two (2) non-executive directors – representing 17% of the Board, and
•
Seven (7) independent non-executive directors – representing 58% of the Board.
Name
Position
Eurobank Holdings
Eurobank
First
appointment
due to merger
First
appointment
End of
Term
Georgios P. Zanias
Chairperson, Non-Executive Director
Mar. 2019
12 December 2025
Mar. 2020
2027
Fokion C. Karavias
Chief Executive Officer
Jun. 2014
12 December 2025
Mar. 2020
2027
Stavros E. Ioannou
Deputy Chief Executive Officer
Apr. 2015
12 December 2025
Mar. 2020
2027
Konstantinos V. Vasileiou
Deputy Chief Executive Officer
July 2018
12 December 2025
Mar. 2020
2027
Bradley Paul L. Martin
Non-Executive Director
Jun. 2014
12 December 2025
Mar. 2020
2027
Rajeev Kakar
Non-Executive Independent Director
July 2018
12 December 2025
Mar. 2020
2027
Alice K. Gregoriadi
Non-Executive Independent Director
Apr. 2020
12 December 2025
Apr. 2020
2027
Irene Rouvitha Panou
Non-Executive Independent Director
Apr. 2020
12 December 2025
Apr. 2020
2027
Cinzia V. Basile
Non-Executive Independent Director
Dec. 2020
12 December 2025
Dec. 2020
2027
Burkhard Eckes
Non-Executive Independent Director
Jul. 2023
12 December 2025
Jul. 2023
2027
John Arthur Hollows
Non-Executive Independent Director
Jul. 2023
12 December 2025
Jul. 2023
2027
Evangelos Kotsovinos
Non-Executive Independent Director
Jul. 2024
12 December 2025
Jul. 2024
2027
The average tenure of BoD members stands at (6.5) years.
5.3
CVs of Board Board members and Secretary
The short CVs of Eurobank Board members, summarized below (the CVs of the Board may be found at the Bank website
https://www.eurobank.gr/en/group/about-eurobank/corporate-governance/board-of-directors/the-bod-members
), demonstrate
that the Board’s composition aligns with the knowledge, skills, and experience necessary for the effective execution of their duties.
This is in accordance with the Board Nomination Policy and the business model and strategy of Eurobank.
Additionally, the directorships held by Eurobank Board members as of December 31, 2025, are outlined in Section "Directorships of
Board Members".
Georgios Zanias - Chairperson, Non-Executive Director
-
Membership in Board Committees: Nomination and Corporate Governance Committee – Member
-
Year of birth: 1955
-
Nationality: Hellenic
-
Number of shares in Eurobank: None
Mr. Zanias joined Eurobank as the Chairman of the Board of Directors in 2019. He is also a Professor Emeritus of Economics at the
Athens University of Economics and Business, Chairman of the Hellenic Bank Association (HBA) ,Board Member of the European
Banking Federation (EBF) and a Member of the Board of IOBE.
In the past, Mr Zanias has served as the Minister of Finance (2012), Chairman of the Board of Directors of the National Bank of Greece
(2012-2015), Chairman of the Board of the Hellenic Banking Association (2012-2015), Member of the Board of the European Banking
Federation (2012-2015), Member of the Board of the American-Greek Chamber of Commerce ( 2019-2022), Chairman of the Council
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of Economic Advisors at the Ministry of Finance (2009-2012), General Secretary of the Ministry of Economy and Finance (2001-2004),
Chairman and Scientific Director of the National Economic Institute (KEPE) (1998-2001).
He has also served as a Director on the Boards of Hellenic Exchanges (2000-2001), Public Debt Management Office (PDMA) (2009-
2012), General Bank (1997-1998), CHIPITA SA (2015-2019), the European Financial Stability Mechanism (EFSF/ESM) (2010-2012). Also:
Member of the Board of Governors of the Black Sea Trade and Development Bank (2003-2004), Alternate Governor of the Board of
Governors of EBRD (2002-2004), Member of the European Securities Committee (2001-2002), Member of the Monetary Policy
Committee of the Bank of Greece (May-July 2012), Chairman of the Board of Directors of Piraeus Real Estate SA and Picar SA (2017-
2019), Vice Chairman of the Board of ETVA Industrial Zone SA (2018-2019).
He holds a Doctorate from Oxford University, an M.Sc. for the University of Reading and a B.Sc. from the Athens University of
Economics and Business.
Fokion Karavias-Chief Executive Officer (CEO)
-
Membership in Board Committees: None
-
Year of birth: 1964
-
Nationality: Hellenic
-
Number of shares in Eurobank: 1,311,488
Mr. Karavias has served as Chief Executive Officer of Eurobank since February 2015 and has been an Executive Member of the Board
of Directors since 2014. He joined Eurobank in 1997, initially leading fixed income and derivative product trading. Over the years, he
held various key positions, including Deputy General Manager and Treasurer (2002-2005), General Manager and Executive Committee
Member (2005-2013), and Senior General Manager overseeing Group Corporate & Investment Banking, Capital Markets, and Wealth
Management (2014-2015).
Previously, Mr. Karavias held several key positions including Treasurer at Telesis Investment Bank in 2000 and Head of Fixed Income
Products and Derivatives for Citibank in Athens from 1994 to 1997. He began his banking career in 1991 at JP Morgan in New York,
working in the Market Risk Management Division.
He is currently a Member of the Board of Directors at the Hellenic Bank Association (HBA), a Member of the General Council of the
Hellenic Federation of Enterprises (SEV), and an Honorary Member of The Greek Tourism Confederation (SETE). His previous roles
include serving on the Board of Directors of Eurobank Private Bank Luxembourg SA from 2012 to 2022 and as a Member of the Board
of Directors at the Athens Stock Exchange from 2013 to 2015.
He holds a PhD in Chemical Engineering from the University of Pennsylvania, Philadelphia, USA and an MA in Chemical Engineering
from the same university, as well as a Diploma in Chemical Engineering from the National Technical University of Athens.
Stavros Ioannou-Deputy Chief Executive Officer (CEO), Group Chief Operating Officer (COO) & International Activities
-
Membership in Board Committees: Board Digital and Transformation Committee - Member
-
Year of birth: 1961
-
Nationality: Hellenic
-
Number of shares in Eurobank: 236,529
Mr. Ioannou holds several other posts in the Eurobank Group as Head of International Activities & Group Private Banking, Member
of the BoD of Eurobank Private Bank Luxembourg S.A (since October 2024), Member of the Supervisory Board of Eurobank Bulgaria
AD (since October 2015), Member of the BoD of Eurobank Limited (since October 2025) and is also the Chairman of the BoD inBE-
Business Exchanges SA (since January 2014). He has been appointed as the responsible BoD member Eurobank for climate-related
and environmental risks and for the outsourcing function.
He is currently Non-Executive Board member of Grivalia Management Company S.A. (since September 2019).
In the past, Mr. Ioannou had also the following significant posts: he was appointed Chief Executive Officer at Eurobank A.D. Beograd
(2005-2008), Chairman of the Executive Committee in the Hellenic Banking Association (2020-2022) where he had been member
since 2013, Vice Chairman at Cardlink SA (2013-2015), Member of the BoD in Millennium Bank, responsible for Retail, Private Banking
and Business Banking (2003), Head at Barclays Bank PLC, responsible for Retail Banking, Private Banking and Operations (1990-1997).
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He holds an MA in Banking and Finance from the University of Wales, UK and a Bachelor Degree in Business Administration from the
University of Piraeus.
Kostas Vassiliou-Deputy Chief Executive Officer (CEO), Head of Corporate & Investment Banking
-
Membership in Board Committees: None
-
Year of birth: 1972
-
Nationality: Hellenic
-
Number of shares in Eurobank: 235,001
Mr. Vassiliou currently holds several key positions within the Eurobank Group, including Chairman of the Board of Directors of
Eurobank Factors Single Member SA since December 2018.
Additionally, he serves as Vice-Chairman of the Board of Directors of Eurolife FFH Insurance Group Holdings SA (since January 2021),
Eurolife FFH Life Insurance SA (since December 2020), and Eurolife FFH General Insurance SA (since December 2020). He is also a
Non-Executive Director of Marketing Greece S.A..
Previously, Mr. Vassiliou served as a Non-Executive Director of Hellenic Exchanges – Athens Stock Exchange S.A. and as a Member of
the Board of Directors of Eurobank Equities Single Member S.A. His earlier career includes significant roles at Mitsubishi UFJ Financial
Group in London, where he was Country Manager for Greece, Cyprus, and the Balkans (2000-2005), and Senior Relationship Manager
(1998-2000).
He holds an MBA from Boston University, USA and a BA in Business Administration from the Athens University of Economics and
Business.
Alice Gregoriadi-Independent Non-Executive Director
-
Membership in Board Committees: a) Audit Committee – Member, b) Remuneration Committee – Member, c) Board Digital
and Transformation Committee – Chairwoman
-
Year of birth: 1968
-
Nationality: Hellenic
-
Number of shares in Eurobank: None
Mrs. Gregoriadi also serves as an Affiliate Partner – Management Consultant at True North Partners LLP, London, UK and is a Non-
Executive Board Director at CGI Greece - Climate Governance Initiative Greece and as a Non-Executive Director / Founding Member
at Hellenic Blockchain Hub.
In the past, Mrs. Gregoriadi had also the following significant posts: Hellenic Corporation of Assets & Participations (HCAP), Greece,
Non-Executive Board member, Audit Committee member, Corporate Governance and Nominations Committee member (February
2017 – February 2021), JPMorgan, London, UK, various posts as Managing Director (February 2010 – May 2015), IBOS Board Director
(April 2010 – August 2014), ABN Amro Bank, Amsterdam, Netherlands & London, UK, various posts as Managing / Executive Director
(November 2001 – December 2009), Citibank NA, London, UK, various Senior Executive Director posts (February 1994 – August 2001),
Clearing House Automated Payments System (CHAPS), UK, Board Director (June 1997 – July 2000).
She holds an MBA from the Manchester Business School, UK (1991-1993), including an MBA international exchange program from
the E.J.Cox School of Management, Texas, USA – (1992), an Executive Certification on Blockchain for business from University College
London (2019), an Executive Certification on eCommerce from the Darden School of Business, Virginia University, USA (2000) and a
BSc in Business Administration from the The American College, Athens, (1987-1990).
Rajeev Kakar-Independent Non-Executive Director
-
Membership in Board Committees: a) Audit Committee – Member, b) Board Risk Committee – Chairman, c) Nomination &
Corporate Governance Committee – Member
-
Year of birth: 1963
-
Nationality: Indian
-
Number of shares in Eurobank: None
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Mr. Kakar is a senior international banker with 37 years of financial services experience, and currently also serves as a board member
of several Financial Institutions- including Gulf International Bank Group Board (Bahrain), Gulf International Bank (Saudi Arabia) and
a Board Member at Pan-IIM, Indian Institutes of Management. In the past Mr. Kakar has also served as board member on several
international financial institutions/bank boards - eg., as Board Member of Commercial International Bank (CIB) (2019 – 2025), as a
Global Advisory Board member at the University of Chicago’s Booth School of Business, as Board Member of Visa International
CEEMEA (United Kingdom 2004-2006), Global Management Board member of Fullerton Financial Holdings (Singapore 2006-
2018), Board member of UTI AMC in India (2019-2024), Chairman of the BoD, Fullerton Securities & Wealth Advisors (New Delhi,
India 2008-2017), board Member of Fullerton India Credit Company (India 2009-2017), Member of the Board of Commissioners, Adira
Dinamika Multi Finance Tbk, subsidiary of Bank Danamon (Indonesia 2010-2013), etc.
Between 2006-2018, Mr. Kakar served as the Global Co-Founder of Fullerton Financial Holdings (Singapore) - a wholly owned
subsidiary of Temasek Holdings, Singapore. In this role, he also concurrently served as Fullerton’s Global CEO of Consumer Banking,
Regional CEO for Central Europe, Middle East and Africa, and also as the Founder, Managing Director and CEO of Dunia Finance
(Fullerton’s UAE subsidiary). Prior to 2016, he was at Citibank for 20 years working across various countries and held various senior
management positions, including, his most recent Citibank assignment where he served as the Regional CEO & Division Executive for
Citibank-Turkey, Middle East and Africa until Jan 2006.
Mr. Kakar holds an MBA, Finance & Marketing from the Indian Institute of Management, Ahmedabad (India) and a Bachelor of
Technology, Mechanical Engineering from the Indian Institute of Technology (India).
Bradley Paul Martin-Non-Executive Director
-
Membership in Board Committees: None
-
Year of birth: 1959
-
Nationality: Canadian
-
Number of shares in Eurobank Holdings: 122,500
In the past Mr. Martin has also served as: Vice President of Fairfax Financial Holdings (1998 - 2024), Vice President, Strategic
Investments of Fairfax Financial Holdings (2012 - 2024), Member of the BoD, Bank of Ireland (2013-2017), Chief Operating Officer
(COO), Fairfax Financial Holdings (2006-2012) and Partner, Torys LLP law firm (before 1998).
Mr. Martin also serves as Non-Executive Director, of AGT Food and Ingredients Inc., of Blue Ant Media Corporation, of G.S. Dunn
Limited and of Universal Matter Inc..
He holds a ΒΑ from Harvard University, USA and an LLB from the University of Toronto, Canada.
Irene Rouvitha Panou-Independent Non-Executive Director
-
Membership in Board Committees: a) Nomination & Corporate Governance Committee – Chairwoman, b) Audit Committee
– Member, c) Remuneration Committee - Member
-
Year of birth: 1958
-
Nationality: Cyprus
-
Number of shares in Eurobank: None
Mrs. Rouvitha Panou is a highly accomplished international leader with over three decades of cross-border financial services
experience in strategy, governance, organizational & digital transformation, audit and compliance. Throughout her career she has
consistently attained sustainable corporate growth by initiating and implementing key strategic initiatives, driving corporate
turnarounds, enhancing governance frameworks and fostering innovation. She has contributed to the drastic upgrade and digital
evolution of critical services in Cyprus, a country of strategic importance to Eurobank. Her work spans across Cyprus, Greece, Central
Europe, the UK, the USA and Australia, providing her with broad international exposure in banking, financial services and
telecommunications.
She served as Chair of the Board of Cyta (Cyprus’ leading integrated electronic communications provider) for two consecutive tenures
(July 2016-July 2021) and Chair of the Management Committee of the Pensions & Grants Fund of the Personnel of Cyta (January 2019-
July 2021). Her leadership at Cyta focused on driving major M&A and pivotal digital transformation initiatives, which contributed to
the modernization of Cyprus’ telecommunications and digital infrastructure. These include the early rollout of 5G & Fiber-
To
-The-
Home (FTTH) technologies, innovative smart city activities and significant forward-looking ESG projects.
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Previously, she had been Chair of the Board of the Cyprus Development Bank following its privatization (September 2008-April 2014)
and Board Member of the Cyprus Employers and Industrialists Federation (May 2020-July 2021). She was Independent Non-Executive
Director and Chair or Member of Board Committees at the Cyprus Asset Management Company KEDIPES (March 2023-June 2024),
Alpha Bank subsidiaries in Romania, Cyprus and Greece (November 2014-April 2020) and Vassiliko Cement public company (February
2012-October 2014). She was Managing Director of Laiki Bank Hellas SA (April 2002-November 2006) and Group General Manager of
Cyprus Popular Bank (HSBC associate bank) (January 2000-November 2006), also serving as Group Board Director and Member of the
Group’s banking subsidiary Boards in Greece and Australia. Between June 1984 and September 1991 she worked in Boston USA,
where she held senior positions in the field of management and financial services consulting.
Apart from her engagement with Eurobank, Mrs. Rouvitha Panou is currently Non-Executive Board Director of the Aik Group (CY)
Limited in the field of banking and financial services. She is also a committed Board Member in academic, social and philanthropic
organisations internationally, serving as Trustee of the UK-based Stelios Philanthropic Foundation, Member of the International
Advisory Committee of Komvos Global Hellenism Network and Member of the Advisory Council of the School of Economics &
Management at the University of Cyprus.
She graduated from the London School of Economics, UK (B.Sc. Economics, Metcalfe Scholar) with postgraduate studies at the
University of Cambridge, UK (M.Phil. Economics) and the Massachusetts Institute of Technology, USA (M.Sc. Management, Fulbright
Scholar).
Cinzia Basile-Independent Non-Executive Director
-
Membership in Board Committees: a) Board Risk Committee – Member, b) Remuneration Committee – Chairwoman, c)
Board Digital and Transformation Committee – Member
-
Year of birth: 1971
-
Nationality: Italian / British
-
Number of shares in Eurobank: None
Mrs Basile is the Chairperson of Amova Asset Management Europe, one of Asia’s largest asset managers; she also Chairs the HR
Advisory Committee and is a member of the Risk & Stewardship Committee.
Mrs Basile is a highly accomplished financial leader with deep expertise in the financial sector, asset management, and strategic
growth. In addition, she is a Non-Executive Director at Amova Global Umbrella Fund and Zenith Global S. p.A..
In the past, Mrs. Basile had also the following significant posts: she set up and ran Credit Suisse AG’s Investment Bank multi-asset
investment management business (Custom Markets) in the UK, Ireland and Luxembourg, Non-Executive Member of the BoD and
Chair of the Operating and Risk Committee of Credit Suisse Custom Markets, a sponsored management company of Credit Suisse
located Luxembourg (August 2011 – August 2017), Non-Executive Member of the BoD and Chair of the Operating of Custom Markets
plc and Custom Markets QIAF, sponsored management companies of Credit Suisse located in Ireland (August 2011 – August 2017),
Non-Executive Member of the BoD and Chair of the Operating and Risk Committee of Custom Markets QIAF a subsidiary of Credit
Suisse located in Ireland (August 2011 – August 2017).
She is a fellow at the CSaP's Dowling Policy Fellowship, Cambridge University. The fellowship's mission is to help public policy-making
address the major challenges of the 21st century by drawing more effectively on the best research, evidence, and expertise. Fellows
share a common interest in advancing policies that support science, innovation, and entrepreneurship in the public interest.
She holds a Juris Doctor Degree from the University of Rome “La Sapienza”, Italy and she was awarded a Thesis Scholarship (derivative
instruments), London School of Economics, UK.
John Arthur Hollows-Independent, Non-Executive Director
-
Membership in Board Committees: a) Board Risk Committee – Vice Chairman, b) Board Digital and Transformation
Committee – Member, c) Remuneration Committee - Member
-
Year of birth: 1956
-
Nationality: British
-
Number of shares in Eurobank: None
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Mr. Hollows served for 26 years in the KBC Group as Member of the Boards of Directors, KBC Bank and KBC Insurance (2009-2022),
Member of the Executive Committee, KBC Group (2009-2022), Chair of the Board of Directors of Československá obchodní banka, a.
s. (ČSOB) and CEO (2014-2022), Member of the Board of Directors of KBC Group N.V., Group Chief Risk Officer (2010-2014), CEO,
Central and Eastern Europe and Russia (2009-2010), Senior General Manager, Banking, Central Europe Business Unit, KBC Group,
Brussels (2006-2009), CEO, Kereskedelmi es Hitelbank Rt., Hungary (2003-2006), General Manager, Asia Pacific, KBC Bank N.V. (1999-
2003), General Manager, Shanghai Branch, KBC Bank N.V. (1997-1999) and Commercial Banking Head, Hong Kong Branch, Kredietbank
N.V (1996).
In the past. Mr. Hollows served at Barclays Bank PLC as Chief Manager, Taipei Branch (1991-1995), Head of International Trade
Services, London (1989-1991), Manager, Export Finance Department, London (1986-1989), Corporate Manager, Watford Branch
(1984-1986), Assistant Manager, Cost Control Unit, General Manager’s Office (1982-1984) and Graduate Trainee (1978-1982). He has
also served as Chair, European Council of Commerce and Trade (1994-1995) and Deputy Chair, British Exporters Association (1989-
1991).
He holds a Master of Arts, Sidney Sussex College, Cambridge (law and economics).
Burkhard Eckes - Independent, Non-Executive Director
-
Membership in Board Committees: a) Audit Committee – Chairman, b) Nomination and Corporate Governance Committee
– Member, c) Board Risk Committee - Member
-
Year of birth: 1960
-
Nationality: German
-
Number of shares in Eurobank: None
Mr. Eckes served for more than 30 years at PwC. He was Senior Advisor, of PwC Germany and EMEA (Europe, Middle East and Africa)
(2022 - 2023)
in Banking & Capital Markets (BCM), Global BCM ESG
Leader and member of the Global Financial Services (FS) ESG
Leadership Team (2019 - 2022), responsible for BCM activities in ESG consulting globally, EMEA BCM Leader and member of the EMEA
FS Leadership Team (2017 - 2022), responsible for BCM client relationships, projects and strategy in consulting and assurance services,
including development and implementation of banking strategies, business models, supervisory and regulatory requirements and
practices, governance, risk management, accounting and reporting best practices, ESG, bank restructuring and bank transformation
advice, Member of the Global BCM Leadership Team (2009 - 2022), German BCM Leader and member of the German FS Leadership
Team (2009 - 2018), responsible for consulting and assurance services, including HR, people development and statutory audits of
large German banks, Chair of the Global Banking International Accounting Group (2002 - 2023) and Partner (1996 - 2022).
Mr. Eckes also serves as Member of the Board of Directors and Chair of the Audit Committee of Commercial International Bank, Cairo
(since June 2025),
Member of the Supervisory Board and Chair of the Audit Committee
of Bayerische Landesbank,Munich (since May
2024), as Member of the Supervisory Board and Chair of the Audit Committee of Bank Pictet & Cie (Europe) AG, Frankfurt (since June
2023) and as Member of the Supervisory Board and Chair of the Risk and Audit Committee of Solaris SE, Berlin (since April 2023
until
March 2025).
In the past, Mr. Eckes has served as Chair of the Banks Working Party of Accountancy Europe (former FEE - Fédération des Experts
Comptables Européens) (2015 - 2022), Chair of the Banking Committee (Bankenfachausschuss – BFA) of the German Institute of Public
Auditors (Institut der Wirtschaftsprüfer - IDW) (2017 - 2022) and member of the BFA (2008 - 2022), Member of the European
Parlamentary Financial Services Forum - EPFSF (2012 - 2023) and Member of the Steering Committee Sustainability of IDW (2020 -
2022).
He holds an MBA from the University of Saarland, Saarbrücken (1986) and is a Certified Public Auditor (German Wirtschaftsfprüfer)
(1996).
Evan Kotsovinos-Independent, Non-Executive Director
-
Membership in Board Committees: a) Board Risk Committee – Member, b) Board Digital and Transformation Committee –
Member
-
Year of birth: 1979
-
Nationality: Greek / UK
-
Number of shares in Eurobank: None
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Mr. Kotsovinos also serves as Vice President of Engineering and General Manager, Google, New York (since November 2022).
In the past. Mr. Kotsovinos served at American Express, New York as Senior Vice President and Global Head of Infrastructure, (2019-
2022). He also held senior management positions at Morgan Stanley: Asia Chief Information Officer, Hong Kong (2018-2019), Head of
Asia Infrastructure, China CIO, Hong Kong and Shanghai (2014-2018), Head of Infrastructure Hungary, Executive Director, Budapest
(2013-2014), EMEA CTO of Infrastructure, Global CTO of Cloud, Executive Director (2012-2014).
He holds a Masters in Finance (2010-2012), London Business School, a PhD in Computer Science (2001-2004), University of Cambridge
and a BSc in Computer Science (1997-2001), University of Crete.
The Board is served by a competent and experienced company secretary, the short CV of whom is outlined below:
Ioannis Chadolias-Secretary to the BoD, Head of Group Company Secretariat
-
Secretary to the following Board Committees: a) Remuneration Committee, b) Nomination & Corporate Governance
Committee, c) Board Digital and Transformation Committee
-
Year of birth: 1970
-
Nationality: Hellenic
-
Number of shares in Eurobank: 30,000
Mr. Chadolias is responsible to lead the Group Company Secretariat unit and provide effective company secretarial support to the
Board and Board Committees of Eurobank and Eurobank Holdings as well as to their most important Executive Committees, ensuring
compliance with corporate law and regulations and maintaining effective corporate governance and internal policy framework.
With nearly three decades of experience in corporate governance, compliance, and financial services, he previously served as Deputy
Company Secretary of Eurobank and Eurobank Holdings (2016–2021) and led the Group Corporate Governance Division (2009–2016).
Earlier roles at Eurobank include Subsidiaries Control and Compliance Manager (2006–2009). Before joining the Bank, he held
managerial positions, among others, at Megatrust (a stockbroker company-member of Interamerican group) and Cosmote (the largest
telecommunications group in Greece), while he began his career as an auditor and business consultant at PwC.
He holds an MSc in Project Analysis, Finance, and Investment from the University of York and a Bachelor's in Economics from the
Athens University of Economics and Business and several professional qualifications.
5.4
Diversity Profile of the Board
As at 31 December 2025, the Bank Board consists of twelve (12) members, of whom three (3) are women, corresponding to 25%
representation of the less represented gender.
Apart from the gender dimension, the diversity characteristics of the Board, assessed in the context of the Diversity Policy (please
refer to the relevant section) and the annual collective suitability review, are summarized below.
Geographical origin and international experience
The Board demonstrates a strong international profile. Half of the Board members are non-Greek nationals and/or have substantial
professional experience outside Greece, contributing international perspectives and cross-border expertise to Board deliberations.
Age distribution
The age profile of the Board reflects a balance between long-standing senior experience and active executive engagement, supporting
continuity and effective challenge. Board members are distributed across the following age ranges:
●
40–50 years: 8.3%
●
51–60 years: 25.0%
●
61–70 years: 66.7%
Educational and professional background
The Board comprises members with diverse educational and professional backgrounds, including economics, business administration
and finance, engineering and other STEM disciplines, as well as legal studies. All Board members hold postgraduate or doctoral
qualifications, reinforcing the Board’s collective analytical capability and technical depth.
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Skills and expertise
Based on NomCo’s assessment, the Board collectively covers the key areas of knowledge, skills and experience required for the
effective governance of the Group, including banking and financial services, corporate and investment banking, risk management and
regulatory matters, audit and accounting, capital markets and treasury, digital transformation and technology, ESG and sustainability,
as well as international and cross-border operations.
Taking into consideration that the Bank and HoldCo BoDs had an identical composition, the above diversity profile also applies to the
HoldCo’s BoD as at 12 December 2025.
5.5
Re-election, Cessation and Independence of Board Members
There are no limitations on the re-election or cessation of Directors in the Articles of Association of Eurobank. In cases where a Board
member’s term has expired, the Board retains the authority to continue managing and representing the Bank without immediately
replacing the expired members, provided that the remaining members constitute more than half of the original number of members
before the lapse event and, in any case, are not fewer than three (3).
As stipulated in the Articles of Association of Eurobank, and in compliance with Law 4548/2018, the Board may consist of three (3) to
fifteen (15) members. Additionally, in accordance with Law 4706/2020 on corporate governance, independent non-executive
directors are appointed by the General Meeting and must constitute at least one-third (1/3) of the total number of Board members
(rounded to the nearest integer), with a minimum of two (2) independent non-executive directors.
The above principles were also applicable to Eurobank Holdings during the period of its operation, until 12 December 2025.
For the year 2025, the Nominations and Corporate Governance Committees of Eurobank and HoldCo, in their meetings held on May
27, 2025, and November 24, 2025, reviewed the independence criteria in accordance with Law 4706/2020, European Commission
Recommendation 2005/162/EC, and the Executive Committee Act of the Bank of Greece No. 224/21.12.2023 (BoG ECA 224/2023),
which incorporated the Joint ESMA and EBA Guidelines on the Assessment of the Suitability of Members of the Management Body
and Key Function Holders. The Committees concluded that the Independent Non-Executive Directors meet the applicable
independence criteria.
5.6
Division of responsibilities
At the top level of Eurobank, there is a clear separation of responsibilities between governance and executive management. The
Chairperson oversees the governance functions, while the Chief Executive Officer (CEO) and Deputy CEOs manage the operational
and managerial aspects of the organization. Importantly, the roles of Chairperson and CEO are held by different individuals, ensuring
a balanced and effective leadership structure.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.6.1
Chairperson
The Chairperson of the Eurobank Board is a Non-Executive Director and does not concurrently serve as Chairperson of the Risk or
Audit Committees. Elected by all Board members, including Independent Non-Executive Directors, in accordance with Law 4548/2018
and the Articles of Association, the Chairperson presides over Board meetings, ensuring their effective organization and operation.
The Chairperson’s responsibilities include:
●
Organizing and coordinating the work of the Board.
●
Setting the Board’s agenda and ensuring adequate time for discussions, particularly on strategic matters.
●
Promoting a culture of open-mindedness and constructive dialogue.
●
Facilitating and promoting good relationships among Board members and ensuring the effective contribution of all Non-
Executive Directors.
●
Ensuring that Directors receive accurate, timely, and clear information and that their developmental needs are met to
enhance Board effectiveness.
●
Maintaining continuous communication with representatives of the Ministry of Finance, the Bank of Greece (BoG), and other
public authorities.
●
Ensuring that the Board as a whole has a satisfactory understanding of shareholder views.
●
Ensuring effective communication with all shareholders, promoting fair and equitable treatment, and fostering constructive
dialogue to understand their perspectives.
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●
Working closely with the CEO and the Corporate Secretary to prepare Board meetings and ensure that Board members are
fully informed.
It is noted that the Board has not appointed a Senior Independent Director (SID).
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.6.2
CEO
The CEO of Eurobank is responsible for the development and execution of strategy in alignment with the Group's vision. As the leader
of the organization, the CEO is accountable for driving the achievement of the Group’s goals and objectives, ensuring effective
implementation of strategic initiatives and operational excellence.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.6.3
Executive Directors
The Executive Directors of Eurobank, including the CEO and Deputy CEOs, are responsible for the day-to-day management and
oversight of the Group, as well as for executing its strategy, as defined by the Board. Their responsibilities include:
●
Regularly consulting with Non-Executive Directors to assess the appropriateness of the implemented strategy.
●
Providing updates to the Board, in collaboration with senior managers, regarding market conditions and other developments
affecting HoldCo and Eurobank.
●
Promptly informing the Board, either jointly or individually in writing, by submitting a report with assessments and
proposals, in the event of crisis situations or anticipated risks that may impact the financial position of HoldCo and Eurobank.
The CEO and Deputy CEOs of Euobank fulfill their duties in accordance with the Internal Governance Control Manual (IGCM) of
Eurobank, which are endorsed by their respective Boards. These IGCMs provide a comprehensive framework for the governance,
direction, and supervision of Eurobank, ensuring compliance with legal and regulatory corporate governance standards.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.6.4
Non-Executive Directors
The Non-Executive Directors are responsible for promoting and safeguarding the interests of Eurobank as a whole. Their key
responsibilities include:
●
Monitoring and evaluating the strategy and its execution, as well as assessing the achievement of objectives.
●
Ensuring effective oversight of executive members, including monitoring and evaluating their performance.
●
Reviewing and providing feedback on proposals submitted by the Executive Directors, based on available information.
●
Approving, revising, and overseeing the implementation of the Group-level remuneration policy.
The Non-Executive Directors have the authority to request, in accordance with Eurobank’s internal procedures, direct engagement
with senior management. This is facilitated through regular presentations by department heads and service leaders.
The Non-Executive Directors convene at least once a year, or as deemed appropriate, without the presence of executive members,
to evaluate their performance. These meetings do not constitute a formal Board body or committee. In 2025, the Non-Executive
Directors of Eurobank held meetings on May 7, 2025.
Eurobank encourage Non-Executive Directors to remain well-informed on all matters handled by the respective Board.
The Independent Non-Executive Directors are required to submit their own reports, either individually or collectively, to the Annual
or Extraordinary General Meeting of Shareholders, in addition to the reports presented by the Board.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.7
Operation of the Board
The operation of the Board, including its meeting protocols, decision-making processes, and procedural guidelines, is defined in the
Internal Governance Control Manual (IGCM) of Eurobank. This manual, endorsed by the Board, is designed to adhere to legal and
regulatory corporate governance standards, while also incorporating the relevant provisions of Eurobank’s Articles of Association.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
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5.7.1
Board Meetings
The Board convenes regularly on a quarterly basis and on an ad hoc basis whenever required by law or the needs of Eurobank. Each
year, within the third quarter of the preceding year, the Board establishes an annual calendar of Board and Committee meeting s,
along with an annual action plan. This plan is adjusted as necessary to ensure the timely, comprehensive, and effective execution of
responsibilities and the thorough review of all matters requiring decisions. Any updates or modifications to the annual calendar are
promptly communicated to all Board and Committee members to facilitate their planning.
Board meetings are convened with a notice period of at least two (2) business days or five (5) business days if the meeting is held
outside the registered office of Eurobank, in accordance with Company Law 4548/2018. The invitation must clearly state the agenda
items. If the agenda is not explicitly stated, decisions may only be made if all Board members are present or represented and no
objections are raised regarding the meeting’s convocation and decision-making. Documents submitted to the Board are typically
circulated along with the agenda.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.7.2
Dissemination of Information
The Bank Board utilizes technological tools with necessary security specifications to facilitate real-time information sharing and
connectivity for Board members.
The CEO and senior management are responsible for ensuring that Board members have access to all necessary information required
for the performance of their duties at any time.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.7.3
Quorum in the Board Meetings
The Bank Board is considered to have quorum and may conduct valid meetings when at least half plus one of its members are present
or represented. The number of present or represented members may not fall below three (3), and any resulting fraction when
determining quorum is disregarded.
Board decisions are made by an absolute majority of the Directors present or represented. In the event of a tie vote, the Chairperson
does not have a casting vote.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.7.4
Board Decisions and Minutes
Ban Board decisions are made following discussions that fully address the agenda items, ensuring that all members present are
satisfied with the deliberations.
Bank Board meeting minutes are kept by the Company Secretary, approved at subsequent Board meetings, and signed by all members
present. Additionally, the drafting and signing of minutes by all Board members or their representatives is considered equivalent to
a formal Board decision, even in the absence of a preceding physical meeting.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.7.5
Company Secretary
The Board of Eurobank is supported by a capable, skilled, and experienced Company Secretary, who ensures adherence to internal
procedures and policies, as well as compliance with relevant laws and regulations, thereby enabling the effective and efficient
operation of the Boards.
The Company Secretary holds a senior management position and is appointed or dismissed by the Board, based on the
recommendation of the Chairperson.
Serving as the head of the Group Company Secretariat, a unit within Eurobank, the Company Secretary, in collaboration with the
Chairperson, is responsible for:
●
Ensuring prompt, transparent, and comprehensive communication with the Board and its Committees.
●
Managing the integration of new Board and Committee members.
●
Organizing General Meetings of Shareholders.
●
Facilitating communication between shareholders and the Board.
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●
Facilitating communication between the Board and senior management.
Additionally, the Company Secretary provides advice to the Board, through the Chairperson, on governance matters, ensuring
adherence to Board procedures.
All Board members have the right to access the advice and services of the Company Secretary, who is also responsible for facilitating
their orientation and supporting their professional development.
The above principles also applied to Eurobank Holdings during the period of its operation, until 12 December 2025.
5.8
Attendance of Board members in the Board and Board Committees
In accordance with the Bank Board and Board Committees Attendance Policy (that was also applicable to Eurobank Holdings during
the period of its operation, until 12 December 2025 - please refer to the relevant section in this report), and within the scope of the
Nomination and Corporate Governance Committee’s (NomCo) responsibility to regularly monitor Board members attendance and
assess whether escalation to the Board is necessary in cases of inadequate participation, the NomCo conducted reviews of Directors'
attendance on June 25, 2025 (for the Bank and HoldCo), and December 16, 2025 (for the Bank).
Furthermore, in 2025, the average attendance rate of Directors of Eurobank and HoldCo at Board and Board Committee meetings
was as follows:
Company
Meetings
Average ratio of
Directors’ attendance
2025
2024
2025
2024
Bank
18
25
98.2%
98.5%
HoldCo
15
20
96.8%
98.1%
During 2025, at individual level, the attendance of the Directors to the Board, stood above the 85% threshold. In addition, it is noted
that all Directors with missed Board attendances, provided representation proxies, leading to an attendance rate (physical and under
representation) of 100%.
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In particular, the Directors’ attendance rates at the Board meetings in 2025 were the following:
Name
Eurobank Holdings Board
Eurobank Board
Eligible to
attend
Attended in person
(# and %)
Eligible to
attend
Attended in person
(# and %)
Georgios Zanias,
Chairperson, Non-Executive Director
15
15
100%
18
18
100%
Fokion Karavias,
Chief Executive Officer
15
15
100%
18
18
100%
Stavros Ioannou,
Deputy Chief Executive Officer
15
15
100%
18
18
100%
Konstantinos Vassiliou,
Deputy Chief Executive Officer
15
14
93%
18
18
100%
Bradley Paul Martin,
Non-Executive Director
15
14
93%
17
17
94%
Rajeev Kakar,
Non-Executive Independent Director
15
15
100%
18
18
100%
Jawaid Mirza,
Non-Executive Independent Director
1
9
9
100%
8
8
100%
Alice Gregoriadi,
Non-Executive Independent Director
15
15
100%
18
18
100%
Irene Rouvitha Panou,
Non-Executive Independent
Director
15
14
93%
18
17
100%
Cinzia Basile,
Non-Executive Independent Director
15
15
100%
18
18
100%
Burkhard Eckes,
Non-Executive Independent Director
15
15
100%
18
18
100%
John Arthur Hollows,
Non-Executive Independent
Director
15
13
87%
18
17
94%
Evangelos Kotsovinos,
Non-Executive Independent
Director
15
14
93%
18
17
94%
1
On 18 June 2025, Mr. Jawaid Mirza, Non-Executive Independent Member of the Boards of Directors of Eurobank Holdings and Eurobank, submitted his
resignation, effective as of 27 June 2025, due to no longer fulfilling the independence criteria of Article 9 of Law 4706/2020, as he has cumulatively served
nine (9) years as a member of the Company’s and the Bank’s BoDs
The average Director’s attendance rates to Eurobank’s and HoldCo’s Board Committees, along with the individual attendance rates
per Board Committee are presented separately, under the subsection of the present Corporate Governance Statement, referring to
the Board Committees.
5.9
Directorships of Board members
The directorships held by Board members, including significant non-executive commitments to companies and non-profit
organizations, are notified prior to appointment to the Chairperson of the Nomination & Corporate Governance Committee (NomCo)
and/or NomCo, in accordance with the Bank External Engagements Policy (that, until the merger, was also applicable to Eurobank
Holdings). Additionally, Board members must notify the Bank Group Company Secretariat of any changes to their directorships as
soon as they occur.
The number of directorships a Board member may hold simultaneously is regulated by Article 83 of Law 4261/2014. Under this
provision, a Director may not hold more than one of the following combinations of directorships at the same time:
●
One (1) executive directorship with two (2) non-executive directorships, or
●
Four (4) non-executive directorships.
This restriction does not apply to directorships within the Group. Additionally, the Bank of Greece (BoG), as the competent authority,
may permit a Board member to hold one (1) additional non-executive directorship.
Furthermore, directorships in organizations that do not pursue predominantly commercial objectives are not counted for regulatory
purposes.
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As part of the Board’s overall effectiveness assessment, through which NomCo annually evaluates the knowledge, skills, experience,
and contribution of both individual Board members and the Board collectively, the directorships of Board members were reviewed
for 2025. This review confirmed that all Board members of Eurobank and Eurobank Holdings (until 12 December 2025) comply with
the provisions of the Law.
5.9.1
HoldCo and Eurobank Board Members’ Directorships (including Directorships within Eurobank Group) as at 31.12.2024
Georgios Zanias – Chairperson, Non-Executive Director
●
Foundation for Economic and Industrial Research (IOBE) – Board Member¹
●
Hellenic Bank Association – Chairman¹
●
European Banking Federation – Board Member¹
Fokion Karavias – Chief Executive Officer
●
Hellenic Bank Association (HBA) – Member¹
Stavros Ioannou – Deputy Chief Executive Officer
●
Grivalia Management Company S.A. – Non-Executive Director
●
Be-Business Exchanges S.A. of Business Exchanges Networks and Accounting and Tax Services – Chairman²
●
Eurobank Limited – Non-Executive Director
●
Eurobank Private Bank Luxembourg S.A. – Non-Executive Director²
●
Eurobank Bulgaria AD – Non-Executive Director, Supervisory Board²
Konstantinos Vasileiou – Deputy Chief Executive Officer
●
Marketing Greece S.A. – Non-Executive Director¹
●
Eurolife FFH General Insurance Single Member S.A. – Vice Chairman, Non-Executive Director³
●
Eurolife FFH Life Insurance Single Member S.A. – Vice Chairman, Non-Executive Director³
●
Eurolife FFH Insurance Group Holdings S.A. – Vice Chairman, Non-Executive Director³
●
Eurobank Factors Single Member S.A. – Chairman²
Bradley Paul Martin – Non-Executive Director
●
Blue Ant Media Corporation. – Non-Executive Director
●
AGT Food and Ingredients Inc. – Non-Executive Director
●
G.S. Dunn Limited– Non-Executive Director
●
Universal Matter Inc– Non-Executive Director
6
Rajeev Kakar – Non-Executive Independent Director
●
Gulf International Bank, Bahrain – Non-Executive Director⁴
●
Gulf International Bank, Kingdom of Saudi Arabia – Non-Executive Director⁴
Alice Gregoriadi – Non-Executive Independent Director
●
Hellenic Blockchain Hub – Non-Executive Director¹
●
CGI Greece – “Climate Governance Initiative Greece” – Non-Executive Director
Cinzia Basile – Non-Executive Independent Director
●
Zenith Global S.p.A. – Non-Executive Director
●
Amova Asset Management – Chairperson, Non-Executive Director⁵
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●
Amova Global Umbrella Fund – Non-Executive Director⁵
Irene Rouvitha Panou – Non-Executive Independent Director
●
Aik Group (CY) Limited – Non-Executive Director
●
Stelios Philanthropic Foundation – Trustee¹
Burkhard Eckes – Non-Executive Independent Director
●
Bank Pictet & Cie (Europe) AG – Non-Executive Member of the Supervisory Board
●
Bayerische Landesbank (BayernLB)– Non-Executive Member of the Supervisory Board
●
Commercial International Bank (CIB) – Non-Executive Director
John Hollows – Non-Executive Independent Director
●
None
Evangelos Kotsovinos – Non-Executive Independent Director
●
None
Explanatory Notes
¹ Organization that does not pursue predominantly commercial objectives.
² Company that belongs to Eurobank Group and, along with directorships in other Eurobank Group companies, is considered one (1)
directorship for regulatory purposes.
³ Company that belongs to Eurolife FFH Group and, along with directorships in other Eurolife FFH Group companies, is considered one
(1) directorship for regulatory purposes.
⁴ Company that belongs to Gulf International Bank Group and, along with directorships in other Gulf International Bank Group
companies, is considered one (1) directorship for regulatory purposes.
⁵ Company that belongs to Amova Asset Management Group and, along with directorships in other Amova Asset Management Group
companies, is considered one (1) directorship for regulatory purposes.
⁶ Via ECB decision notification dated 9.9.2025, it has been notified that European Central Bank has decided to grant the authorization
for Mr. Martin to hold a 5th non-executive directorship, as a member of the board of Universal Matter Inc..
5.10
Board Duties and Responsibilities
The principal duties and responsibilities of the Bank’s Board mainly described in paragraphs 14 to 21 of the Bank of Greece (BoG)
Executive Committee Act 243/2/07.07.2025, encompass a wide range of strategic, oversight, and governance functions:
●
review, guide, and approve the strategy and the key policies, major plans of action, risk policy and risk culture, business and
restructuring plans, and set performance objectives taking into account long-term financial interests and solvency,
●
monitor performance and oversee major capital expenditures, acquisitions, divestitures, and formation of new entities,
including special purpose vehicles and set targets for the liquidity management,
●
ensure the availability of necessary financial and human resources, as well as an internal control system,
●
approve the annual budget and monitor its implementation quarterly,
●
approve the three-year business plan and monitor its implementation,
●
review and approve at least annually the risk strategy and risk appetite, ensuring alignment with overall business strategy
and other plans,
●
receive and discuss comprehensive risk reports on a quarterly basis,
●
develop and deliver objectives in agreed restructuring plans under applicable laws,
●
provide oversight to senior management and approve corporate governance practices and values,
●
set standards shaping corporate culture and integrate desired culture into systems, policies, and behaviors,
●
approve risk and capital strategy and monitor CEO and Executive Board implementation,
●
approve organization chart and related policies as required by law or internal processes,
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●
approve material on & off balance sheet credit transactions including restructuring and write-offs with related parties as
defined as defined under legal and regulatory framework and as provided for in the Related Parties Credit Approval Policy,
●
ensure rigorous processes for monitoring organizational compliance with strategy, risk appetite, laws, and regulations,
●
select, compensate, monitor, and replace key executives as needed and oversee succession planning,
●
align executive and board remuneration with long-term interests of Group and shareholders,
●
facilitate formal and transparent board nomination and election processes, as well as the key function holders in line with
the applicable and regulatory framework
●
monitor and manage potential conflicts of interest among management, board, and shareholders,
●
ensure integrity of accounting and financial reporting systems,
●
review and monitor Non-Performing Loans (NPL) and Non-Performing Exposures (NPE) performance against set targets,
●
ensure an adequate level of risk data quality and governance within the Group, in line with the provisions and responsibilities
prescribed in the Group’s “BCBS 239 Overarching Framework”,
●
ensure the implementation of policies and processes for Risk Data Aggregation & Risk Reporting (RDARR) at Group level,
●
oversee disclosure and communication processes,
●
determine appropriate level of remuneration for Board and Committees’ members pending ratification,
●
address matters related to new technologies and environmental issues,
●
identify and engage with important stakeholders, understanding their interests and interactions with Group strategy,
●
facilitate open dialogue with stakeholders and utilize various communication channels for effective engagement and
understanding,
●
ensures the implementation of an adequate and effective internal governance and internal control framework, which
includes the implementation of a clear organisational structure and well-functioning independent internal risk management,
compliance and audit functions that have sufficient authority, stature and resources to perform their functions,
●
ensures compliance with applicable regulatory requirements in the context of the prevention of money laundering and
terrorism financing,
●
the amounts, types and distribution of both internal capital and regulatory capital to adequately cover the risks of Eurobank,
●
approve and oversee the implementation of the remuneration policy in line with the applicable legal and regulatory
framework.
These duties collectively contribute to the effective governance, strategic direction, risk management, and sustainable growth of the
Bank and its operations.
Throughout its period of operation until 12 December 2025, Eurobank Holdings had the same duties and responsibilities as those
described above.
5.11
Main issues the Board dealt with during 2025
In 2025, the Board of Eurobank, and during the period from 1 January until 12 December 2025, the Board of Eurobank Holdings,
conducted a comprehensive review of the corporate strategy, the principal business risks to the business, and the system of internal
controls.
In more detail, the main issues addressed by the Boards of Directors of Eurobank Holdings and Eurobank included the following:
5.11.1
Bank Board activities in 2025
a) Governance
●
Approved the constitution of the BoD – Appointment of the Chief Executive Officer and the Deputy Chief Executive Officers
– Determination of executive and non-executive members.
●
Approved the new composition of Board Committees and their revised Terms of Reference.
●
Was updated on the on-going Board nomination process for the appointment of a new female candidate to the Board of
Directors.
●
Reviewed an annual progress report on BoD gender representation.
●
Received a wrap-up for the Nomination and Corporate Governance Committee workings during 2025 concerning the C-level
Succession Planning and Diversity.
●
Approved the assessment of the Corporate Governance System (L.4706/2020 requirement)
●
Convened the Shareholders’ General Meetings.
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●
Discussed the 2024 annual evaluation of the Board and Board Committees and reviewed/acknowledged the Action Plan.
●
Reviewed the attendance of Directors at Board and Board Committee meetings.
●
Non-Executive Directors approved the CEO’s performance evaluation for 2024 and his financial and non-financial objectives
for 2025.
●
Approved key governance policies, including:
o
CEO Succession Planning Policy
o
Board of Directors Diversity Policy
o
Board Nomination Policy (also submitted to the Annual General Meeting (AGM) for approval)
o
Board and Board Committees Evaluation Policy
o
Group Governance Policy
o
Related Party Transactions Policy
o
Key Function Holders Selection and Appointment Policy
o
Compliance Policy
o
Anti-Bribery and Corruption Policy
o
External Engagements Policy
o
Insider Dealing Guideline
o
Conflict of Interest Policy
o
C-Level Succession Planning Policy
o
Senior Management Selection and Appointment Policy
o
AML/CFT and Sanctions Policy
o
Board and Board Committees attendance policy
o
Shareholders' Remuneration Policy (prior Dividend Distribution policy)
o
Policy for Reporting Illegal or Unethical Conduct or Violations of European Union Law
o
Group Subsidiaries’ Dividend Distribution Policy
●
Non-Executive Directors approved the Board of Directors Remuneration Policy (post merger), the Group Greece Annual Base
Salary Framework, the evaluation of Group KPIs and KRIs for FY2024 and the Performance (related remuneration pool of
the Group and its allocation among Countries) as well as the setting of Group KPIs & KRIs for FY2025 variable remuneration.
●
Approved the Board and Board Committees' fees for Non-Executive Directors, which were subsequently submitted to the
AGM for approval.
●
Approved the distribution of net profits to senior management and employees and granted approvals according to Article
86 of Law 4261/2014, which were subsequently submitted to the AGM for approval.
●
Non-Executive Directors approved the Implementation of the Group Separation Policy at Group level.
●
Non-Executive Directors approved the Group Subsidiary Board Remuneration Policy and reviewed the implementation of
this Policy during 2024.
●
Approved the Bank’s Internal Governance Control Manual.
●
Received regular updates on Board Committee matters.
●
Approved the Board and Board Committees’ calendar for 2026.
●
Addressed remuneration matters, including variable remuneration and remuneration increases for senior executives of
international subsidiaries.
●
Approved and submitted to the AGM for approval the appointment of auditors for the financial year 2025.
●
In the context of the External Auditor’s tendering, approved the recommended audit firm for the new Group External
Auditors for 2027-2031.
●
Received updates from the Board Chairpersons of the international banking subsidiaries.
●
Approved credit facilities to related parties and other related parties’ transactions.
●
Received the Group Company Secretary’s Report 2024.
b) Strategic Issues, Corporate and Other Actions
●
Received CEO’s quarterly report and discussed various strategy matters.
●
Approved the updated Group Investment and Group Divestment Policies.
●
Approved the issuance by Eurobank of Additional Tier 1 instruments in the form of common, unsecured, perpetual,
subordinated notes
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●
Approved Eurobank’s dividend distribution to Eurobank Holdings (the sole shareholder of the Bank at that time) and the
amendment of the Dividend Policy.
●
Discussed the Geopolitical and Business Planning Implications of the New US Tariff Policy.
●
Approved the Corporate Investment Banking (CIB) International Expansion strategy
●
In the context of the merger for the absorption of Eurobank Holdings by Eurobank (Project Square):
a) approved the Transformation Balance Sheet, Draft Merger Agreement and Explanatory Report to Shareholders.
b) approved the listing of Eurobank shares on Athens and Cyprus Stock Exchange (subsequent parallel listing).
c) approved and further proposed to the General Meeting for approval the merger of the Bank with Eurobank Holdings by
absorption of latter by the former in accordance with the applicable legislation.
d) approved and further proposed to the General Meeting for approval the increase and reduction of the share capital of
the Bank, as a result of the Merger, with amendment of article 5 of the Articles of Association of the Bank.
e) for the Share Buyback Program: approved and further proposed to the General Meeting for approval the continuation of
the program of Eurobank Holdings and approved the specific terms for the continuation of the program’s implementation.
f) approved and further proposed to the General Meeting for approval the continuation of the Stock Options Plan of
Eurobank Holdings.
g) approved the ovedraft facility from Eurobank to Eurobank Holdings.
h) approved the Interim Consolidated Financial Statements of Eurobank for the nine-month period ended 30 September
2025
i) approved the certification of the payment of share capital increase as a result of the merger of Eurobank with Eurobank
Holdings.
●
Approved the Hellenic Bank integration plan.
●
Approved the establishment of category 4 branch in Abu Dhabi.
●
Approved a Pre-Settlement Agreement between the Hellenic Bank Public Company Ltd and the Cypriot Asset Management
Company KEDIPES.
●
Approved Arbitration Agreements and authorizations.
●
Approved the Project Sun, the outright sale of Eurobank’s corporate exposures previously included in Project Solar.
●
Approved Project Shell, entering into a term sheet with Fairfax to fully acquire Eurolife FFH Life Insurance
●
Reviewed presentations concerning the Retail Banking business (for 2024) and Revolut.
●
Discussed the Postbank Bulgaria Retail Portfolio.
●
Discussed the 2024 payout ratio & capital headroom for large ECB-supervised banks.
●
Approved the Cards Monoissuer Request for Proposal (RFP) Process
●
Approved the financing of the "Marietta Giannakou" school renovation program.
c) Capital Adequacy
●
Approved the 2025 Internal Capital & Liquidity Adequacy Statements (CAS & LAS) as part of the Internal Capital & Liquidity
Adequacy Assessment Process (ICAAP & ILAAP 2025).
●
Approved the exercise of the call option for Wave I securitization.
●
Approved the Wave III Upsize (Synthetic Securitization of Shipping Loans)
●
Approved the updated Minimum Requirement for Own Funds and Eligible Liabilities (MREL) Plan 2025-2027 and the MREL
Plan 2026-2028.
d) Business Monitoring
●
Approved the 2024 annual consolidated financial statements and the 2025 interim consolidated financial statements.
●
Approved the Annual Budget 2025 and the Three-Year Business Plan (2025-2026), including an adverse scenario.
●
Discussed the Annual Budget 2026 and the Three-Year Business Plan (2026-2028), including assumptions for the adverse
scenario.
●
Discussed 2025 performance versus budget.
●
Received updates from the CEOs of the international banking subsidiaries.
●
Approved the update of Group accounting policies.
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e) Risk Management and Internal Control
●
Approved the appointment of the new Group Chief Risk Officer.
●
Acknowledged the annual regulatory report of Group Internal Audit on the System of Internal Controls (SIC).
●
Received updates on significant internal audit issues, Group Internal Audit Priorities and Plans for 2025 and beyond.
●
Discussed the Annual Group Compliance report on Anti-Money Laundering (AML) and the Annual Group Compliance Report
(including MiFID report).
●
Reviewed compliance updates, including the Anti-Money Laundering (AML) Business Risk Assessment and the Compliance
Risk Assessment for Greece and International Subsidiaries.
●
Approved the appointment of the new Money Laundering Reporting Officer (MLRO)
●
Approved the renewal of terms for the Report Receiving & Monitoring Officer (RRMO) and the assistant RRMO.
●
Reviewed the Anti-Bribery and Corruption Annual Report and the Ethics Hotline Reports received during 2024.
●
Received updates on significant legal and regulatory matters.
●
Discussed the Risk Appetite Dashboard for the Level 1 Key Risk Indicators (KRIs) and approved the Risk Appetite Statements.
●
Approved the Risk Identification and Materiality Assessment (RIMA) Reports.
●
Approved the Data Governance Deployment Plan for Eurobank Limited, in the context of the ongoing actions for compliance
with the Basel Committee on Banking Supervision principles for effective risk data aggregation and risk reporting (BCBS 239).
●
Approved the consolidated Pillar 3 Report (capital and risk management disclosures) for 2024.
●
Received updates on credit and NPE-related issues.
●
Received updates on Securitizations Performance.
●
Received Dashboards for Liquidity, IRRBB/CSRBB and Market Developments.
●
Received the Annual Outsourcing Risk Review.
●
Approved the updated thresholds for the Recovery Plan Indicators.
●
Reviewed significant risk issues, including the Group Chief Risk Officer’s Annual Report for 2024.
●
Reviewed the 2024 Annual Activity Report of the Audit Committee before submission to the AGM.
●
Approved new and revised risk policies, including:
o
Risk Culture policy
o
Group Liquidity Risk Policy
o
Market & Counterparty Risk Policy
o
Interest Rate Risk in the Banking Book (IRRBB) & Credit Spread Risk in the Banking Book (CSRBB) Policy
o
Grouping and Degrouping policy
●
Approved the IT & Security Risk Management Framework (including Information Security Policy)
●
Reviewed presentations of various large groups included to Eurobank’s 25 Largest Performing Exposures.
●
Received update regarding the Low Start portfolio Deep Dive from SSM
●
Received updates by the responsible BoD member for climate -related and environmental risks
●
Discussed the Operational Act regarding Macro Hedging Unwinding
●
Discussed the findings from the On-Site Investigation (OSI) in the areas of IRRBB/CSRBB and Funding Risk.
f) Transformation Project
●
Received regular updates on the transformation project.
5.11.2
Eurobank Holdings’ Board activities during the period from 1 January until 12 December 2025
a) Governance
●
Approved the constitution of the BoD – Appointment of the Chief Executive Officer and the Deputy Chief Executive Officers
– Determination of executive and non-executive members
●
Approved the new composition of Board Committees and their revised Terms of Reference.
●
Reviewed an annual progress report on BoD gender representation.
●
Approved the assessment of the Corporate Governance System (L.4706/2020 requirement)
●
Convened the Shareholders’ General Meetings.
●
Discussed the 2024 annual evaluation of the Board and Board Committees and reviewed/acknowledged the Action Plan.
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●
Reviewed the attendance of Directors at Board and Board Committee meetings.
●
Non-Executive Directors approved the CEO’s performance evaluation for 2024 and his financial and non-financial objectives
for 2025.
●
Approved key governance policies, including:
o
CEO Succession Planning Policy
o
Board of Directors Diversity Policy
o
Group Governance Policy
o
Related Party Transactions Policy
o
Key Function Holders Selection and Appointment Policy
o
Compliance Policy
o
Anti-Bribery and Corruption Policy
o
Insider Dealing Guideline
o
Conflict of Interest Policy
o
Shareholders’ Remuneration Policy
o
Policy for Reporting Illegal or Unethical Conduct or Violations of European Union Law
●
Addressed remuneration matters, including:
o
Non-Executive Directors approved the Group Greece Annual Base Salary Framework, the evaluation of Group KPIs
& KRIs for FY2024 and the Performance (related remuneration pool of the Group and its allocation among
Countries) as well as the setting of Group KPIs and KRIs for FY2025 variable remuneration.
o
Non-Executive Directors approved the Remuneration adjustment for the CEO.
o
Proposed to the AGM for approval of the Board and Board Committees' fees for Non-Executive Directors, the Board
of Directors’ Remuneration Policy, the Remuneration Report for 2024.
o
Approved the Stock Options exercise of the 8th Stock Option Plan.
●
Non-Executive Directors approved the Implementation of the Group Separation Policy at Group level.
●
Received regular updates on Board Committee matters.
●
Approved and submitted to the AGM for approval the appointment of auditors for the financial year 2025.
●
In the context of the External Auditor’s tendering, approved the recommended audit firm for the new Group External
Auditors for 2027-2031.
●
Discussed the 2024 Supervisory Review and Evaluation Process (SREP)aggregated results, the Supervisory Review and
Evaluation Process (SREP) preliminary assessment 2025 and received update on SREP 2025 final decision.
●
Approved related parties’ transactions.
●
Received the Group Company Secretary’s Report 2024.
b) Strategic Issues, Corporate and Other Actions
●
Received the CEO’s quarterly reports and discussed various strategy matters.
●
Approved the exchange offer of subordinated instruments issued by Eurobank Holdings with dated subordinated notes
issued by Hellenic Bank Plc.
●
Approved a share capital increase following the exercise of stock option rights and amended Article 5 of the Articles of
Association in accordance with Article 113(3) of Law 4548/2018.
●
Discussed the Geopolitical and Business Planning Implications of the New US Tariff Policy.
●
Approved (subject to AGM approval) the Shareholders’ Remuneration in cash and share buyback.
●
Approved specific terms for the Share Buy-back.
●
In the context of the merger for the absorption of Eurobank Holdings by Eurobank (Project Square):
o
Approved the Transformation Balance Sheet, the draft Merger Agreement and the Explanatory Report to Shareholders.
o
Approved the merger of Eurobank with Eurobank Holdings by absorption of latter by the former in accordance with the
provisions of Articles 6–21, 30–34 and 140 of Law 4601/2019, Article 16 of Law 2515/1997, and the applicable provisions
of Law 4548/2018
●
Approved the interim dividend distribution.
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●
Approved the issuance of Additional Tier 1 Instruments in the form of common, unsecured perpetual, subordinated notes
by Eurobank Holdings.
●
Discussed the 2024 payout ratio & capital headroom for large ECB-supervised banks.
c) Capital Adequacy
●
Approved the 2025 Internal Capital & Liquidity Adequacy Statements (CAS & LAS) as part of the Internal Capital & Liquidity
Adequacy Assessment Process (ICAAP & ILAAP 2025).
●
Approved the updated Minimum Requirement for Own Funds and Eligible Liabilities (MREL) Plan 2025-2027.
d) Business Monitoring
●
Approved the 2024 annual financial statements and the 2025 interim financial statements.
●
Approved the final Annual Budget 2025 and the Three-Year Business Plan (2025-2027), including an adverse scenario.
●
Approved the updated thresholds for the Recovery Plan Indicators and the Group Recovery Plan.
●
Reviewed 2025 performance versus budget.
●
Reviewed the Segmental performance analysis.
●
Approved the Business and Capital Plan Policy and discussed the top-down Business and Capital Plan 2025-2027.
●
Approved the update of Group accounting policies.
e) Risk Management and Internal Control
●
Approved the appointment of the Group Chief Risk Officer.
●
Acknowledged the annual regulatory reports of Group Compliance and Group Internal Audit on the System of Internal
Controls (SIC).
●
Discussed the Annual Group Compliance Report (including MiFID report).
●
Approved the renewal of terms for the Report Receiving & Monitoring Officer (RRMO) and the assistant RRMO.
●
Reviewed the Anti-Bribery and Corruption Annual Report and the Ethics Hotline Reports received during 2024.
●
Received updates on significant internal audit and compliance issues.
●
Discussed the Risk Appetite Dashboard for the Level 1 Key Risk Indicators (KRIs) and approved the Risk Appetite Statements.
●
Approved the Risk Identification and Materiality Assessment (RIMA) Reports.
●
Approved the consolidated Pillar 3 Reports (capital and risk management disclosures) for2024, Q1 2025, Q2 2025, and Q3
2025.
●
Received Dashboards for Liquidity, IRRBB/CSRBB and Market Developments.
●
Received the Annual Outsourcing Risk Review.
●
Received updates on significant risk issues, including the Group Chief Risk Officer’s Annual Report for 2024.
●
Reviewed the 2024 Annual Activity Report of the Audit Committee before submission to the AGM.
●
Approved new and revised risk policies and plans, including:
o
Risk Culture policy
o
Group Liquidity Risk Policy
o
Market & Counterparty Risk Policy
o
Interest Rate Risk in the Banking Book (IRRBB) & Credit Spread Risk in the Banking Book (CSRBB) Policy
o
Grouping and Degrouping policy revision
o
Consolidated Pillar 3 disclosures policy
●
Approved the IT & Security Risk Management Framework (including Information Security Policy)
●
Received updates by the responsible BoD member for climate -related and environmental risks
●
Discussed the Operational Act regarding Macro Hedging Unwinding
●
Discussed the findings from the On-Site Investigation (OSI) in the areas of IRRBB/CSRBB and Funding Risk.
f) Transformation Project
●
Received regular updates on the transformation project.
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5.11.3
Board Strategy Day
In addition to the formal meetings focused on Eurobank’s annual budget and three-year business plan, the Board holds an annual
strategy meeting, known as the Board Strategy Day. This meeting is separate from the regular Board of Directors’ meetings and is
conducted in an informal setting, without the recording of formal minutes.
The purpose of the Board Strategy Day is to allow Board members the time and flexibility to engage in in-depth discussions and
deliberations on the top strategic initiatives that are critical to Eurobank’s growth and competitive positioning among its peers.
During the most recent Board Strategy Day, held on September 25 and 26, 2025
various strategic issues were discussed. Following
the meeting, a memorandum was issued summarizing the key discussions.
5.12
Board and Board Committees overall effectiveness assessment
5.12.1
Board and Board Committees Evaluation
In accordance with the Bank Board and Board Committees Evaluation Policy (Section B4) – that was also applicable to Eurobank
Holdings until 12 December 2025 - the Nomination and Corporate Governance Committee (NomCo) is responsible for evaluating the
structure, size, composition, and performance of the Board and its Committees and making recommendations for necessary changes.
The NomCo oversees the annual self-evaluation of the Board’s and Committees' effectiveness (Internal Evaluation), typically using a
self-assessment questionnaire as the primary tool.
For the 2025 Internal Evaluation, all twelve (12) Board members participated by completing anonymous self-assessment
questionnaires, which were administered via Diligent’s secure web-based platform. These questionnaires covered various areas,
including:
●
Strategy oversight
●
Engagement with management
●
Risk management
●
Board composition and dynamics
●
Chairperson’s role
●
Secretarial support
●
Effectiveness of Board Committees
Key Findings of the Internal Evaluation
The results indicated that in 2025, the Board of Eurobank, and until 12 December 2025, the Board of HoldCo, continued to function
effectively, maintaining a high level of performance consistent with the 2024 evaluation.
Strategy Oversight
●
Board members expressed a positive impression of the Board’s role in strategy, particularly regarding the improved
integration of strategic, financial and ESG-related information, which has enhanced the Board’s ability to effectively monitor
execution.
Relationship with Management
●
The Board maintained a strong relationship with management, characterized by high levels of trust, open communication,
and effective follow-up, which supported and reinforced the Board’s oversight role.
Strategic HR and Remuneration
●
The Board demonstrated strong oversight of banking culture, leadership capability and alignment of remuneration with
strategy and risk appetite, with oversight of banking and risk culture remaining a clear strength.
Risk Governance and Internal Control
●
The Board maintained high standards in risk governance and internal control.
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●
Oversight of internal controls, Internal Audit and Compliance is particularly strong, reinforcing confidence in the Group’s
control environment and ethical framework.
Board Profile and Composition
●
The Board was recognized for its adequate knowledge, skills, experience, and diversity.
●
Financial and international experience continue to represent clear strengths, reinforcing the Board’s ability to oversee a
complex, multi-jurisdictional banking group.
Board Functioning and Dynamics
●
The Board demonstrated robust annual agenda planning, with well -established and consistent procedures.
●
Board discussions included constructive reviews and challenges, fostering effective decision-making.
Board Chairperson's Role
●
The Chairperson’s leadership was recognized as a key factor in the Board’s overall effectiveness and success.
Board Secretarial Support
●
Board members highlighted the effectiveness of operational support and recognized for professionalism, reliability and
quality, particularly in the materials submitted by management and the preparation of meeting minutes.
Opportunities for further enhancement
While the evaluation was overwhelmingly positive, some areas for enhancement were identified:
●
Further sharpening the Board’s medium- to long-term strategic focus, particularly in light of the Group’s expanding
international footprint, with more structured and recurring discussions on growth platforms and geographic priorities.
●
Strengthening the Board’s focus on innovation, digital leadership and competitive positioning.
●
Improving the monitoring of subsidiary performance, ensuring more strategic and in depth discussions.
The main conclusions of the Internal Evaluation regarding Board Committees have been integrated into the relevant sections detailing
their functioning and operations.
5.12.2
Assessment of the knowledge, skills and experience (KSE) of the Board collectively as well as the KSE and contribution of
individual Board members.
In accordance with the Bank Board and Board Committees Evaluation Policy (see the relevant section in this Statement) - that was
also applicable to Eurobank Holdings until 12 December 2025 - the NomCo is responsible for assessing the knowledge, skills, and
experience (KSE) of the Board collectively, as well as the KSE and contribution of individual Board members, and reporting to the
Board accordingly.
5.12.3
Individual Evaluations
The individual evaluations (assessment of the Board Chairperson, Non-Executive Directors (NEDs), and Executive Directors) consider
the status of the member (executive, non-executive, independent), participation in committees, specific responsibilities/projects
undertaken, time commitment, behavior, and the application of knowledge and experience.
A. Assessment of the Board Chairperson
The Board Chairperson’s evaluation is part of the Internal Evaluation and is conducted by all other Board members through the Board
and Board Committees’ Self-Evaluation Questionnaire.
The evaluation of the Board Chairperson in 2025 for the Bank and until 12 December 2025 for the HoldCo remained very strong,
consistent with the 2024 evaluation.
B. Assessment of the Non-Executive Directors’ (NEDs) Contribution to the Board (Excluding the Chairperson)
The Board Chairperson is responsible for conducting the assessment of NEDs' contributions and presenting the results to the NomCo.
The assessment process follows these steps:
●
NomCo approves the NEDs’ self-evaluation questionnaire.
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●
The questionnaire is distributed to the NEDs, and responses remain strictly confidential, accessible only to the Board
Chairperson or designated individuals.
●
The Board Chairperson conducts confidential one-on-one interviews with each NED, using the self-evaluation questionnaire
as a reference.
●
The Board Chairperson presents an overall report on the findings to the NomCo.
●
The Board Chairperson’s views on NEDs’ performance, knowledge, skills, and experience are discussed in the NomCo,
particularly during the (re)appointment and succession planning of Board members.
For the 2025 annual assessment, the Board Chairperson led the evaluation of the NEDs' contribution using a self-evaluation
questionnaire consisting of 10 questions focused on five key areas:
●
Contribution to overall Board profile and skillset
●
Board participation and quality of contributions to deliberations
●
Punctuality and attendance
●
Team spirit and demeanor
●
Independent thinking and constructive challenge
The 2025 annual assessment for the Bank and until 12 December 2025 for the HoldCo, demonstrated that the NEDs adequately meet
expectations, effectively fulfilling their roles as Directors of HoldCo/Bank.
C. Executive Directors’ Performance Evaluation
The evaluation of Executive Directors in 2025 for the Bank until 12 December 2025 for the HoldCo, including the CEO and Deputy
CEOs, follows a structured process involving the CEO, the NomCo, and the Board Remuneration Committee (RemCo). This annual
evaluation is based on qualitative and quantitative Key Performance Indicators (KPIs) approved by the Non-Executive Directors.
For the CEO’s evaluation, the RemCo proposes KPIs related to CEO remuneration, which are then submitted to the Non-Executive
Directors for approval. The CEO's performance is assessed based on these approved KPIs, and the results are communicated to the
CEO and considered in determining remuneration.
5.12.4
Collective Suitability Assessment
In 2025, alongside the Board of Directors’ performance evaluation, an assessment of the Board’s collective suitability was conducted
in accordance with the Joint ESMA/EBA Guidelines on the assessment of the suitability of members of the management body and key
function holders (EBA/GL/2021/06). This assessment was supported by the NomCo.
The evaluation examined whether the Bank Board in 2025 and the HoldCo Board until 12 December 2025, collectively possessed the
necessary knowledge, skills, and experience to understand the business model, strategy, risks, and governance-related matters. The
assessment confirmed that the Board was collectively suitable to effectively address these areas.
The evaluation also identified potential areas for improvement in specific Bank business lines and products, various geographies and
subsidiaries, and risk management, particularly regarding cybersecurity and outsourcing risks. It was suggested that initiatives could
be considered to address these observations and ensure alignment with Bank strategic goals.
To enhance understanding in these areas, presentations at the Board and Board Committees level, along with targeted external
training and internal sessions, will continue to play a central role in strengthening the Bank Board’s expertise.
5.13
Directors’ Induction and Continuous Professional Development
In accordance with the Directors’ Induction and Continuous Professional Development Process of the Bank - that was also applicable
to Eurobank Holdings during the period of its operation, until 12 December 2025 - all directors who join the Board, undergo a
comprehensive Induction Program designed to achieve several key objectives, as outlined in Section B8.
Mr. Evangelos Kotsovinos, who was the last director who joined the Bank/HoldCo Board in 2024, upon his appointment:
●
Received a Manual of Obligations detailing his main responsibilities towards the Supervisory Authorities and HoldCo/Bank,
including local regulations and Board procedures.
●
Attended meetings and presentations by Key Executives of HoldCo/Bank, providing a comprehensive overview of the
organization.
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As part of the continuous professional development framework, in 2025, Board members participated in formal training sessions on:
●
Artificial Intelligence and Algorithmic Risk Governance
●
Cybersecurity Awareness Session (incl. Digital Operational Resilience Act (DORA))
●
Risk Data Aggregation and Risk Reporting (RDARR) for decision making
Additionally, Board members engaged in in-house meetings and discussions on Strategy, Business Planning, and Budgeting. They
received regular updates, reports, and presentations from senior management on operational and strategic targets, market
developments, and updates on risk, audit, compliance, financial, human resources, legal, and regulatory matters.
Board members also received regular and ad-hoc research and economic bulletins from Eurobank's Economic Analysis and Financial
Markets Research.
6.
Board Committees
The Board of Eurobank is assisted in carrying out its duties by Board Committees, to which it delegates specific responsibilities.
The Bank Board Committees include:
●
Audit Committee (AC)
●
Board Risk Committee (BRC)
●
Remuneration Committee (RemCo)
●
Nomination and Corporate Governance Committee (NomCo)
●
Bank Board Digital & Transformation Committee (BDTC)
It is noted that, throughout its period of operation until 12 December 2025, the HoldCo Board was assisted in the discharge of its
duties by Board Committees, to which it delegated specific responsibilities. The HoldCo Board Committees comprised the AC, BRC,
RemCo and NomCo and had responsibilities similar to those of the respective Board Committees of the Bank.
6.1
Governance and Operations of Board Committees
The governance and operational arrangements applicable to the Bank Board Committees are set out below. It is noted that,
throughout their period of operation until 12 December 2025, the HoldCo Board Committees operated in accordance with the same
governance and operational arrangements as those applicable to the Bank Board Committees.
6.1.1
Board Committees’ members
The members of Bank Board Committees are appointed by the Board, following a recommendation from the NomCo and in
accordance with the applicable legal and regulatory framework.
The tenure of Committee members coincides with the tenure of the Board, with the option for renewal. However, total service on
the Committees must not exceed nine (9) years.
6.1.2
Board Committees’ Terms of Reference (ToR)
The ToR of each Board Committee outlines its purpose, responsibilities, and modus operandi. It is reviewed annually and revised if
necessary unless significant changes require an earlier revision. The ToR is approved by the Board and made publicly available on the
Bank website.
6.1.3
Board Committees’ meetings
The minimum number of annual meetings for each Board Committee is defined in its ToR.
Only Committee members have the right to attend meetings, though other individuals, such as Management members, external
auditors, and external advisors, may be invited when appropriate and necessary. The number of invitees is kept to a minimum to
preserve the efficiency and effectiveness of the meeting.
Members may attend meetings remotely via video or audio conference. A mandatory minimum attendance requirement applies, as
set out in the Board and Board Committees’ Attendance Policy (please refer to the relevant section in this Statement).
6.1.4 Quorum in the Board Committees’ Meetings
A quorum is established when more than half of the Committee members are present or represented, provided that at least three
(3) members are present, including the Chairperson or, in the case of BRC, the Vice Chairperson.
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Each Committee member may validly represent only one other Committee member. Representation cannot be assigned to individuals
outside the Committee.
6.1.5 Board Committees’ Decisions
Resolutions are validly adopted by an absolute majority of the members present or represented.
In the event of a tie, the Chairperson or in his/her absence, the Vice Chairperson for BRC or the most senior Independent Non-
Executive Director present (based on tenure), has the casting vote.
The Board is informed whenever a decision is not reached unanimously.
Minutes may be drawn up and signed by circulation by all Committee members, which is equivalent to a valid decision, even if no
formal meeting takes place.
6.1.6 Board Committees’ Secretary and Minutes
Each Bank Board Committee appoints its Secretary, who reports to the Group Company Secretariat and collaborates with the
Committee Chairperson and other relevant parties.
The Secretary is responsible for:
●
Recording the proceedings and decisions of the Committee meetings.
●
Listing the names of attendees and documenting action plans and follow-ups.
●
Issuing extracts of minutes as required.
●
Disseminating decisions, actions, and follow-ups to the relevant parties.
6.1.7
Board Committees’ Performance Evaluation
The performance of Board Committees is evaluated annually, in line with the Board and Board Committees Evaluation Policy (please
refer to the relevant section in this Statement).
6.2 Audit Committee
The primary function of the Bank Audit Committee (AC) is to assist the respective Board in discharging its oversight responsibilities
primarily relating to:
●
the review of the adequacy of the Internal Control and Risk Management systems and the compliance with rules and
regulations monitoring process including on issues of sustainability,
●
the review of the financial reporting process and satisfaction as to the integrity of the Bank’s Statutory Financial Statements,
Information, including Sustainability Reporting,
●
the External Auditors’ / Independent Assurance Providers’ for the audit and assurance of sustainability reporting (IASP)
selection, performance and independence,
●
the effectiveness and performance of the Group Internal Audit (Group IA) and of the Compliance function.
In addition, in the context of AC’s responsibility to safeguard External Auditors’ independence, the AC ensures that the nature of non-
audit services, prior to their being undertaken by the External Auditors, has been reviewed and approved as required and that there
is proper balance between audit and non-audit work in accordance with the policy on External Auditors’ Independence.
Throughout its operation, until 12 December 2025, HoldCo AC carried out responsibilities similar to those described above.
6.2.1
AC Membership/Composition
The Bank’s AC is consisted exclusively by Board members and its composition has been approved by the General Meeting of the
Shareholders (as per the legal framework), following the recommendation of the NomCo to the Board. The Chairperson of the
Committee is appointed by the members of the Committee.
All AC members have sufficient knowledge in the field of Bank’s activities and the necessary skills and experience to carry out their
duties and meet the requirement of established knowledge and experience in auditing and/or accounting.
4
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The AC consists of four (4) independent non-executive Directors of the Board. In particular, the Bank’s AC composition is outlined
below:
AC Chairperson:
Burkhard Eckes,
Non-Executive Independent Director of the Board
AC Members:
Irene Rouvitha Panou,
Non-executive Independent Director of the Board
Rajeev Kakar
,
Non-Executive Independent Director of the Board
Alice Gregoriadi,
Non-Executive Independent Director of the Board
Following Mr. Jawaid Mirza’s resignation dated 18.06.2025 from the position of member of the Bank BoD and member of the Bank
BoD Committees he served, effective as of 27.06.2025 and the Bank Nomination & Corporate Governance Committee’s relevant
recommendation, the Bank BoD of 27.06.2025 decided the Bank AC to continue its operation with the remaining independent non-
executive directors.
Throughout the period of its operation, until 12 December 2025, the composition of the HoldCo AC was identical to that of the Bank
AC.
6.2.2
AC Meetings
The AC meets at least eight (8) times per year or more frequently, as circumstances require, reports on its activities to the Board on
a quarterly basis and submits the minutes of its meetings and the annual Activity Reports (before its submission to the Shareholders’
Annual General Meeting) to the Board.
Apart from the AC members, the BRC’s members may also attend AC sessions when common issues are discussed (e.g. compliance
risk assessment). The Chairperson of the AC may also invite to the meetings other executives of the Group or external advisors or
experts, as deemed appropriate.
6.2.3
Attendance to the AC Meetings
During 2025 the attendance details for the Audit Committee were as follows:
Company
Meetings
Average ratio of
Directors’ attendance
2025
2024
2025
2024
HoldCo
14
15
98%
97%
Bank
17
14
100%
98%
The Directors’ individual attendance rates at the AC meetings in 2025 were the following:
Name
Eurobank Holdings AC
Eurobank AC
Eligible to attend
Attended in person
(# and %)
Eligible to
attend
Attended in person
(# and %)
Burkhard Eckes,
AC Chairperson
14
14
100%
17
17
100%
Jawaid Mirza,
8
8
100%
9
9
100%
Irene Rouvitha Panou,
AC member
14
14
100%
17
17
100%
Rajeev Kakar,
14
13
93%
17
17
100%
Alice Gregoriadi,
AC member
14
14
100%
17
100%
It is noted that in 2025, Mr. Rajeev Kakar provided representation proxy for his missed meeting in HoldCo’s AC, leading his overall
attendance rate (physical and under representation) at 100% in HoldCo’s AC.
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6.2.4
AC’s Performance Evaluation
The AC’s 2025 evaluation by BoD members that are not members of the AC confirmed the Committee’s enhanced ability to support
the Board and to communicate its work clearly and effectively. The improvements noted reflect strengthened reporting, clearer
articulation of key issues and robust oversight across financial reporting, internal control and audit matters.
Similarly, the AC’s 2025 evaluation by its members confirms a very high level of effectiveness. The results reflect a mature, well-
functioning Committee with strong leadership, disciplined processes and comprehensive mandate coverage, while also pointing to
limited areas where further fine-tuning could enhance effectiveness.
In this context, the AC members identified a focused set of priority areas for further enhancement. These priorities largely reflect the
growing complexity of the Group, the expansion of international activities, and the increasing regulatory, technological and
supervisory demands placed on the Audit Committee.
6.2.5
ACs’ Activity in 2025
ACs have amongst others:
Eurobank for 2025
●
Decided on its constitution/reconstitution and the appointment of its Chairman.
●
Reviewed and approved the revised Compliance Mandate.
●
Jointly with the BRC, discussed and further submitted to the BoD for discussion the Business Risk Assessment Exercise (AML,
CFT, Sanctions) and the Compliance Risk Assessment for the Bank and international subsidiaries.
●
Approved and further submitted to the BoD for information the annual and triennial Plans of Internal Audit and Compliance
and monitored their progress.
●
Reviewed and discussed regular and ad hoc reports with information relating to the System of Internal Controls, including
quarterly reports from Group Internal Audit, Group Compliance, the Operational Risk Sector, Clients Relations Office, etc.
●
Received updates on various legal and regulatory issues.
●
Discussed extensively AML issues, including the legal and regulatory framework for the EU’s Anti-Money Laundering
Authority (AMLA) along with the respective implementation timeline for Eurobank.
●
Discussed various Group Compliance issues.
●
In line with the BoG Act 2577/2006 (that was in force in that time), ensured that an annual evaluation of the System of
Internal Controls for the year 2024 was performed and documented by the Internal Audit Group. This report, along with the
AC’s assessmen t, was further submitted to the BoD and subsequently to the BoG as required.
●
In line with the BoG Governors Act 2577/2006 (that was in force in that time), reviewed the annual Group Compliance
Sector’s reports on AML and compliance activities of the Bank for the year 2024. These reports, along with the AC’s own
assessment, were further submitted to the Board and the BoG.
●
Reviewed and submitted to the BoD for approval the revised Related Party Transactions Policy.
●
Reviewed and, depending on the case, approved or approved and further submitted to the BoD for approval/information:
a) the Compliance Policy, b) the Policy governing marketing communications of MiFID II investment products-services c) the
Inducements Policy, d) the new European Market Infrastructure Regulation (EMIR) Policy, e) the Policy on Safekeeping of
Clients’ Financial Instruments and Funds, f) the Appropriateness Assessment Policy, g) the Suitability Assessment Policy, h)
the Insider Dealing Guideline, i) the Group Anti-trust Compliance Policy, j) the Client/Investor Categorization Policy, k) the
Conflict of Interest Policy, l) the Anti-Bribery and Corruption Policy, m) the Order Execution Policy, n) the Policy for the
Prevention and Detection of Market Abuse, o) the Policy for Reporting Illegal or Unethical Conduct or Violations of European
Union Law, p) the AML/CFT and Sanctions Policy, q) the Code of Conduct and Ethics, r) the Policy for governance of MiFID II
financial products (MiFID II Product Governance).
●
In the context of the Policy for Reporting Illegal or Unethical Conduct or Violations of European Union Law (mentioned
above), approved and further submitted to the BoD for approval the Report Receiving & Monitoring Officer (RRMO) and the
Assistant RRMO.
●
In joint session with the BRC and the Board Digital Transformation Committee (BDTCo), approved the Policy regarding the
Responsible AI Framework.
●
in the presence of NomCo members for consultation, proposed to the BoD for approval the appointment of a new Money
Laundering Reporting Officer (MLRO), with effective date February 1st, 2025, pursuant to the provisions of article 38 of L.
4557/2018 and the Decision 281/17.3.2009 of the Banking and Credit Matters Committee of Bank of Greece.
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●
Discussed with Management, Internal Audit, and External Auditors issues relating to the financial results, including
accounting policies.
●
Discussed/approved (depending on the case) various Group Internal Audit issues, including its staffing, strategy, budget, and
training.
●
Strengthened its monitoring of the effectiveness of the IA functions of subsidiaries (in Greece and abroad).
●
Reviewed and cleared the consolidated financial statements.
●
Discussed with Management the implementation of corrective actions to recommendations made by Internal and External
Auditors and Regulatory Authorities.
●
Assessed the effectiveness, objectivity, and independence of the External Auditors for the financial year 2024, discussed the
results of their evaluation with Management and Internal Audit, and communicated the final results to the Board and the
External Auditors.
●
Approved the External Auditors’ Bank Group Audit and Assurance Fees for 2025.
●
Proposed to the Board and the Annual General Meeting of Shareholders for approval the appointment of the External
Auditors for the financial year 2025.
●
Approved the External Auditors’ Independence Policy and monitored, in line with this Policy, the non-audit services provided
by the External Auditor in 2025.
●
Assessed the performance of the Chief Audit Executive and the General Manager Head of Group Compliance/Anti-Money
Laundering Reporting Officer.
●
Monitored the memberships and the modus operandi of the Audit Committees of the banking subsidiaries, as required, and
reviewed their Activity Reports.
●
Approved AC Chair of Eurobank Bulgaria.
●
Discussed key Audit Committee issues with the Chairpersons of banking subsidiaries.
●
In accordance with the provisions of Law 2533/1997, the Audit Committee reviewed reports on substantial stock
transactions of the Bank’s Directors and General Managers that met the criteria set in Law 2533/1997 and notified the Board.
●
With the assistance of Group Finance, maintained oversight of the merger of Eurobank with Eurobank Holdings (Project
Square) and received regular updates on the project’s progress. In this context, the AC reviewed the final prospectus for the
submission to Hellenic Capital Markets Committee (HCMC) and subsequently each of the BoD members signed the
endorsement letter, which was signed following the AC’s clearance of the final prospectus.
●
Approved and notified the Board for further submission to the Annual General Meeting the annual AC Activity Report for
2024.
●
Discussed the Annual AC Plan for 2026.
●
At the BRC meetings that the AC members participated in, among others various issues including accounting policies,
progress reports for the Corporate Sustainability Report Directive (CSRD) Program Implementation, risk related issues such
as the operational and non-financial risks, Group Top ten non-financial risks report, Semi-annual COO/CIO report, Risk
Culture policy, the Information and Communication Technology risk (ICT risk) and security (incl. Cyber Security and Digital
Operational Resilience Act (DORA)), the climate-related and environmental risks, the
Minimum Requirement for Own Funds
and Eligible Liabilities
Governance (ESG) and the
General Data Protection Regulation (GDPR)
Eurobank Holdings (from 1 January until 12 December 2025)
●
Decided on their constitution/reconstitution and the appointment of their Chairman.
●
Reviewed and approved the Compliance Mandate.
●
Monitored the progress of Internal Audit and Compliance annual plans.
●
Reviewed and discussed reports related to Internal Audit and Compliance, including quarterly reports from the Internal
Audit and Compliance functions.
●
Discussed the progress of actions taken to resolve Internal Audit findings.
●
Received updates on various internal control, legal, and regulatory issues.
●
Ensured that an annual evaluation of the System of Internal Controls (SIC) for 2024 was performed and documented by
Internal Audit. This report, along with the AC’s assessment, was further submitted to the Board of Directors (BoD) and
subsequently to the Bank of Greece (BoG) as required.
●
In line with the BoG Governors Act 2577/2006 (that was in force at that time), acknowledged the annual Group Compliance
report on compliance activities for 2024. This report, along with the AC’s assessment, was further submitted to the BoD and
subsequently to BoG as required.
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●
Reviewed and submitted to the BoD for approval the revised Related Party Transactions Policy.
●
Reviewed and, depending on the case, ratified, approved, or approved and submitted to the BoD for approval/information:
a) the Compliance Policy, b) the Insider Dealing Guideline, c) the Group Anti-trust Compliance Policy, d) Policy for the
Prevention and Detection of Market Abuse, e) Policy for Reporting Illegal or Unethical Conduct or Violations of European
Union Law, f) Conflict of Interest Policy, g) Anti-Bribery and Corruption Policy.
●
In joint session with the BRC, approved the Policy regarding the Responsible AI Framework.
●
In the context of the Policy for Reporting Illegal or Unethical Conduct or Violations of European Union Law, approved and
submitted to the BoD for approval the appointment of the Report Receiving & Monitoring Officer (RRMO) and the assistant
RRMO.
●
Discussed financial results with Management, Internal Audit, and External Auditors.
●
Reviewed and cleared the financial statements and other financial reports and trading updates prior to their release.
●
Discussed with Management the implementation of corrective actions to recommendations made by Internal and External
Auditors and Regulatory Authorities.
●
Assessed the effectiveness, objectivity, and independence of the External Auditors for the financial year 2024, discussed the
results of their evaluation with Management and Internal Audit, and communicated the final results to the Board and the
External Auditors.
●
Proposed to the Board and the Annual General Meeting (AGM) the appointment of the External Auditors for the financial
year 2025.
●
Discussed and approved the Global Group Audit and Assurance Fees for 2025.
●
Approved the External Auditors’ Independence Policy and monitored, in line with this policy, the non-audit services provided
by the External Auditor in 2025.
●
Worked with Group Finance to complete the External Auditor’s tendering process for the Group statutory audit of 2027 and
subseuently made a recommendation to the BoD for the selection of the new Group External Auditors for 2027.
●
discussed various issues regarding the Corporate Sustainability Reporting Directive (CSRD), including the Sustainability
reporting process, the Sustainability IT Platform and the Group Internal Audit Report on CSRD, and received update on the
status of CSRD outlining key milestones and highlights of the 2025 Sustainability Statement
●
Assessed the performance of the Internal Auditor and the Head of Compliance/Anti-Money Laundering Reporting Officer
for 2024.
●
Received updates on the progress of the Annual Budget.
●
In accordance with the provisions of Law 2533/1997, reviewed reports on substantial stock transactions by HoldCo’s
Directors and General Managers that meet the criteria set in Law 2533/1997 and notified the Board.
●
Approved and submitted to the Board for further submission to the AGM the annual AC Activity Report for 2024.
●
Discussed the Annual AC Plan for 2026.
●
Participated in Board Risk Committee (BRC) meetings, during which discussions included:
o
Accounting policies, including hedge accounting policy.
o
Progress reports on the Corporate Sustainability Report Directive (CSRD) Program Implementation.
o
Various risks, including non-financial risks, climate-related and environmental risks, and the Environmental and Social
Governance (ESG) Strategy.
It is noted that in accordance with the Law 4449/2017 as in force, the Bank AC submits an annual activity report to their Shareholders’
Annual General Meeting on the issues dealt with by the AC during the previous year, also including a description of the sustainability
policy followed by the entity.
The 2025 Bank AC Activity Report, which forms part of the 2025 Annual Financial Report, provides a detailed account of the Bank AC’s
activities for 2025 and, for completeness purposes, also includes reference to the HoldCo AC’s activities for 2025.
6.3
Board Risk Committee
The purpose of the Bank’s Board Risk Committee (BRC) is to assist the Board in the following risk-related issues:
●
To advise and support Eurobank’s BoD regarding Eurobank’s capital management, the monitoring of the overall
actual/present and future risk strategy and risk appetite, taking into account all types of risks to ensure that they are in line
5
HoldCo/Bank BRCs’ Terms of Reference may be found at the HoldCo/Bank websites (
www.eurobankholdings.gr
www.eurobank.gr
).
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with the business strategy, objectives, corporate culture, corporate values and the availability of the Bank’s and the Bank’s
Group resources;
●
To provide Eurobank’s BoD with recommendations on necessary adjustments to the risk strategy resulting from, inter alia,
changes in the business model of Eurobank, market developments or recommendations made by the risk management
function;
●
To assist Eurobank’s BoD in overseeing the implementation of Eurobank’s risk strategy and the corresponding
limits/thresholds set;
●
To oversee the implementation of the capital and liquidity management strategies as well as for all material risks of the
Group, as identified through the Risk Identification and Materiality Assessment (RIMA) process and listed in the relevant
RIMA report, in order to assess their adequacy against the approved risk strategy and risk appetite. Material risk types
include financial and non-financial risks, indicatively credit risk, market risk, liquidity risk, interest rate risk and credit spread
risk in the banking book, counterparty risk, operational risk (including legal and IT, fundamental rights, discrimination and
ICT risks), outsourcing risk, climate risk, country risk, reputational risk, conduct risk, risk stemming from strategic projects;
●
To oversee the progress of the Bank to enhance its resolvability in accordance with the requirements of the Resolution
Authorities;
●
To review a number of possible scenarios, including stressed scenarios, to assess how Eurobank’s risk profile would react to
external and internal events;
●
To oversee the alignment between all material financial products and services offered to clients and the business model and
risk strategy of Eurobank. The BRC should assess the risks associated with the financial products and services offered and
take into account the alignment between the prices set for them and the profits derived from them;
●
To provide advice on the appointment of external consultants that Eurobank’s BoD may decide to engage for advice or
support on matters within its competence;
●
To assess the recommendations of internal or external auditors and follow up on the appropriate implementation of
measures taken on matters within its competence;
●
To ensure the development of an internal risk management framework and its integration into the business decision-making
process (e.g. decisions concerning new products and services introduction, risk adjusted pricing for products and services,
risk related performance measurement and capital allocation) across the full range of Eurobank’s activities or operations
and the Group;
●
To define the principles that must govern risk management regarding the identification, forecasting, measurement,
monitoring, control, and mitigation of risks, in line with the applicable business strategy and the adequacy of the available
resources;
●
To receive and evaluate the reports submitted at least quarterly by the risk management function/GCRO, inform Eurobank’s
BoD about the most significant risks undertaken by the Bank and document their effective management.
●
implementation of the Bank's risk management strategy or deviations in its implementation.
●
To set, approve and oversee the implementation of the Bank’s core values and expectations regarding all material risks and
propose to the BoD the approval of the Bank’s risk culture.
Throughout its operation, until 12 December 2025, HoldCo BRC carried out responsibilities and duties similar to those described
above.
6.3.1
BRC Membership/Composition
The BRCs consist of five (5) independent non-executive Directors. The Chairperson qualifies as independent member with a solid
experience in commercial banking and preferably risk and/or Non-Performing Exposures management and is familiar with the Greek
and international regulatory framework.
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The BRCs’ composition is outlined below:
BRC Chairperson:
Rajeev Kakar,
Non-Executive Independent Director of the Board
BRC Vice-Chairperson:
Non-executive Independent Director of the Board
BRC Members:
Cinzia Basile,
Burkhard Eckes,
Non-Executive Independent Director of the Board
Evangelos Kotsovinos
, Non-executive Independent Director of the Board
It is noted that during 2025 no changes occurred in the composition of the Committee, as no such need arose.
6.3.2
BRC Meetings
The BRC meets at least ten (10) times per year and the Chairperson updates the BoD members on the material matters covered by
the Committee during the previous period (if any) at the quarterly meetings of the BoD.
Apart from the BRC members, the AC’s members may also attend BRC sessions when common issues are discussed (i.e. on operational
risk matters, on IT security and cyber risks). The Chairperson of the BRC may also invite to the meetings other executives of the Group
or external advisors or experts, as deemed appropriate.
6.3.3
Attendance to the BRC Meetings
During 2025, attendance details for the Board Risk Committee were as follows,
Company
Meetings
Average ratio of
Directors’ attendance
2025
2024
2025
2024
HoldCo
11
12
93%
95%
Bank
13
12
95%
95%
The Directors’ individual attendance rates at the BRC meetings in 2025 were the following:
Name
Eurobank Holdings
BRC until 12
December 2025
Eurobank BRC
Eligible to attend
Attended in person
(# and %)
Eligible to
attend
Attended in
person
(# and %)
Rajeev Kakar,
BRC
Chairperson
11
11
100%
13
13
100%
John Arthur Hollows,
11
11
100%
13
13
100%
Cinzia Basile,
BRC member
11
10
91%
13
12
92%
Burkhard Eckes,
11
10
91%
13
12
92%
Evangelos Kotsovinos,
BRC member
11
9
82%
13
12
92%
It is noted that in 2025, Ms. Cinzia Basile, Mr. Burkhard Eckes and Mr. Evangelos Kotsovinos provided representation proxies for their
missed meetings in HoldCo/Bank’s BRCs, leading their overall attendance rate (physical and under representation) at 100% in
HoldCo/Bank’s BRCs.
6.3.4
BRCs’ Performance Evaluation
The 2025self-evaluation conducted by the HoldCo/Bank BRCs indicates that the Committee remains substantively strong, with high
levels of expertise, challenge and regulatory alignment, while also highlighting persistent pressures around time management, agenda
density and balance of participation.
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The evaluation also highlighted a clear set of priorities centred on strengthening Group-wide risk integration, enhancing forward-
looking and independent risk judgement, improving time management and agenda discipline, and deepening coverage of non-
financial and emerging risks. The feedback also places strong emphasis on regulatory credibility and alignment with supervisory
expectations.
6.3.5
BRCs’ Activity in 2025
The BRCs have, amongst others:
Eurobank in 2025
●
Monitored Eurobank’s overall actual and future risk appetite and strategy, ensuring that all types of risks were aligned with
the institution’s business strategy, objectives, corporate culture, and values.
●
Oversaw both qualitative and quantitative aspects of credit, market, liquidity, and operational and non-inancial risks.
●
Reviewed Information and Communication Technology (ICT) Risk and Security, including Cyber Security, Physical Security,
and Fraud Detection.
●
Approved various regulatory and other reports, risk policies, and frameworks, including:
o
Liquidity Report.
o
Counterparty and Issuer Risk Report.
o
Interest Rate Risk in the Banking Book / Credit Spread Risk in the Banking Book.
o
Market Risk Developments Report.
o
Group Operational and Non-Financial Risk Report.
o
Asset Quality Monthly and Quarterly Update.
o
Impairment Results: Quarterly Update.
o
New Disbursements Performance Report.
o
Forbearance Report.
o
Quarterly NPE & Early Remedial update.
o
Quarterly Securitizations Performance Update Report.
o
Risk Appetite Dashboard.
o
Bank’s Macro Hedging Strategy Updates.
o
BCBS239 Project implementation progress update
o
CIB international expansion strategy
o
OSI findings updates (Postbank for Credit Counterparty)
o
CHF loans update
o
SREP 2025 update
o
Country limits
o
IFRS9 risk parameters update and models validation report
o
Varius Policies reviews incl., Sensitive Borrowers Policy, Related parties credit approval policy, CPMs, Market and
Counterparty Risk Policy, Liquidity Risk Policy, IRRBB & CSRRB, write off policy, Country limits framework etc.
o
International Subsidiaries Monitoring, including key risk indicators, the BRC Chairman’s Annual Activity Report, and the
approval of BRC Chairs appointed during 2024.
●
BRC meetings where AC members were also invited, discussing and approving the following issues:
o
Resolvability Progress Report.
o
Corporate Sustainability Report Directive (CSRD) program implementation
o
Climate and Environmental Risk issues incl. Collateral Valuation Policy enhancements to incorporate CR&E aspects,
climate and Environmental Risks Dashboard, Semiannual update of responsible BoD person, Climate related &
Environmental Risks Materiality Assessment; Group Climate Risk Stress Test Framework; Omnibus key implications for
the Bank
o
Quarterly Outsourcing report
o
Quarterly Group Operational and Non-Financial Risk Report
o
Group top 10 NFR annual risk review, semiannual actions update
o
ICT & Security Risk Management framework and regular updates
o
OSI Low Start Deep dive, Low Start portfolio updates and FRC model review
o
EBA Guidelines on management of ESG Risks progress updates
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o
GDPR status updates
o
Notification for breaches of Risk Appetite Statements (RAS) thresholds
o
MREL plan
o
Various Accounting Policies (e.g. Classification & Measurement of financial assets)
o
Risk Culture Policy
Eurobank Holdings (for the period from 1.1.2025 until 12.12.2025)
●
Monitored the Group’s overall actual and future risk appetite and strategy, ensuring alignment with the business strategy,
objectives, corporate culture, and values of the Group, while considering all types of risks.
●
Approved various regulatory and risk-related reports, policies, and frameworks, including:
o
Internal Capital & Liquidity Adequacy Assessment Processes (ICAAP/ILAAP)
o
Capital Adequacy Statements (CAS) and Liquidity Adequacy Statements (LAS)
o
Risk Identification and Materiality Process (RIMA) Report
o
Group Recovery Plan
●
Approved the Group Chief Risk Officer (GCRO) Annual Report.
●
Approved the Group Risk and Capital Strategy, the Risk Appetite Framework (RAF), and the Risk Appetite Statements (RAS),
including the RAS dashboard.
6.4
Remuneration Committee
The Bank’s Boards has delegated to RemCo the responsibilities (a) to provide specialized and independent advice for matters relating
to remuneration policy and its implementation at Bank Group level and for the incentives created while managing risks, capital and
liquidity, (b) to safeguard the proper exercise of its duties and responsibilities, the efficient alignment of the personnel’s remuneration
with the risks the Bank undertakes and manages and the required alignment between the Bank and the Group, and (c) to approve or
propose for approval all exposures of Key Management Personnel and their relatives (spouses, children, siblings). The Non-Executive
Directors of Bank have the responsibility to approve and periodically review Bank’s remuneration policy and oversee its
implementation both at Bank and Group level.
The implementation of the Bank remuneration policy is in line with the provisions of Law 4261/2014 and Bank of Greece Executive
Committee’s Act 231/2024.
The Bank RemCo is also responsible to:
●
determine the remuneration system for the members of the Board of Directors and the senior executives and to make a
relevant recommendation on them to the Board of Directors, which decides on them or to make recommendations to the
General Meeting, where required,
●
propose to the Non-Executive Directors of the HoldCo/Bank’s BoD for their approval the goals and objectives relevant to the
Bank’s CEO remuneration and evaluate his/her performance in light of these goals and objectives,
●
guide and monitor the external remuneration consultant (if hired) and ensure that it receives appropriate reporting from
him/her. In addition, Bank RemCo ensures that the external consultant is referred in the Bank’s annual report of the year
hired and/or completed his/her work, together with a statement of any possible relationship between him/her and the Bank
or with members of the Bank’s Board individually.
The above responsibilities and duties also applied to HoldCo RemCo until the date of the merger, 12 December 2025.
6.4.1
RemCo’s Membership/Composition
The Bank RemCo consists of four (4) independent non- executive Directors.
In the event that the Chairperson of the Bank’s Board is a member of the RemCo, she/he cannot participate in the determination of
his/her remuneration.
6
HoldCo/Bank RemCos’ Terms of Reference may be found at the HoldCo/Bank websites (
www.eurobankholdings.gr
www.eurobank.gr
).
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The Bank RemCo’s composition is outlined below:
RemCo Chairperson:
Cinzia Basile,
Non-executive Independent Director of the Board
Members:
Non-Executive Independent Director of the Board
John Arthur Hollows,
Non-Executive Independent Director of the Board
Following Mr. Jawaid Mirza’s resignation dated 18.06.2025 from the position of member of the Bank BoD and member of the Bank
BoD Committees he served, effective as of 27.06.2025 and the Bank Nomination & Corporate Governance Committee’s relevant
recommendation, the Bank BoD of 27.06.2025 decided the Bank RemCo to continue its operation with the remaining independent
non-executive directors.
Throughout the period of its operation, until 12 December 2025, the composition of the HoldCo RemCo was identical to that of the
Bank RemCo.
6.4.2
RemCo’s meetings
RemCo meet at least twice a year.
6.4.3
Attendance to the RemCo meetings
During 2025 the attendance details for the Remuneration Committees were as follows:
Company
Meetings
Average ratio of
Directors’ attendance
2025
2024
2025
2024
HoldCo
10
11
100%
100%
Bank
11
11
100%
100%
6.4.4
RemCo’s Performance Evaluation
The 2025 self-evaluation conducted by RemCos’ members reflects a clear improvement in overall effectiveness. This positive
development indicates strengthened leadership, improved meeting discipline, and more consistent engagement by Committee
members, while also confirming that the RemCo has responded constructively to areas for enhancement identified in the previous
year.
in addition the evaluation by non-members highlighted heightened expectations regarding the Committee’s visibility, clarity of
outcomes and communication to the Board, particularly in the context of ongoing pressure on remuneration competitiveness,
regulatory constraints and talent retention considerations.
6.4.5
RemCos' Activity in 2025
For 2025, RemCos have amongst others:
Eurobank for 2025
●
Proposed to the Board of Directors (BoD) for approval the revised RemCo Terms of Reference.
●
Received the Board and Board Committees evaluation 2024 outcome for RemCo and discussed an action plan and
suggestions for improvement.
●
Reviewed and proposed to the BoD and the General Meeting for approval the Board of Directors Remuneration Policy (post
merger).
●
Reviewed and proposed to the Non-Executive Directors for approval the Group Greece Annual Base Salary Framework.
●
Reviewed and proposed to the Non-Executive Directors for approval the Variable Remuneration - Key Performance
Indicators (KPIs) & Key Risk Indicators (KRIs) and the Group Variable Remuneration Pool.
●
Reviewed and approved the Material Risk Takers’ List and the Remuneration Disclosures for 2024.
●
Discussed the remuneration policy implementation at both the Bank and Group levels.
●
Discussed the Remuneration Policy Review – Follow-up (for the year 2024), conducted by the Internal Audit Group.
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●
Proposed to the Board and Annual General Meeting (AGM) for approval the Board and Board Committees’ Fees for Non-
Executive Directors of the Bank (Actual Fees 2024 & Estimated Fees 2025).
●
Proposed to the Board and AGM for approval:
o
The distribution of net profits to senior management and employees.
o
Approvals in accordance with Article 86 of Law 4261/2014.
●
Proposed to the Non-Executive Directors of the Bank for approval the CEO’s Performance Evaluation for 2024 and the CEO’s
Financial and Non-Financial Objectives for2025.
●
Reviewed the implementation of the Board and Board Committees’ Attendance Policy.
●
Discussed and further submitted to the Board for approval the implementation of the Group Subsidiary Board Remuneration
Policy across the Group.
●
Depending on the case, approved or proposed to the Non-Executive Directors for approval various remuneration issues
related to subsidiaries.
●
Depending on the case, approved or proposed to the Non-Executive Directors for approval various remuneration issues and
borrowing requests.
●
Received and reviewed the annual updates from the RemCo Chairpersons of the Group’s banking subsidiaries.
●
Approved the appointment of a new RemCo Chairperson in Eurobank Bulgaria.
●
Discussed / received updates on various issues:
o
The Benefits and Business Related Components Framework.
o
The Board Fees framework
o
Gender pay gap
●
Reviewed and proposed to the Non-Executive Directors for approval Implementation of the Group Separation Policy at
Group level
●
Approved the engagement of a consulting firm for the Benchmarking Remuneration Exercise which aims to address critical
remuneration challenges, particularly those related to the retention of key senior executives and discussed the results of
this exercise.
●
Received dedicated training for the following topics:
o
Evolving trends in Executive and Non-Executive remuneration
o
Regulatory Compliance in Executive Compensation
●
Discussed the Annual RemCo Plan for 2026.
Eurobank Holdings (for the period from 1.1.2025 until 12.12.2025)
●
Proposed to the Board of Directors (BoD) for approval the revised RemCo Terms of Reference.
●
Received the Board and Board Committees evaluation 2024 outcome for RemCo and discussed an action plan and
suggestions for improvement.
●
Reviewed and proposed to the Board and the Annual General Meeting (AGM) for approval the Remuneration Policy for
Directors.
●
Reviewed and proposed to the Non-Executive Directors for approval the Group Greece Annual Base Salary Framework.
●
Reviewed and proposed to the Non-Executive Directors for approval the Variable Remuneration - Key Performance
Indicators (KPIs) & Key Risk Indicators (KRIs) and the Group Variable Remuneration Pool.
●
Reviewed and approved the Material Risk Takers’ List and the Remuneration Disclosures for 2024.
●
Discussed the remuneration policy implementation at the Group level.
●
Discussed the Remuneration Policy Review – Follow-up (2024), conducted by the Internal Audit Group.
●
Proposed to the Board and AGM for approval the Board and Board Committees’ Fees for Non-Executive Directors of the
HoldCo (Actual Fees 2024 & Estimated Fees 2025).
●
Proposed to the Board and AGM for approval the Remuneration Report for the financial year 2024.
●
Proposed to the Board and AGM for approval:
o
The distribution of net profits to senior management and employees.
o
Approvals in accordance with Article 86 of Law 4261/2014.
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●
Proposed to the Non-Executive Directors for approval the CEO’s Performance Evaluation for 2024 and the CEO’s Financial
and Non-Financial Objectives for 2025.
●
Reviewed and approved the Material Risk Takers’ List and the Remuneration Disclosures for 2024.
●
Reviewed the implementation of the Board and Board Committees’ Attendance Policy.
●
Depending on the case, approved or proposed to the Non-Executive Directors for approval various remuneration issues and
borrowing requests.
●
Proposed to the Board for approval the Stock Option Plan 8 – 5th Series
●
Reviewed and proposed to the Non-Executive Directors for approval Implementation of the Group Separation Policy at
Group level.
●
Approved the engagement of a consulting firm for the Benchmarking Remuneration Exercise which aims to address critical
remuneration challenges, particularly those related to the retention of key senior executives and discussed the results of
this exercise.
●
Received dedicated training for the following topic:
o
Evolving trends in Executive and Non-Executive remuneration
6.5
Nomination and Corporate Governance Committee
Bank’s Board has delegated to the NomCo the responsibilities (a) to lead the process for Board and Board Committees appointments,
including the identification, nomination and recommendation of candidates for appointment to the Board, (b) to consider matters
related to the Board’s adequacy, efficiency and effectiveness and (c) review the Group’s corporate governance policies, procedures
and arrangements and recommend, where appropriate revisions for the approval of the Board of Directors.
The NomCo, in carrying out its duties, is accountable to the Board.
In particular, among others, the NomCo is responsible:
●
at least annually and in accordance with Board and Board Committees Evaluation Policy, to assess the structure, size,
composition and performance of the BoD and make recommendations to the BoD with regard to the need for its renewal
and/or any other changes it considers appropriate,
●
at least annually and in accordance with Board and Board Committees Evaluation Policy, to assess the knowledge, skills,
experience and contribution of individual Board members and of the Board collectively and report to the BoD accordingly,
●
in the context of Board and Board Committees Evaluation Policy implementation, to determine the evaluation parameters
based on best practices and ensure the effectiveness of the evaluation of the Board, the individual evaluation of Non-
Executive Directors, including the Chair, the succession plan of the Chief Executive and the members of the Board, the
targeted composition of the Board of Directors in relation to the strategy and Board Nomination Policy,
●
to play a leading role in the nomination process and the design of the succession plan for the members of the Board and
senior management,
●
to review at least once every two years and recommend for the approval of the BoD the BoD Nomination Policy,
●
to ensure that the nomination process, as this is defined in the BoD Nomination Policy, is clearly defined and applied in a
transparent manner and in a way that ensures its effectiveness,
●
to ensure that there is adequate, step-wise succession planning for Board members so as to maintain an appropriate level
of continuity and organizational memory at Board level, especially when dealing with sudden or unexpected absences or
departures of Board members,
●
to monitor the Board succession planning in order to ensure the smooth succession of the members of the Board with their
gradual replacement in order to avoid the lack of management,
●
to ensure that the succession framework takes into account the findings of the evaluation of the Board in order to achieve
the necessary changes in composition or skills and to maximise the effectiveness and collective suitability of the Board,
●
to review at least annually and always before the initiation of the CEO succession process the qualifications required for the
position of the CEO, to ensure that there is a viable pool of internal and external candidates and also to ensure that the CEO
is involved in all the areas of CEO Succession Plan, including the assessment of the nominees for his/her position, as he
deems appropriate,
●
to ensure that the CEO is involved in the succession planning process of the senior executives at the level of the CEO minus
one, including the assessment of nominees for the said positions.
7
HoldCo/Bank NomCos’ Terms of Reference may be found at the HoldCo/Bank websites (
www.eurobankholdings.gr
www.eurobank.gr
).
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The above responsibilities and duties also applied to HoldCo NomCo until the date of the merger, 12 December 2025.
As far as NomCos of subsidiaries are concerned, the Eurobank NomCo cannot replace them, nor did the HoldCo NomCo replace them
during the period of its operation. However, the Eurobank NomCo has the overall responsibility to oversee that the NomCos of
subsidiaries comply with its standards, modus operandi and governance framework.
6.5.1
NomCo Membership/Composition
The Bank NomCo consists of four (4) non-executive Directors, three (3) of whom are independent Directors, including the Chairperson
who may not serve as the Chairperson of the Remuneration Committee.
Throughout the period of its operation, until 12 December 2025, the composition of the HoldCo NomCo was identical to that of the
Bank NomCo.
The NomCo composition is outlined below:
NomCo Chairperson:
Irene Rouvitha Panou,
Non-Executive Independent Director of the Board
George Zanias,
Rajeev Kakar,
Non-Executive Independent Director of the Board
Burkhard Eckes,
Non-Executive Independent Director of the Board
Following Mr. Jawaid Mirza’s resignation dated 18.06.2025 from the position of member of the Bank BoD and member of the Bank
BoD Committees he served, effective as of 27.06.2025 and the Bank Nomination & Corporate Governance Committee’s relevant
recommendation, the Bank BoD of 27.06.2025 decided the Bank NomCo to continue its operation with the remaining independent
non-executive directors.
Throughout the period of its operation, until 12 December 2025, the composition of the HoldCo NomCo was identical to that of the
Bank NomCo.
6.5.2
NomCo Meetings
NomCo meets at least twice a year.
6.5.3
Attendance to the NomCo meetings
During 2025 the attendance details for the NomCo were as follows:
Company
Meetings
Average ratio of Directors’
attendance
2025
2024
2025
2024
HoldCo
10
10
95%
98%
Bank
11
10
95%
98%
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Directors’ individual attendance rates at the NomCo meetings in 2025 were the following:
Name
Eurobank Holdings
NomCo until 12
December 2025
Eurobank NomCo
Eligible to
attend
Attended in person
(# and %)
Eligible to
attend
Attended in
person
(# and %)
Irene Rouvitha Panou, NomCo
Chairperson
10
10
100%
11
11
100%
George Zanias, NomCo member
10
9
90%
11
10
91%
Jawaid Mirza, NomCo member until 27.6.2025
6
6
100%
6
6
100%
Rajeev Kakar
10
10
100%
11
11
100%
Burkhard Eckes, NomCo member
10
9
90%
11
10
91%
Irene Rouvitha Panou, NomCo
Chairperson
10
10
100%
11
11
100%
It is noted that in 2025, Mr. George Zanias and Mr. Burkhard Eckes provided representation proxies for their missed meetings
in
Bank/HoldCo’s NomCos, leading their overall attendance rate (physical and under representation) at 100% in Bank/ HoldCo’s NomCos.
6.5.4
NomCos’ Performance Evaluation
The 2025 self-evaluation conducted by the NomCos indicates excellent preparation, structured agenda management, high-quality
participation and a well-balanced composition, confirming the Committee’s effectiveness in addressing its mandate across
nomination, succession and governance matters. Leadership is also assessed positively, confirming effective and constructive chairing
and a solid governance tone.
The evaluation also highlighted opportunities for further enhancement. Areas requiring ongoing focus included a forward-looking
agenda focused on Board and Senior Management succession planning, structured skills mapping, diversity and inclusion priorities,
and the continued strengthening of Group-wide governance alignment, including across international subsidiaries.
6.5.5
NomCos’ Activity in 2025
NomCos have amongst others:
Eurobank for 2025
●
Proposed to the Board of Directors (BoD) for approval the revised NomCo Terms of Reference.
●
Reviewed the Board and Board Committees' 2024 self-evaluation and the Board’s overall effectiveness assessment for
further update to the Board. Additionally, reviewed and acknowledged the Action Plan for the BoD Evaluation 2024.
●
Reviewed and proposed to the BoD for approval the assessment of the Corporate Governance System (L.4706/2020
requirement)
●
Received update on the annual Performance Evaluation and the semi-annual Feedback Process for Key Function Holders.
●
Discussed, approved and/or proposed to the Board for approval (depending on the case) the Board nomination process, the
composition of the Board Committees and other Board and Board Committees’ matters.
●
Reviewed and proposed to the Board for approval various governance and nomination policies, including:
o
CEO Succession Planning Policy.
o
Board of Directors Diversity Policy.
o
Key Function Holders Selection and Appointment Policy.
o
Group Governance Policy.
o
External Engagements Policy.
o
Board and Board Committees Evaluation Policy.
o
C-Level Succession Planning Policy.
o
Senior Management Selection and Appointment Policy.
o
Board Nomination Policy – that was also proposed to the General Meeting for approval.
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●
Received update on the organizational chart of Eurobank.
●
Proposed to the Board for approval the Internal Governance Control Manual.
●
Received quarterly updates on governance-related issues.
●
Discussed various governance-related issues, including:
o
The new Law 5178/2025 on Board Gender Diversity and its implementation.
o
Action plan for strengthening ESG ratings
o
Compliance Risk Assessment (CRA) related to the Corporate Governance Framework.
o
Annual implementation report of the Group Governance Policy by Eurobank’s banking subsidiaries and the Review of
Group Governance Policy Implementation by Group Internal Audit (Assurance Assignment).
●
Discussed and/or approved various issues regarding significant subsidiaries, including the selection of candidates as Board
members of the Group’s significant subsidiaries and the Hellenic Bank BoD following the completion of the Transfer of
Business from Eurobank Cyprus to Hellenic Bank.
●
Received and reviewed the annual updates from the NomCo Chairpersons of the Group’s banking subsidiaries and approved
the NomCo Chairperson in Eurobank Private Bank Luxembourg.
●
Reviewed, discussed, and approved (depending on the case) various succession planning issues, including:
o
CEO Succession Plan.
o
Roadmap for 2025 NomCo's oversight of the C-Level succession planning process and gender diversity.
o
The C-Level Succession Planning Assessment Criteria.
o
The Criteria for identifying emergency/interim successors and process for activating emergency succession.
o
2025 C-Level Succession Planning: SPC members & Key Function Holders.
●
Approved
●
of Directors at the Board and its Committees.
●
Discussed the external engagements for Board members.
●
Reviewed the independence of the Independent Non-Executive Directors.
●
Reviewed the attendance gender Diversity in Executive & Senior Management: forward-looking initiatives.
●
Reviewed the Terms of Reference of the Board Digital and Transformation Committee (BDTCo) to ensure alignment with the
corporate governance framework, prior to submission to the BoD for approval (by the BDTCo)
●
Discussed the NomCo Annual Plan for 2026.
Eurobank Holdings (for the period from 1.1.2025 until 12.12.2025)
●
Proposed to the Board of Directors (BoD) for approval the revised NomCo Terms of Reference.
●
Reviewed the Board and Board Committees' 2024 self-evaluation and the Board’s overall effectiveness assessment for
further update to the Board. Additionally, reviewed and acknowledged the Action Plan for the BoD Evaluation 2024.
●
Reviewed and proposed to the BoD for approval the assessment of the Corporate Governance System (L.4706/2020
requirement)
●
Received update on the annual Performance Evaluation and the semi-annual Feedback Process for Key Function Holders
●
Discussed, approved and/or proposed to the Board for approval (depending on the case) the Board nomination process the
new composition of the Board Committees and other Board and Board Committees’ matters.
●
Reviewed and proposed to the Board for approval various governance and nomination policies, including:
o
CEO Succession Planning Policy.
o
Board of Directors Diversity Policy.
o
Key Function Holders Selection and Appointment Policy.
●
Received an update on the HoldCo Group Organizational Chart.
●
Reviewed and proposed to the Audit Committee and the Board for approval the 2024 Corporate Governance Statement.
●
Received quarterly updates on governance-related audit issues.
●
Discussed various governance-related issues, including:
o
The new Law 5178/2025 on Board Gender Diversity and its implementation.
o
Action plan for strengthening ESG ratings
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●
Reviewed, discussed, and approved (depending on the case) various succession planning issues, including:
o
CEO Succession Plan.
o
Roadmap for 2025 NomCo's oversight of the C-Level succession planning process and gender diversity
o
C-Level Succession Planning Assessment Criteria.
o
Criteria for identifying emergency/interim successors and process for activating emergency succession
o
2025 C-Level Succession Planning: SPC members & Key Function Holders.
●
Approved external engagements for Board members.
●
Reviewed the independence of the Independent Non-Executive Directors.
●
Reviewed the attendance of Directors at the Board and Board Committees.
6.5.6
Senior Management Diversity
The Bank, as a major employer of women, is committed to fostering an inclusive employment framework and culture that enables
women to thrive. Eurobank provides supportive working arrangements, robust learning and development opportunities, and
equitable career pathways to empower women to excel in senior management roles.
To advance this commitment, the Bank is implementing a series of targeted strategic initiatives and has taken significant steps to
enhance gender diversity, strengthen leadership pipelines, and support the professional growth of women executives:
•
C-Level Succession Planning: A key initiative is the annual C-Level Succession Planning exercise, which aims to improve the
underrepresented gender ratio in the successors’ pool. In the 2025 succession planning exercise, 30% of the total C-Level
successors’ pool were women, demonstrating a strong commitment to gender diversity at senior levels.
•
Participation in “The Boardroom” initiative: The Bank actively participates in initiatives such as "The Boardroom" in Greece,
which supports senior female leaders aspiring to become Board members in major organizations. By sponsoring such
initiatives, the Bank encourages employees and clients to pursue leadership roles.
•
Women in Banking (WiB) programme: The Bank has successfully completed the third season of the Women in Banking (WiB)
programme, following the strong momentum of the previous cycles. WiB is an Accelerating Talent initiative designed to
empower women across Eurobank, supporting their progression into higher leadership roles, driving transformative change,
and promoting an inclusive and equitable work environment. The collaboration among participants from all three seasons,
together with the involvement of 200 mentors and mentees, has created a vibrant and growing WiB Community within
Eurobank.
•
C-1 Succession Planning Review: In 2025, the Bank completed the first review of C-1 succession planning, complementing
the existing C-Level succession framework. Notably, 38% of the total C-1 successor pool were women, demonstrating the
strong potential for further enhancement and support of the Bank’s female senior talent pipeline.
•
DE&I Awareness Training: As part of the Bank’s ESG Strategy, a DE&I awareness training programme for all managers was
completed in 2025 to reinforce inclusivity.
6.6
Board Digital & Transformation Committee
The Bank’s Board Digital & Transformation Committee (BDTC) operates as a non-regulatory, consultative forum, supporting the
Board’s engagement on digital and transformation matters from a strategic perspective. The BDTC, in carrying out its duties, is
accountable to the Bank Board.
8
Bank BDTC Terms of Reference may be found at the Bank websites (
www.eurobank.gr
).
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6.6.1
BDTC Membership / Chairmanship
The BDTC consists of five (5) Directors of whom one (1) executive and (4) independent non-executives. The BDTC composition is
outlined below:
BDTC Chairperson:
Alice Gregoriadi,
Non-Executive Independent Director of the Board
Members:
Cinzia Basile,
John Arthur Hollows,
Non-Executive Independent Director of the Board
Evangelos Kotsovinos,
Non-Executive Independent Director of the Board
Stavros Ioannou,
Executive Director of the Board
It is noted that during 2025 no changes occurred in the composition of the Committee, as no such need arose.
6.6.2
BDTC Meetings
BDTC meets at least twice a year and as The Committee meets at least twice a year and as often as required. It is noted that the
annually held Strategy Away Day is also a forum in which relevant digital and transformation strategic matters may be discussed.
6.6.3
BDTC Attendance Rate
During 2025, BDTC held thee (3) meetings and the ratio of attendance was 87% (vs. four (4) meetings with ratio of attendance was
100% in 2024).
The Directors’ individual attendance rates at the BDTC meetings in 2025 were the following:
Name
Eurobank ‘s BDTC
Eligible to
attend
Attended in person
(# and %)
Alice Gregoriadi,
BDTC Chairperson
3
3
100%
BDTC member
3
2
67%
Cinzia Basile,
BDTC member
3
3
100%
Evangelos Kotsovinos,
3
3
100%
Stavros Ioannou,
BDTC member
3
2
67%
It is noted that in 2025, Mr. John Arthur Hollows and Mr. Stavros Ioannou provided representation proxies for their missed meetings
in Bank’s BDTCo, leading their overall attendance rate (physical and under representation) at 100% in Bank’s BDTCo.
6.6.4
BDTC Performance Evaluation
The 2025 evaluation of the BDTC highlights opportunities to enhance its effectiveness. While the Committee has provided valuable
insights, feedback suggests a need for more outcome-driven discussions and a stronger focus on high-impact initiatives. Non-
committee members emphasized to align expectations regarding strategic relevance and visible impact at Board level with the
outcomes currently perceived.
BDTCo members marked a material improvement in 2025 (vs. 2024), reflecting tangible progress in leadership effectiveness, meeting
structure, agenda discipline and mandate coverage. Members recognised that actions taken during the year have strengthened the
Committee’s internal functioning and its ability to engage constructively on digital and transformation topics.
6.6.5
BDTC’s Activity in 2025
In 2025, the BDTC reviewed the Board and Board Committees evaluation 2024 outcome for BDTC and discussed on action plan and
suggestions for improvement. The Committee also proposed its Terms of Reference (ToR) for Board approval.
Throughout the year, the Committee reviewed updates on:
●
the Eurobank 2030 Transformation Plan and Digital metrics
●
the global digital banking study Digital Banking Maturity 2024 and the Digital Banking Benchmarking
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●
the Journey to Cloud and Data Transformation
●
the Sustainability and alignment with Transformation
●
the Core Banking System in Eurobank and Luxembourg and the Cyprus Operational Merger Plan and Status
●
the Digital Leader Strategy
●
the Embedded Banking
7
Management Committees
At the Bank level, the CEO establishes committees as needed to assist in fulfilling his duties and responsibilities. The most significant
committees include the Executive Board, the Strategic Planning Committee, the Management Risk Committee, the Group Asset and
Liability Committee, the Central Credit Committees (I & II), the Troubled Assets Committee, the Products and Services Committee
(PSC), and the Sustainability Management Committee (SMC).
At the HoldCo level, however, the CEO had not established committees, as there was neither a regulatory requirement nor a business
necessity.
7.1
Management Committees’ Policy
The Bank has implemented the Management Committees’ Policy, which defines the framework and general principles governing the
establishment, dissolution, and operation of a Management Committee (MCo). This policy aligns with international corporate
governance best practices and regulatory requirements, where applicable. It also establishes the minimum requirements for each
MCo’s Terms of Reference (ToR).
According to the Management Committees’ Policy:
●
The establishment of each MCo is formally announced through a Management Act, which clearly defines the purpose,
composition, and Chairperson of the Committee. This Management Act is signed by the CEO and, where applicable, by the
responsible Deputy CEO or General Manager.
●
The MCo’s ToR are approved by the CEO and define, among other aspects, the modus operandi, including the frequency of
meetings, quorum requirements, and decision-making process. The ToR are reviewed regularly and revised as needed, with
any updates also requiring the CEO’s approval.
●
Individuals who are not MCo members or the MCo Secretary—such as Board members, Bank or Group subsidiary officers,
or external auditors/consultants—may be invited to attend all or part of an MCo meeting, depending on the topics under
discussion. These individuals do not have voting rights, and their attendance is determined by the MCo Chairperson.
●
The MCo Secretary, appointed when the MCo is established and stated in the Management Act, supports the Chairperson
in ensuring the effective operation of the MCo. The Secretary’s responsibilities include maintaining an annual meeting
calendar, coordinating logistics, recording attendance, ensuring quorum requirements are met, documenting meeting
minutes and resolutions, and issuing extracts of decisions. Additionally, the Secretary notifies responsible managers about
relevant discussions or actions required.
●
Each MCo is required to define evaluation criteria based on its ToR and to assess its performance annually. If the Chairperson
identifies concerns related to the scope or functioning of the MCo, an earlier evaluation may be conducted.
●
The CEO has the discretion to dissolve an MCo at any time, with the dissolution formally communicated through a
Management Act.
7.2
Executive Board (ExBo)
7.2.1
CVs of ExBo members (other than BoD members)
The composition of the Executive Board (ExBo), excluding the Executive Members of the Board of Directors who are also ExBo
members, is summarized below. The CVs of Mr. F. Karavias (CEO), Mr. S. Ioannou (Deputy CEO), and Mr. K. Vassiliou (Deputy CEO)
are presented in the Board of Directors section. Short biographical details of the remaining ExBo members are provided below
the
CVs of the ExBo members may be found at the Bank website
https://www.eurobank.gr/en/group/about-eurobank/corporate-
governance/committees-formed-by-the-ceo/executive-committee
).
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Thanasis Athanasopoulos-General Manager Group Compliance, Group Chief Compliance Officer
-
Year of birth: 1973
-
Nationality: Hellenic
-
Number of shares in Eurobank : 453,358
He is also a Member of the Executive Committee of Hellenic Bank Association. In the past, Mr. Athanasopoulos has served as Chief
Audit Executive of the Alpha Bank Group and Vice President - Audit & Risk Review of the Mellon Financial Corporation.
He holds a BSc, Business Administration from the Athens University of Economics and Business, a MSc, Banking from the University
of Reading, a MSc, Economic History from the London School of Economics and he is certified as a Fellow Chartered Accountant of
ICAEW, as a Fellow of the International Compliance Association and a Certified Director (IDP) by INSEAD.
Iakovos Giannaklis-Deputy Chief Executive Officer, Head of Retail & Digital Banking of Eurobank SA
-
Year of birth: 1971
-
Nationality: Hellenic
-
Number of shares in Eurobank: 319,606
He is also the Vice-Chairman in the Board of Directors of Worldline Merchant Acquiring Greece S.A. In the past, Mr. Giannaklis held
BoD positions in the following entities of Eurobank Group: Eurobank FPS Loans and Credits Claim Management SA (2018-2019),
Eurobank Household Lending Services SA (2016-2018), Eurobank Asset Management MFMC (2014-2017) and Eurobank Business
Services (2009-2017). He also held the following posts in Eurobank: Head of Retail Banking General Division (2016-2023), Head of
Branch Network General Division (2014-2016), Head of Branch Network Commercial Development Sector (2014), and Head of Branch
Network Sector (2009-2014).
He has also been a member of the BoDs of Eurolife FFH Group Holdings, General Insurance and Life Insurance (2021-2023). Mr
Giannaklis also served as Group Deputy General Manager, Retail and Digital, Growth and Transformation in Bank Muscat, Oman
(2023)
He holds an MBA from the University of Indianapolis, USA and a BA in Business Administration, from the City University of Seattle,
USA.
Eleftherios Economides - General Manager Group Risk Management, Group Chief Risk Officer (Group CRO), Eurobank SA
-
Year of birth: 1971
-
Nationality: Hellenic
-
Number of shares in Eurobank: 67,697
In the past, Mr. Economides has served within the Eurobank Group as General Manager, Group Chief Credit Officer (2016- March
2025), Head of Corporate Special Handling Sector (2013-2016), Head of Global Corporate Clients International (2008-2013), Senior
Manager of Debt Capital Markets, EFG Telesis Finance (2003-2008) and Wholesale Credit Audit Manager, Internal Audit Group (2000-
2003). In the past, Mr. Economides worked in Telesis Investment Bank in the position of Large Corporate Account Officer (1998-2000)
and in Price Waterhouse Coopers as Auditor/Consultant, (1996-1998).
He holds an MBA in International Banking and Finance from the University of Birmingham, a Degree in Business Administration from
the University of Macedonia, and he is a Fellow member of the Association of Chartered Certified Accountants (FCCA).
Tasos Ioannidis-General Manager Markets, Eurobank SA
-
Year of birth: 1968
-
Nationality: Hellenic
-
Number of shares in Eurobank Holdings: 322,833
In the past Mr. Ioannidis has served as General Manager, Head of Markets & Asset Management (July 2019 - June 2024), General
Manager, Head of Global Markets & Treasury (April 2015 - July 2019), Deputy General Manager, Head of Global Markets & Treasury
(October 2013 - March 2015), Deputy General Manager, Group Treasurer (April 2009 - October 2013), Deputy General Manager,
Group Head of Trading (March 2007 - April 2009). He has also served Member of the BoD, ERB Hellas PLC (August 2006 - June 2022),
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Member of the BoD, ERB Hellas Ltd (Cayman Islands) (August 2006 - December 2022), as Member of the BoD, Eurobank Asset
Management MFMC (May 2015 - September 2017), Chairman of the BoD, Eurobank ERB MFMC, former TT ELTA MFMC (February
2014 - September 2015), Member of the BoD, Global Asset Management SA (June 2006 - December 2009), and Member of the BoD,
Portfolio Investment SA (June 2002 - April 2003).
He holds a MSc in Shipping, Trade and Finance from Cass Business School, London, UK and a BSc, School of Mechanical Engineering
from the National Technical University of Athens.
Apostolos Kazakos-General Manager, Group Strategy, Eurobank SA
-
Year of birth: 1972
-
Nationality: Hellenic
-
Number of shares in Eurobank: 167,041
He serves also as a Non-Executive Director at doValue Greece Loans and Credits Claim Management Société Anonyme.
Mr. Kazakos has held several senior positions including Senior Executive and Head of Investment Banking at Eurobank Equities and
Telesis Bank (1998–2010), CEO of Eurobank Telesis Finance, Deputy CEO of Eurobank Equities (2010–2013), General Manager and
Head of Investment Banking, Restructuring & Capital Investment at General Bank, Piraeus Group (2013–2014), and Assistant General
Manager, Head of Group Strategy & Investor Relations at National Bank of Greece (2014–2015).
He earned an MSc in International Securities, Investment and Banking from the University of Reading (ISMA Centre), UK, and a degree
in Accounting from the International University of Greece.
Harris Kokologiannis-General Manager, Group Finance, Group Chief Financial Officer (Group CFO), Eurobank SA
-
Year of birth: 1967
-
Nationality: Hellenic
-
Number of shares in Eurobank: 180,940
Mr. Kokologiannis joined Eurobank in January 2008 as Head of Group Finance and Control until his appointment as Group CFO in July
2013.
He has served as Audit Supervisor, Deloitte (Tax, Audit, Management Consultant), Group CFO (Lafarge Cement - Heracles General
Cement Company), Director of Finance and Control (L’Oreal Hellas), Group Financial Manager (PLIAS Group).
He is a Chartered Accountant in UK, member of the Chartered Institute of Management Accountant (C.I.M.A.), UK. He holds an MBA
from the University of Warwick (UK) and a BA in Business Management and Organization from the School of Economics and Business
Science (ASOEE).
Michalis Louis-Chief Executive Officer (CEO) & Executive Board Member of Hellenic Bank Public Company Limited & Executive
Committee Member of Eurobank S.A.
-
Year of birth: 1962
-
Nationality: Cypriot
-
Number of shares in Eurobank: 435,648
Mr. Louis has also served as Head of International Activities General Division (2014-2024) & Group Private Banking (2019-2024), CEO
of Eurobank Cyprus Ltd (2007-2024), Member of the BoD of Eurobank Private Bank Luxembourg SA (2014-2024) and Member of the
Supervisory Board (SB) of Eurobank Bulgaria AD (2015-2024).
Additionally, he was a Member of various Committees within Eurobank Group and served on the Boards of multiple subsidiaries
abroad owned by Eurobank Group.
Earlier in his career, he held Senior Managerial roles at Laiki Bank of Cyprus and at an HSBC subsidiary in New York, specializing in
Corporate Finance.
He holds a B.A in Accounting Studies from Ealing College, London, and an M.Sc. in Corporate Finance & Accounting from the London
School of Economics.
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Natassa Paschali-General Manager, Group Human Resources General Division, (Group CHRO), Eurobank SA
-
Year of birth: 1972
-
Nationality: Greek
-
Number of shares in Eurobank: 145,643
Mrs. Paschali is the Group Chief Resources Officer (Group CHRO), since June 2018.In the past she has served within the Eurobank
Group as Head of People Engagement (January 2017 – June 2018), Head of HR, Eurobank Private Bank Luxembourg SA (parallel
assignment), Luxembourg (May 2014 – May 2017), Head of HR Line Management, Wholesale Banking (2008-2016). She also
held positions in Citigroup- Citibank International Plc as Head of HR – Vice President, Global Corporate and Investment Banking Group,
(July 2006 – June 2008) and Head of Training & Development – Assistant Vice President, Consumer Banking Group, (February 2004 –
July 2006).
She holds a MSc in Industrial Relations and Personnel Management from the London School of Economics and Political Science (1995-
1996) and a BA in English Language and Literature from the University of Athens, School of Philosophy (1991-1995).
Ioannis Serafeimidis-General Manager, Retail Banking Strategy & Growth, Chief Retail Growth Officer, Eurobank SA
-
Year of birth: 1973
-
Nationality: Hellenic
-
Number of shares in Eurobank:
329,090
Mr Serafeimidis is also a Non-Executive member of the BoDs in, Eurolife FFH Insurance Group Holdings SA (since July 2023), Eurolife
FFH Life Insurance SA (since July 2023) and Eurolife FFH General Insurance SA (since July 2023).
In the past Mr. Serafeimidis has served as Head of Retail Banking Channels, General Manager (2023-2024), Head of Branch Network,
General Manager (2019-2023), Executive Director and Head of Retail Banking, Postbank, Sofia (2014-2019), Head of Branch Network,
Postbank, Sofia (2011-2014), Senior Executive Manager and Head of Small Business Banking, Bancpost, Bucharest (2008-2011), as
well as other significant posts in Eurobank’s Branch Network, which he joined in 2002 after a 4 year incumbency in KPMG Management
Consulting in Athens.
He holds an MSc in International Relations from London School of Economics (UK) and a BSc in Economics from the University College
London (UK).
7.2.2
ExBo Permanent Attendees
Additional permanent attendees without voting rights may include pivotal roles subject to the CEO's discretion. Such roles include,
among others, the role of the Group Chief Audit Executive.
Spyridon Zarkos-Group Chief Audit Executive
-
Year of birth: 1967
-
Nationality: Hellenic
-
Number of shares in Eurobank: 210,923
Mr. Spyros G. Zarkos is Eurobank’s Group Chief Audit Executive since May 2024.
Prior to joining Eurobank, Mr. Zarkos has inter alia served as an external financial sector expert on risk -based supervision and crisis
management for the IMF, as Head of Supervision and Resolution at the EBA, as Director of Banking Supervision and as Director of
Private Insurance Supervision at the Bank of Greece, as Deputy and Group Chief Risk Officer in Geniki Bank and as senior economist
& macro-econometrician at the National Bank of Greece.
Mr. Zarkos holds a BA, MA and PhD in Economics, with specialization in the fields of monetary economics, international trade and
finance, econometrics. His early research interests were in the area of computational econometrics and macro-econometrics. He has
taught at undergraduate and graduate level in the US and in Greece.
7.2.3
ExBo Secretary
Mrs. Veronique Karalis, Deputy Group Company Secretary, serves as the Secretary of the ExBo and reports to the Group Company
Secretariat.
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7.2.4
ExBo Operations and Responsibilities
The ExBo manages the implementation of Group’s strategy in line with the Board’s guidance.
The ExBo meets on a weekly basis or ad hoc when necessary.
The ExBo achieves quorum when: 1. At least half its members plus one (fractions are excluded from the computation) are present,
with a minimum of three members in attendance. 2. Either the Chairperson or the longest-serving Deputy CEO (if chairing) is present.
Decisions are passed by majority vote. In the event of a tie, the Chairperson has the casting vote; if absent, the longest-serving Deputy
CEO has this authority.
The ExBo’s key tasks and responsibilities are to:
●
manage the implementation of the Group’s strategy, in line with the BoD’s guidance
●
draw up the annual budget and the business plan
●
approve issues concerning the Group’s strategic choices (e.g. partnerships, share capital increase, issuing convertibles and/or
launching debt issuance programs, mergers, acquisitions or disposals, the formation of joint ventures, creation or dissolution of
special purpose vehicles, dividend distribution and all other investments or non-material disinvestments by the Group etc.),
ensuring these being in line with the approved Group’s strategy, if the issue under discussion is less than or equal to €40 million.
In case though:
a.
the issue under discussion exceeds € 40 million,
b.
a decision of the Board is obligatory by Law or by the Bank’s contractual commitments,
c.
it is deemed necessary by the SPC, taking into account the complexity and nature of the strategic choices under discussion,
the issues concerning the Group’s strategic choices are approved by the Board following a relevant proposal by the SPC (as
per its Terms of Reference)
●
monitor the performance of each business unit and country against budget and ensure corrective measures are in place wherever
required
●
decide on all major Group’s initiatives aiming at transforming the business and operating model, enhancing the operating
efficiency and cost rationalization, improving organizational and business structure
●
ensure that adequate systems of internal controls are properly maintained
●
review and approve Bank’s Policies and other governance documents that are related to its responsibilities and/or are of critical
importance to the Bank,
●
review the performance of any Committee and /or individuals to whom it has delegated part of its responsibilities, as approved
●
ensure adequacy of Resolution Planning governance, processes and systems
●
ensure adequacy of Risk Data Aggregation and Risk Reporting (RDARR) implementation programs processes, remediation of
issues and progress monitoring.
●
hire and retain external consulting firms and approve their compensation and terms of engagement in accordance with Bank’s
policies and procedures
●
hire and retain investment banking advisors, and approve their compensation and terms of engagement, in accordance with
Bank’s policies and procedures, where applicable
The 2025 self-assessment confirmed the Executive Board’s consistently strong performance across its profile and composition, the
effectiveness of its organization and administration, and the execution of its key managerial and strategic responsibilities. The results
demonstrate a mature governance body with sustained operational discipline and strategic focus. The evaluation identified
opportunities for further enhancement, including continued prioritization of agenda focus, optimization of supporting materials,
strengthened monitoring of transformation initiatives, and more structured oversight of delegated responsibilities.
7.3
Strategic Planning Committee
The primary purpose of the SPC is to support Management in planning, developing, and implementing the Group’s strategy.
Additionally, the SPC is responsible for recommending certain strategic initiatives to the Board for consideration and approval.
9
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
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The key tasks and responsibilities of the SPC are:
●
To ensure that the Group establishes a well-defined, planned medium-term strategy aligned with the Board’s guidance and
the approved business plan.
●
To review the key objectives and goals within the framework established by the Executive Board’s annual budget and
business plan, as well as major business initiatives, prior to their submission for Board approval.
●
To review, analyze, and deliberate on issues concerning the Group’s strategic choices—such as strategic partnerships, capital
increases, issuance of convertible or debt instruments, mergers/demergers, acquisitions or disposals, joint ventures,
creation or dissolution of special purpose vehicles, dividend distributions, and other major investments or divestments—
ensuring alignment with the approved Group strategy. The SPC will formulate relevant proposals to the Board if:
a) The matter under discussion exceeds €40 million, while lower amounts are approved by the Executive Board.
b) A decision by the Board is required by law or by the Bank’s contractual commitments.
c) The SPC deems Board consideration necessary due to the complexity or nature of the strategic choices under
discussion.
●
To submit proposals to the Board for approval concerning the strategy and budget of the property portfolio, as outlined in
the Service Level Agreement between Eurobank and Grivalia Management Company.
●
To submit proposals to the Board for approval concerning the acquisition or disposal of assets, excluding repossessed assets
(as defined in the Service Level Agreement between Eurobank and Grivalia Management Company), with a book value
exceeding €10 million.
●
To submit proposals to the Board for approval regarding the disposal of repossessed assets, as defined in the Service Level
Agreement between Eurobank and Grivalia Management Company, with a gross book value exceeding €20 million.
●
To maintain and implement all necessary measures for regulatory and internal capital management, ensuring sufficient
coverage for all risk types, including strategic, reputational, and other non-quantifiable risks, to consistently meet capital
requirements.
●
To review and assess all major Group initiatives aimed at transforming the business and operating model.
●
To regularly monitor the Group's strategic and key performance indicators, including a segmental perspective.
●
To review and, when necessary, make recommendations to the Board on any other matters of strategic significance to the
Group.
The SPC meets on a weekly basis or ad hoc, when necessary.
The SPC is in quorum and meets validly when a) half of its members plus one are present (fractions are excluded from the
computation), provided that at least three members are present and b) SPC’s Chairperson or the longest serving Deputy CEO in
attendance, entitled to chair the Committee, is present.
Decisions are passed by majority vote. In case of a tie of votes, SPC’s Chairperson has the casting vote. If SPC’s Chairperson is absent,
the longest serving Deputy CEO in attendance, entitled to chair the Committee, has the casting vote.
The 2025 self-assessment confirmed the Strategic Planning Committee’s consistently strong performance across all core evaluation
areas, namely its profile and composition, the effectiveness of its organization and administration, and the discharge of its key
strategic tasks and responsibilities. The results reflect a well-balanced Committee with effective strategic oversight and sound
governance practices. The evaluation also identified opportunities for further enhancement, including continued strengthening of
submission discipline, further refinement of supporting materials, deeper integration of forward-looking capital and risk
considerations, and continued development of oversight over the Group’s real estate and property portfolio strategy.
7.4
Management Risk Committee
The main responsibility of the MRC is to oversee the risk management framework of Eurobank S.A. (“the Bank”). As part of its
responsibility, the MRC facilitates reporting to the BRC on the range of risk-related topics under its purview. The MRC proactively
supports the Group CRO to identify material risks, in addition to those identified independently by the Group CRO and the Group Risk
Management General Division, and to promptly escalate them to the BRC and assists the Group CRO in ensuring that the necessary
policies and procedures are in place to prudently manage risk and to comply with regulatory requirements.
10
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
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The MRC understands and evaluates risks, addresses issues, promotes the implementation of risk policies and informs the BRC of the
Group’s risk profile. Furthermore, the MRC assists the BRC in defining risk management principles and methodologies, thereby
ensuring that the Group’s risk management framework contains processes for identifying, measuring, monitoring, mitigating and
reporting the current risk profile against its risk appetite, limits and performance targets.
Specific responsibilities performed by the MRC are relevant to the following areas:
●
Alignment of Business Plan with Risk Appetite
●
Provisioning
●
Risk monitoring, reporting and remediation
●
Stress Testing Programme
●
Regulatory required Stress Tests (EBA / ECB)
●
Group ICAAP and ILAAP
●
Group Recovery Plan
●
Internal Model approval, results monitoring and reporting
●
BCBS 239 – Risk Data Aggregation and Risk Reporting (RDARR)
●
Resolution Planning
●
Reporting
●
Significant Risk Transfer (SRT)
The 2025 self-assessment confirmed the Management Risk Committee’s strong performance across its composition and expertise,
the effectiveness of its organizational framework, and the execution of its key risk oversight responsibilities. The results highlight the
Committee’s solid governance structure and effective contribution to the Bank’s risk management framework. The evaluation
identified opportunities for further enhancement in areas such as agenda management, meeting efficiency and continued
reinforcement of timely submission practices.
7.5
Group Asset and Liability Committee (G-ALCO)
G-ALCO’s primary mandate is to:
a) formulate, propose, approve, implement and monitor – as the case may be - the Group’s i) liquidity position and risk profile and its
funding strategies and policies ii) interest rate guidelines and interest rate risk profile and policies iii) Capital investments - as well as
FX exposure and hedging - strategy iv) Group’s business initiatives and/or investments that affect the bank’s capital, market and
liquidity risk profile. Further, to approve at a first stage, and recommend to BRC for final approval the respective country limits and
the relevant policy/methodology (special attention is given for the approval/monitoring of the limits for countries where Eurobank
has a local presence).
b) approve or propose – as the case may be - changes to these policies that conform to the Bank’s risk appetite and levels of exposure
as determined by the Board Risk Committee (and BoD as the case may be) and Management, while complying with the framework
established by regulatory/supervisory authorities.
G- ALCO responsibility is to also review the overall liquidity positions and developments of the Group on a country-by-country level.
In this context, international subsidiaries’ ALCOs should report on monthly basis material country developments and decisions
(reflected in respective country ALCO minutes) to G-ALCO, based on the above principles and their respective regulatory/supervisory
authorities’ instructions and guidelines.
The key tasks and responsibilities of G-ALCO are the following:
Regarding the approval of general policies and guidelines, compliance with regulatory requirements, review of activities/investments,
risks & exposures:
●
Formulate, propose and/or modify - as appropriate - guidelines and pricing policies for deposit and loan interest rates
for the Group, as well as review and approve business proposals for pricing loans and deposits.
●
Regularly review, adapt/modify - as may be required – and approve on an annual basis (or ad-hoc if needed) the Group’s
internal Funds Transfer Pricing (FTP) policies and FTP annual budget/business plan guidelines, in order to reflect current
market developments and business objectives. With regards to International Subsidiaries, local FTP policy is reviewed,
adapted/modified, approved by local ALCOs and presented for approval/acknowledgement to G-ALCO whenever it is
11
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
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deemed necessary.
●
Review International subsidiaries’ Capital investments, FX exposures and hedging strategies, and approve related
actions as may be required.
●
Review and approve the Market & Counterparty Risk policy and the relevant KRIs and the RAS framework for market
and counterparty risks before their submission to BRC/BoD.
●
Be informed of the MREL requirement and the MREL issuance plan following its approval by the BRC; review and
approve individual MREL instruments’ wholesale issuance and related costs in the context of the approved plan and
MREL targets. Similar intra-group requirements by International Subsidiaries are separately assessed when they arise.
●
Approve the liquidity-related resolution deliverables prior to their submission to the SRB/NRA.
●
Approve the implementation of MREL and liquidity options within the context of the Group’s Recovery Plan.
●
Review ERB/Group material market risks and exposures across investment portfolios (AC, FVOCI etc) and risk
dimensions (e.g., interest rate risk, liquidity/currency mismatch) as may be identified by Markets & and/or GMCRS, and
recommend actions as may be required.
●
Approve Markets’ new trading & investment activities for the bank’s own books (Trading, FVOCI, AC).
●
Review on annual basis country exposures/limits and sovereign exposure/limits (as per Sovereign Risk Policy); approve
new Country and/or Sovereign limits when proposed and modify existing Country and/or Sovereign limits as/when
appropriate. Any Country Limit increases approved by G-ALCO also require BRC approval. G-ALCO should allocate
country limits between exposures in state bonds/treasury bills and exposures in credit facilities to state controlled
entities.
●
Within the context of the approved investment framework for corporate/FI bond portfolio, review the relevant
portfolio limits annually. Review and approve (prior to Group’s formal commitment) business proposals for planned
soft underwriting commitments. Review and clear hard underwriting commitments; to note, these would also require
prior approval by the appropriate Credit Committees as per existing Credit policies.
Regarding Liquidity Risk
●
Within the scope of the Group’s Liquidity Risk Policy, i) monitor the implementation of the Asset Encumberance policy
and the execution of the Contingency Funding Plan process, as may be required, ii) establish, monitor, propose and
approve - as may be required - actions for the maintenance of adequate liquidity buffers in order to withstand liquidity
stress (or alternatively, adverse liquidity) events and comply (as possible) with regulatory requirements and internal
thresholds or targets.
●
Ensure that the Group Liquidity Risk policy is properly coordinated, integrated and updated – as may be required and
in compliance with the relevant regulatory framework, and market practices - across Group entities.
●
Review planned/projected liquidity profile and performance, monitor regulatory liquidity risk ratios (LCR, NSFR); review
wholesale funding strategies and initiatives, and approve related actions for the Bank/Group.
●
Report the Bank’s liquidity position, projections and risks, recommend actions related to liquidity risk management as
may be required to the Board Risk Committee (BRC) and BoD), and implement / monitor related BRC and/or BoD
decisions.
●
Review regulatory liquidity ratios, liquidity stress tests, and internal liquidity related warning indicators. Review material
liquidity risks; formulate, approve, and propose to MRC related stress test scenarios. Formulate and implement action
plans in case regulatory liquidity ratios and indicators’ evolution (and/or stress tests results) may so require, in the
context of the Group’s policies, risk appetite and regulatory framework.
●
Determine the appropriate KRIs and related framework for the monitoring of liquidity risk, approve the proposed KRIs
and framework before their submission to BRC and BoD.
●
Review and approve the periodic funding plan, including the funding plan which is prepared for the ILAAP/ ICAAP
exercise, and take its results into consideration in its decision making process as appropriate. Also, review and approve
the LCR restoration plan and the related funding plan, and any major changes to it.
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Regarding Interest Rate Risk in the Banking Book (IRRBB) and Credit Spread Risk in the Banking Book (CSRBB), G-ALCO (as delegated
by the BoD and BRC) has the overall responsibility for the monitoring and management of said risks, and clear authority over the units
responsible for taking such risks.
More specifically, G-ALCO’s tasks, authorities and responsibilities are to:
●
Formulate the Group’s IRRBB and CSRBB Policies’ framework and assumptions (e.g., models, stress scenarios etc.)
before its submission to BRC/BoD; review and approve the Group’s strategies for managing relevant risks
●
Review and approve the Group’s guidelines for the systems used for IRRBB and CSRBB monitoring and assessment;
further propose to BRC for final approval
●
Formulate the risk appetite and appropriate exposure limits (RAF thresholds) for the IRRBB and CSRBB; propose for
approval to BRC and BoD;
●
Establish a comprehensive IRRBB and CSRBB reporting and monitoring framework to regularly assess the IRRBB and
CSRBB exposure against the respective limits (as they are established); GMCRS is the responsible monitoring/reporting
unit
●
Ensure that adequate controls and procedures are in place, and appropriate management actions are triggered, when
set limits and early warnings levels are breached
●
Evaluate the performance, and impact, of risk management strategies applied to relevant exposures (interest rate,
credit risk) on EVE and NII in the context of the IRRBB/CSRBB Policy and Management targets
●
Approve the Economic Hedging Framework and propose its approval to BRC/BoD (also part of the IRRBB and CSRBB
Policy)
●
Define the high-level risk management strategy on a periodic basis - quarterly or ad hoc as may be required - in the
context of the Economic Hedging Framework (established to hedge the bank’s interest rate risk and credit risk exposures
on a portfolio basis). Further, to monitor and evaluate the outcome of hedging strategies, request their extension or
termination, escalate significant developments to BRC/BoD, monitor the RAF thresholds and the effect of hedging
strategies on the CAD ratio and Bank results.
●
Review and approve proposals to use new products, or engage in new activities - related to risk taking or hedging
strategies, prior to acquisition or implementation, to ensure that the resources required to establish sound and effective
IRRBB management of the product or activity have been identified, the proposed activities are in line with the
institution’s overall risk appetite and RAS, and that procedures to identify, measure, monitor and control the risks of
the proposed product or activity have been established. It should be ensured that the IRRBB characteristics of these
new products and activities are well understood.
●
Approve major hedging or risk-taking initiatives in advance of implementation. Ensure that positions related to internal
risk transfers between the non-trading book and the trading book are properly documented.
Key reports reviewed by G-ALCO:
●
Loans and Deposits evolutions (Greece and International)
●
Deposits Structure (Core, Time Deposits)
●
Deposit rates evolution (per business unit) and market share evolution (Greece)
●
LCR & NSFR evolution on a monthly basis (at a Solo and Group level)
●
FTP budget/business plan guidelines and funding cost
●
Sources and Uses of funds at Group/country level, secured funding report
●
Liquidity buffer analysis (Solo, Group, and per country).
●
Liquidity stress tests
●
Liquidity risk analysis/sensitivities
●
Interest Rate Gap report
●
Market risk analytics reports (PV01 in FVOCI and AC, VaR analysis, historical simulation results and reporting of the
relevant KRIs for MTM exposure in OCI & AC, evolution of RWAs for market risk, reports on the level of KRIs related to
market risk.
●
IRRBB reports: sensitivity of NII and sensitivity of EVE per regulatory framework (EBA IRRBB guideline) & per internal
framework
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●
Greek sovereign exposure report (internal and regulatory)
●
RWA movement report
●
Secured funding analysis report
●
Quarterly report on economic hedging positions
●
International subsidiaries’ liquidity buffers and regulatory ratios
●
International subsidiaries’ FX net investment hedging analysis
Annually / or more frequently if needed:
●
Internal or external auditors reports with reference to G-ALCO areas of responsibility.
●
Regulatory Reports with reference to G-ALCO areas of responsibility
G-ALCO convenes once a month or more frequently if required.
Required quorum for G-ALCO meetings to be effective is six members. In order to have a quorum the presence of its Chairperson and
a minimum of three (3) SPC members is required. Decisions on issues are to be taken by majority; in case of a tie vote, the issue
under discussion is escalated to ExBo. Additionally, under exceptional circumstances, decisions may be taken by circulation, which is
equal to a decision of the G-ALCO, even if no meeting has taken place. A relevant approval memo is then issued by the Secretary.
By the date of issuance of the 2025 Corporate Governance Statement, Committee’s self-evaluation for 2025 was in progress. The last
Committee’s self-evaluation that was extended to include 2024 for completeness, determined that: i) G-ALCO members’ composition
and engagement is well appropriate, and the committee’s performance is well satisfactory ii) the Committee continues to function
effectively in relation to its mandate and responsibilities, with members actively engaging in critical discussions during meetings, with
special focus on topics regarding key risk and regulatory/supervisory issues iii) in light of the complexity and importance of issues
arising, the continued evolution of the regulatory framework and complexity, and the emergence of additional risk
considerations/requirements or activities, G-ALCO should continue to improve its organizational and operational efficiency and
further increase the scheduled frequency, and/or length of meetings (as possible), as may be required to remain as effective. Said
action had been implemented for the 2025 scheduled meetings plan.
7.6
Central Credit Committees
7.6.1
Central Credit Committee I
The main objective of Central Credit Committee I (CCCI) is to ensure the objective credit underwriting of relevant exposures of Greek
corporate performing and private banking clients, in accordance to the Risk Appetite Framework and the Credit Policy Manual of the
Bank and in a way that balances credit risk and return on equity. The CCCI is chaired by an independent to Business and Risk
Professional, convenes at least once a week and all meetings are minuted. Decisions are taken unanimously. If unanimity is not
achieved, the credit request is escalated by the Chairperson to the next (higher) approval level requiring a unanimous decision. In
case of non-unanimity the final decision lies with the Management Risk Committee (MRC), by majority voting.
The main duty and responsibility of the CCCI is to assess and approve all credit requests for clients in the Greek related corporate
performing and private banking portfolio of a total exposure above €50mio and unsecured exposure above €35mio. For total exposure
exceeding €75mio and unsecured exposure exceeding €50mio, additional approval by the GCRO is required, while for total exposure
exceeding €150mio and unsecured exposure exceeding €100mio, additional approval by the CEO is required. Furthermore, for
exposures higher than 10% (or 20% for selected borrowers where no single risk exists) of the Bank’s regulatory capital the additional
approval of the Management Risk Committee (MRC) is required. Subsequently, the final approval is granted by the Board Risk
Committee (BRC).
7.6.2
Central Credit Committee II
The main objective of the Central Credit Committee II (CCCII) is the same as for the CCCI for lower levels of exposure.
The CCCII convenes at least once a week and all meetings are minuted. Decisions are taken unanimously. If unanimity is not achieved,
the request is escalated by the Chairperson to the next approval level.
12
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
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The main duty and responsibility of CCCII is to assess and approve all credit requests for clients in the Greek related corporate
performing and private banking portfolio for total exposure from €20mio up to €50mio and unsecured exposure from €10mio up to
€35mio and retail exposures for total limits above €3mio.
By the date of issuance of the 2025 Corporate Governance Statement, Committee’s self -evaluation for 2025 was in progress.
7.7
Troubled Assets Committee
The Troubled Assets Committee (TAC) is established according to the regulatory provisions. The main purpose of TAC is to act as an
independent oversight body, closely monitoring the Bank’s troubled assets portfolio and the execution of its NPE Management
Strategy.
The Committee meets at least once per month and/or whenever required if the majority of the members, including the Chairperson,
are present. Decisions are taken by majority, are minuted and circulated as appropriate. The Chairman has a casting vote.
TAC cooperates with Group Risk Management to reach a mutual understanding and develop an appropriate methodology for the
evaluation of the risks inherent in the portfolio management. TAC’s propositions regarding NPE policy updates are submitted to the
Board Risk Committee. In exceptional circumstances, decisions may be taken by circulation.
TAC’s main responsibilities are to:
●
review internal reports regarding troubled assets management under the regulatory provisions,
●
approve the available forbearance, resolution and closure solutions by loan sub-portfolio, and monitor their
performance through Key Performance Indicators (KPIs),
●
define the criteria to assess the sustainability of credit and collateral workout solutions through the design and use of
“decision trees”,
●
approve, monitor and assess pilot modification programmes and
●
supervise and provide guidance and know-how to the respective troubled assets units of Eurobank’s subsidiaries
abroad.
By the date of issuance of the 2025 Corporate Governance Statement, Committee’s self-evaluation for 2025 was in progress. For 2024
the evaluation concluded that the committee operates effectively, in the areas of Profile and Composition, Organization &
Administration as well as regarding the Key Tasks and Responsibilities. However the evaluation also identified that while the overall
quality and quantity of information submitted related to the proposals for assessment by the TAC members is adequate, there is
room for further enhancement on providing more details on the quantification of the impact through monitoring (i.e. through KPIs)
of implemented solutions, products and targets set as well as indicating the monitoring frequency of all new remedial/work -out
proposals. Such enhancements will benefit TAC members make more informed decisions.
7.8
Products & Services Committee (PSC)
The Products & Services Committee (PSC) is responsible for developing and supervising the governance framework for the products
and services offered to Eurobank’s clients in Greece through the physical and alternative channels, in accordance with the supervisory
and regulatory requirements. Risk culture is embedded in the Group’s product governance. A dedicated policy is in place to address
risks associated with the introduction, significant modifications, and periodic monitoring of products and services. The Group operates
a robust governance framework throughout the product and service lifecycle, where material financial and non-financial risks are
assessed by the relevant Group Risk Management units and other Second Line of Defence functions.The products and services of
Remedial & Servicing Strategy are excluded and are under the responsibility of TAC (Troubled Assets Committee).
PSC convenes once a month and/or whenever required.
The PSC is in quorum and meets validly when half of its members plus one are present (fractions are excluded from the computation).
For quorum, the Chairperson or the Vice-Chairperson (in case of Chairperson’s absence) should be also present.
Decisions require, as a minimum, a majority vote of 50%+1 of the members present in the meeting and are recorded in the meeting’s
minutes. In case of a tie vote, the Chairperson or the Vice-Chairperson (in case of Chairperson’s absence) has the casting vote. All
members of the PSC have equal voting rights. In case of no reaching a decision due to disagreement of Members, the issue under
discussion is escalated to the Executive Board (ExBo).
13
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
14
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Additionally, decisions may be taken by circulation, which is equal to a decision of the Committee, even if no meeting has preceded.
No resolution can be deemed for high risks products/services by circulation. They will be submitted to a PSC Meeting for discussion
and approval or rejection.
By the date of issuance of the 2025 Corporate Governance Statement, Committee’s self-evaluation for 2025 was in progress.
According to the Committee’s 2024 self -evaluation, its performance was assessed as very strong, it functions very efficiently,
contributes to the enhancement of the Bank’s governance framework, and its Members demonstrate a high level of commitment and
dedication.
7.9
Sustainability Management Committee (SMC)
The primary mandate of the SMC is to provide strategic direction on sustainability initiatives, review the Sustainability Strategy, Net
Zero targets and transition plans prior to approval, ensure that the elements of the Sustainability Strategy and the Net Zero
commitments are integrated into the Group’s business model and operations, approve changes in eligible assets of Green Bond and
Sustainable Finance Frameworks, regularly measure and analyze the progress of the Sustainability Strategy goals and performance
targets and ensure the proper implementation of sustainability-related policies and procedures, in accordance with supervisory
requirements and voluntary commitments.
SMC convenes four times a year and/or ad hoc when necessary. Other Bank employees, depending on the subject to be discussed,
may be invited as deemed appropriate.
Required quorum for SMC meetings to be effective is when 2/3 of its members. For quorum, the Chairperson should be also present.
In case of Chairperson absence, the Sustainability Management Committee will be chaired by the Group Senior Sustainability Officer,
following relevant previous written acknowledgement to all committee members. In determining the number of members for the
quorum, fractions, if any, shall not be counted. Decisions on issues are taken by majority. In case of a tie vote, the Chairperson has
the casting vote, and if s/he is absent the Group Senior Sustainability Officer (as his substitute) has the casting vote. Whenever a
decision of the SMC is not reached unanimously, this is recorded in the minutes along with the opinion of the minority. All meetings
and decisions are minuted by the Committee’s Secretary and distributed to SMC members.
According to the 2025 self-assessment conducted by the Sustainability Management Committee indicates overall satisfaction among
its members regarding the Committee’s structure, leadership, preparedness, and effectiveness. Members highlighted the quality of
discussions and the Committee’s effective oversight of sustainability strategy, Net Zero commitments, sustainability-related risks,
policies, and regulatory reporting obligations, including CSRD-related matters. The evaluation also identified opportunities for further
enhancement, particularly regarding sustainability training initiatives and the continued integration of sustainability considerations
into remuneration and incentive frameworks. Overall, the assessment confirms that the Committee operates effectively and in line
with applicable regulatory requirements and corporate governance best practices.
7.10 Ethics Co
The task of the Ethics Committee is to ensure that the Eurobank Group’s Code of Conduct & Ethics as well as the Bank’s Statute of
Internal Service is observed, to interpret and constantly enrich it, as well as to contribute, generally, to the formulation of a code of
values with which the behaviour of the officers and personnel of Eurobank, as well as that of third persons that regularly collaborate
with the Bank, must comply. Adherence to the rules of ethics contributes, on the one hand, to the protection of dignity and personality
of the personnel, and on the other hand, to the good reputation and the protection of the interests of the Bank.
The Ethics Committee convenes once a month, if there are issues to be discussed or, exceptionally, more frequently, in case of an
emergency, in a place and time that are stated in the agenda. The Ethics Committee may convene either with the physical presence
of its members, or by electronic means. The Committee shall act unanimously.
Ethics Committee’s performance has been evaluated twice (in February 2023 and in March 2025) and in both occasions has been
determined that it functions effectively.
8
Key Control Functions
As part of its overall system of internal controls, the Bank has established a number of dedicated control functions. These functions
operate as independent control mechanisms designed to strengthen and reinforce the control environment of the Bank.
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During the period of its operation and until 12 December 2025,a Eurobank Holdings also maintained dedicated control functions
aimed at strengthening its control environment.
The most important functions of the Bank and Eurobank Holdings and their key responsibilities are described below.
8.1
Internal Audit
8.1.1
Eurobank
Group Internal Audit (Group IA) is an independent, objective assurance and consulting function designed to add value and improve
the operations of Eurobank. Its Primary Role is to strengthen Eurobank and its subsidiaries (“Eurobank Group” or “Group”) ability to
create, protect, and sustain value by providing the board and management with independent, risk-based, and objective assurance,
advice, insight, and foresight. This is achieved by providing assurance on the adequacy and operational effectiveness of internal
control and risk mitigation systems established by management in order to address inherent risks associated with businesses carried
out and operations.
In order to achieve its objectives in an efficient manner, Group IA consists of seven units, with the heads reporting to the Chief Audit
Executive (CAE):
●
Group Technology Audit & Next-Gen Audit Lab,
●
Strategy, Credit & Business Audit,
●
Sustainability, Markets, Finance and Operations Audit,
●
Forensic Audit (FA),
●
International Audit (INTA),
●
Quality Assurance, Methodology & Training, and
●
Reporting, Monitoring and Support (RMS).
Additionally:
●
The International subsidiaries’ Internal Audit Heads report to CAE and to the respective local ACs.
●
The Head of Branch Network Operational Risk Control, maintains a secondary line of reference to the CAE for the work
related to On-Site Branch Inspections of Retail & Digital Operational Risk Management.
Group IA enhances Eurobank’s: a) Successful achievement of its objectives, b) Governance, risk management, and control processes,
c) Decision-making and oversight, d) Reputation and credibility with its stakeholders and e) Ability to serve the public interest.
Within Eurobank’s organisational structure, Group IA is Independent of Bank units with operational responsibilities.
In order to safeguard its independence, the Group IA reports functionally to the Audit Committee and administratively (for example,
day-to-day operations) to the CEO. Group IA is headed by the Group Chief Audit Executive (CAE) who has the responsibility to report
on the activities of Group IA to the Audit Committee and arrange periodic private meetings with the Audit Committee. The Audit
Committee appoints or dismisses the CAE, assesses periodically his/her performance, soliciting the CEO’s views whenever deemed
necessary/value-adding, and recommends his/her remuneration for approval by the Remuneration Committee.
The key assurance and advisory/consulting responsibilities of Group IA are to:
●
provide reasonable assurance, in the form of an independent opinion, as to the adequacy and effectiveness of the
governance, risk and internal control framework of Eurobank and adherence to the risk appetite framework. In order to
form an opinion, Group IA establishes and carries out a programme of audit work (based on the risk assessment of the audit
universe). Group IA follows a risk -based approach in planning and conducting its work. Group IA carries out continuous
monitoring of the Eurobank’s risk profile. This provides key input to the formal risk-assessment that forms the basis for the
preparation of the Annual Audit Plan.
●
assist Management in enhancing the system of internal controls including improvement of existing policies and procedures
●
manage effectively the internal audit process and resources of both Group IA and the Internal Audit departments of
subsidiaries that are reporting directly to Group IA and assess the performance of the Group’s internal audit functions, which
have a direct reporting line
●
follow-up to ascertain that appropriate action is taken on reported audit findings with agreed deadlines
●
attends the Audit Committee meetings in order to present a summary of its activity and highlight key issues at least on a
quarterly basis
●
attend Shareholders’ General Meetings
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●
provide any information requested in writing by the Supervisory Authorities and co-operate with them in order to facilitate
their work. The Audit Committee and/or Management shall always be advised regarding information provided to the
Authorities
●
carry out any other specific duties required by the Regulatory Authorities and/or participate in bank wide projects
undertaken by the Bank
●
participate in Bank projects in an assurance or consulting capacity
●
liaise with the Legal Services and Group Human Resources and provide support to the Ethics and Operational Risk Legal
Cases Committees
●
liaise with the external auditors and other assurance providers to share information, minimise any duplication of effort and
ensure adequate coverage of risks
●
Strive to maintain an open, constructive and cooperative relationship with the Supervisors
●
assess the adequacy and effectiveness of the control functions (such as risk management, compliance or finance) and
involving judgment determine to what extent it is appropriate to take account of the relevant work undertaken by these
functions
Internal Audit (IA) is an independent, objective assurance and consulting function designed to add value and improve the operations
of Eurobank Holdings. IA has adequate organisation structure and appropriate resources to ensure that it can fulfil its roles and
responsibilities.
Eurobank’s Group Internal Audit (Group IA) maintains a quality assurance and improvement programme to ensure that the
methodology is applied consistently and the objectives and responsibilities of Group IA are met. Under the framework of co-operation
between IA and Group IA, IA assigns the assessment of the effectiveness of internal audit activities and conformance with IIA
Standards to Group IA.
In order to safeguard its independence, IA reports functionally to the Audit Committee and administratively to the CEO. The Board
has delegated the responsibility for monitoring the activity of the IA to the Audit Committee of the HoldCo. IA is headed by the Chief
Internal Auditor (CIA) who is appointed by the Audit Committee. The latter also assesses the CIA’s performance.
The mission of IA is to enhance and protect organisational value by providing risk-based and objective assurance, advice and insight.
The key assurance and consulting responsibilities of IA are to:
●
provide reasonable assurance in the form of an independent opinion, as to the adequacy and effectiveness of the
governance and risk and internal control framework of HoldCo and adherence to the risk appetite framework. In order to
form an opinion, IAU establishes and carries out a programme of audit work (based on the risk assessment of the audit
universe)
●
assist management in enhancing the system of internal control including improvement of existing policies and procedures
●
manage effectively the internal audit process and resources of IA
●
provide any information requested in writing by the Supervisory Authorities and co-operate with them in order to facilitate
their work. The AC and/or Management shall always be advised regarding information provided to the Authorities
●
carry out any other specific duties required by the Regulatory Authorities and/or participate in projects undertaken by the
Company
●
participate in Company’s projects in an assurance or consulting capacity
●
liaise with the external auditors and other assurance providers to share information, minimise any duplication of effort and
ensure adequate coverage of risks
●
assess the adequacy and effectiveness of the control functions (such as risk management, compliance or finance) and
involving judgment determine to what extent it is appropriate to take account of the relevant work undertaken by these
functions
●
strive to maintain an open, constructive and cooperative relationship with the Supervisors.
8.1.2
Eurobank Holdings
During the period of its operation and until 12 December 2025, Internal Audit of Eurobank Holdings (IA) was an independent, objective
assurance and consulting function designed to add value and improve the operations of Eurobank Holdings. IA had adequate
organisation structure and appropriate resources to ensure that it can fulfil its roles and responsibilities.
Eurobank’s Group Internal Audit (Group IA) maintained a quality assurance and improvement programme to ensure that the
methodology was applied consistently and the objectives and responsibilities of Group IA were met. Under the framework of co-
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operation between IA and Group IA, IA assigned the assessment of the effectiveness of internal audit activities and conformance with
IIA Standards to Group IA.
In order to safeguard its independence, IA was reporting functionally to the Audit Committee and administratively to the CEO. The
Board had delegated the responsibility for monitoring the activity of the IA to the Audit Committee of the HoldCo. IA was headed by
the Chief Internal Auditor (CIA) who was appointed by the Audit Committee. The latter was also assessing the CIA’s performance.
The mission of IA was to enhance and protect organisational value by providing risk-based and objective assurance, advice and insight.
The key assurance and consulting responsibilities of IA were to:
●
provide reasonable assurance in the form of an independent opinion, as to the adequacy and effectiveness of the
governance and risk and internal controls framework of HoldCo and adherence to the risk appetite framework. In order to
form an opinion, IA had established and carried out a programme of audit work (based on the risk assessment of the audit
universe)
●
assist management in enhancing the system of internal control including improvement of existing policies and procedures
●
manage effectively the internal audit process and resources of IA
●
follow up to ascertain that appropriate action is taken on reported audit findings within agreed deadlines
●
attend Shareholders’ General Meetings
●
provide any information requested in writing by the Supervisory Authorities and co-operate with them in order to facilitate
their work. The AC and/or Management was always advised regarding information provided to the Authorities
●
carry out any other specific duties required by the Regulatory Authorities and/or participate in projects undertaken by the
Company
●
participate in Company’s projects in an assurance or consulting capacity
●
liaise with the external auditors and other assurance providers to share information, minimise any duplication of effort and
ensure adequate coverage of risks
●
assess the adequacy and effectiveness of the control functions (such as risk management, compliance or finance) and
involving judgment determine to what extent it was appropriate to take account of the relevant work of these functions
●
strive to maintain an open, constructive and cooperative relationship with the Supervisors.
8.2
Risk Management
8.2.1
Eurobank
The Group Risk Management, which is headed by the Group Chief Risk Officer (GCRO), operates independently from the business
units and is responsible for the identification, assessment, monitoring and measurement of the risks the Bank is exposed to. The
major types of risk managed by Eurobank are the material risks, identified through the Risk Identification and Materiality Assessment
(RIMA) process and listed in the relevant RIMA report.
Material risk types include financial and non-financial risks, indicatively credit risk, market risk, liquidity risk, interest rate risk and
credit spread risk in the banking book, operational risk, sustainability risk, country risk, reputational risks, conduct risk, risks stemming
from strategic projects.
The Group Risk Management comprises the Group Credit, the Group Credit Control, the Group Credit Risk Capital Adequacy Control,
the Group Market & Counterparty Risk, the Group Operational and Non-financial Risks, the Group Model & Data Validation, the Group
Risk Management Strategy & Oversight, the Sustainability Risk, the Risk Analytics and the Supervisory Relations & Resolution
Planning
.
The GCRO serves as a pivotal point for the risk management functions. Centralization ensures that business targets and related growth
are combined with a risk conscious perspective, thus ensuring that the approved risk appetite is adhered to.
The GCRO develops and formalises the Risk Appetite Framework (RAF), defines the Risk Appetite Statements (RAS), and submits them
to the Board Risk Committee for approval. The GCRO oversees the implementation of the frameworks and policies for the
identification, measurement and management of risks.
The GCRO reviews and approves the risk policies before their submission for approval to the BRC or to the BoD and oversees their
implementation thereafter. The GCRO reports to the BRC deviations from the risk policies or potential conflict with the approved risk
strategy and risk appetite.
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The GCRO is responsible to provide to the BRC adequate information, so that the Committee can properly assess and advise the BoD
on the Group’s risk exposures / profile and risk strategy. The GCRO oversees compliance with approved Risk Appetite limits, a
nd
reports to the BRC the compliance status and any deviations, as stipulated in the Risk Appetite Framework (RAF).
Risk culture is a foundational element of the Group’s operations, encompassing the norms, attitudes, and behaviors that guide risk
awareness, risk-taking, and risk management. The Group is committed to fostering a robust risk culture that supports proactive
identification, assessment, and mitigation of both financial and non-financial risks. The Risk Management function provides a
comprehensive framework, procedures, and guidance to empower employees across all levels to manage risks effectively within their
areas of responsibility. This includes ongoing education, communication, and awareness initiatives such as dedicated learning
programs, monthly meetings, and the sharing of best practices. A strong risk culture is reinforced by the Group’s Board of Directors
and Senior Management, who set the appropriate “Tone from the Top” to align risk practices with strategic objectives.
Eurobank has a well -established strategy and clear risk management objectives that has to deliver through core risk management
processes and methodologies. At a strategic level, the risk management objectives are to:
●
identify the new risks relevant to the Group and assess their materiality
●
assess the current and emerging risks as an integral part of the strategic planning process
●
provide opinion for the Group Business Plan regarding the risk perspective on the overall outcome and reliability of the Plan
●
ensure that business plan is consistent with Eurobank’s risk appetite
●
participate actively in decision-making processes to ensure that risk considerations are considered appropriately
●
optimize risk/return decisions, while establishing strong and independent review
●
ensure that business growth plans are properly supported by effective risk infrastructure
●
manage risk profile to ensure that specific financial deliverables remain possible under a range of adverse business
conditions
●
assist senior executives to improve the control and co-ordination of risk taking across their business
●
cultivate a robust risk culture throughout the Bank, encouraging a positive attitude towards risk management, regulatory
compliance and the internal control framework, through strong risk awareness and ownership, where all staff members
consider risk management as an integral part of their everyday responsibilities
●
provide the framework, procedures and guidance to enable all employees to manage risk in their own areas and improve
the control and co-ordination of risk taking across the Bank
●
advise and support Eurobank Holdings in risk management according to the agreed Service Level Agreement (SLA) between
Eurobank Holdings and Eurobank.
Risk Management along with Compliance and other Units are involved in the assessment of all products and services throughout their
lifecycle.
The Group applies the elements of the Three Lines of Defence Model for the management of risk. The Three Lines of Defence Model
enhances risk management and control by clarifying roles and responsibilities within the organization. Under the oversight and
direction of the Management Body, three separate lines of defence are necessary for effective risk management. In particular:
-
Line 1 - Own and manage risk and controls. The front-line business and operations are accountable for this responsibility as
they own the rewards and are the primary risk generators.
-
Line 2 - Monitor risk and controls in support of Executive Management, providing oversight, challenge, advice and group-
wide direction. These include the Risk Management and Compliance Units, among others.
-
Line 3 - Provide independent assurance to the Board and Executive Management concerning the effectiveness of risk and
control management. This refers to Internal Audit.
8.2.2
Eurobank Holdings
As part of its overall system of internal controls HoldCo had engaged in a Service Level Agreement (SLA) with Eurobank in order to
receive supporting and advisory services in all areas of risk management (credit, market, liquidity and operational risks) undertaken
by the Group.
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The most important services that were provided to Eurobank Holdings until 12 December 2025, through the above-mentioned SLA
are described below:
●
provision of advice on:
-
Identification, evaluation and monitoring of credit risk,
-
Ensuring policy and instructions (strategy and products) recommended by business owners and Servicers were aligned
to applicable credit policy manual and regulatory guidelines,
-
Standardization of procedures and guidelines,
-
Update and maintenance of the risk strategic framework master document,
-
Participation in systemic bank consultation committees,
-
Review new remedial products and initiatives prior submission to TAC or approval
●
coordination of NPE related regulatory reporting
●
provision of input for SSM submission and 3-year business plan, monthly MIS actual data (including Greek and International
subsidiaries)
●
advising on identification, support/advise, recording and evaluation of liquidity risks and financial monitoring
●
advising in the identification, assessment, recording and monitoring of operational risks (e.g. RCSA, events capture,
outsourcing etc.)
8.3
Compliance
8.3.1
Eurobank
Group Compliance is established with the approval of the Board of Directors and the Audit Committee of Eurobank. It is a permanent
function and independent from the Bank’s business activities so that conflicts of interests are avoided. In order to safeguard its
independence, Group Compliance reports functionally to the Board of Directors through Audit Committee of the Bank and for
administrative purposes to the CEO. The Audit Committee in consultation with the NomCo proposes to the Board for approval the
appointment, replacement or dismissal of the Group Chief Compliance Officer (Group CCO). The performance of the Group CCO is
assessed on an annual basis by the AC. The Group CCO attends all Audit Committee’s meetings and submits quarterly and annual
reports (per regulatory requirements) summarising Group Compliance’s activity and highlighting the main compliance issues.
Its mission is to promote, within Eurobank and its subsidiaries (Eurobank group), an organizational culture that encourages ethical
conduct through integrity and a commitment to compliance with laws and regulations as well as the application of international
governance standards.
The main objective of Group Compliance is to ensure that the Eurobank group has established an adequate system of internal controls
that allows it to operate in accordance with the ethical set of values contained in its “Code of Conduct and Ethics” and in compliance
with applicable laws, regulations and internal policies, as well as international best practices. In brief, for the regulatory topics within
its scope of responsibilities, Group Compliance is mandated to:
●
raise compliance awareness throughout the Eurobank group,
●
provide advice to the Board of Directors and Senior Management on compliance with applicable laws, rules and standards
and keep them informed of related developments,
●
issue policies, procedures and other documents such as compliance manuals, internal codes of conduct & ethics and practice
guidelines in order to provide guidance to staff on the appropriate implementation of applicable laws, rules and standards
as well as to assist the business to develop and implement regulatory compliant policies and procedures,
●
review new activities and advise on potential compliance risks,
●
ensure that staff is adequately trained and frequently updated about compliance issues by designing training programs and
co-operating with HR for their implementation,
●
ensure the development of a robust compliance risk identification and assessment framework, provide support and
challenge, if required, the business line management regarding the effectiveness of the compliance risk management
activities,
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●
coordinate compliance risk management actions performed by other business units,
●
monitor and test whether staff applies effectively the internal processes and procedures aimed at achieving regulatory
compliance and report to the relevant Business Units any potential breaches in order for the latter to proceed with the
required improvements,
●
monitor staff adherence to internal policies and the "Code of Conduct and Ethics" and identify potential breaches or
fraudulent activity,
●
monitor timely submission of reports to Competent Authorities and report any delays and fines for any alleged breaches of
regulations to the AC,
●
fulfil any statutory responsibilities and liaise with regulators and external bodies on compliance issues,
●
supervise, monitor, coordinate and evaluate the activities of the Compliance Officers of the Bank’s local and international
subsidiaries in order to ensure compliance with Eurobank group standards.
The scope of activities of Group Compliance covers the following core regulatory topics:
●
Financial Crime including laws and regulations on Anti Money Laundering (AML) and Countering the Financing of Terrorism
(CFT) and legislation aimed at combatting Tax evasion such as FATCA and CRS (tax compliance). The scope includes the
provision of timely and accurate responses to requests arising from regulatory and judicial authorities for the lifting of
banking secrecy or freezing of assets and co-operation with them. Financial Crime also includes anti-bribery and anti-
corruption legislation. The Eurobank Audit Committee in consultation with the Eurobank NomCo proposes to the Board for
approval the appointment, replacement, or dismissal of the Anti-Money Laundering Reporting Officer of Eurobank, who may
be the same person as the Group CCO, and his/her Deputy
●
Conduct related regulations, including:
o
market Conduct related regulation regarding the provision of investment products and services to clients including laws
and regulations on Market Manipulation, Insider Trading, Unlawful disclosure of inside information and other financial
crimes,
o
Internal Conduct and Ethics, including monitoring adherence with the Group Code of Conduct and Ethics and its related
policies, Conflicts of Interest, insider dealing and managing the Ethics Hotline
o
customer conduct laws and regulations (including, inter alia, dormant accounts legislation, BoG’s Code of Conduct for
loans, the Payment Services Directive and the Deposit Guarantee scheme).
●
Outsourcing and third-party risk regulations
Group Compliance has an overlay role over the regulatory framework concerning personal data protection, corporate governance,
prudential regulation (credit market, liquidity and operational risk), information & IT security, cyber security risk, artificial intelligence
and Sustainability Framework. In this context Group Compliance performs a high-level monitoring through compliance risk
assessments and monitoring of the alignment of the Bank’s activities with regulatory requirements.
The scope of activities can be expanded with the approval of the AC.
8.3.2
Eurobank Holdings
Eurobank Holdings Compliance was established with the approval of the Board of Directors and the Audit Committee of Eurobank
Holdings and operated until 12 December 2025. It was a permanent function and independent from Eurobank Holdings’ business
activities so that conflicts of interests were avoided. In order to safeguard its independence, Eurobank Holdings Compliance was
reporting functionally to the Audit Committee of Eurobank Holdings and for administrative purposes to the CEO
. The Audit
Committee in consultation with the NomCo, was proposing to the Board for approval the appointment, replacement or dismissal of
the Head of Eurobank Holdings Compliance. The performance of the Head of Eurobank Holdings Compliance was assessed on an
annual basis by the AC. The Head of Compliance was attending all AC meetings and was submiting quarterly and annually reports (per
regulatory requirements) summarizing Compliance’s activity and highlighting the main compliance issues.
Its mission was to promote, within Eurobank Holdings, an organizational culture that encouraged ethical conduct, and a commitment
to compliance with laws and regulations as well as global governance standards.
The main objective of Eurobank Holdings Compliance was to ensure that Eurobank Holdings had established an adequate system of
internal controls that allowed it to operate in accordance with the ethical set of values contained in its "Code of Conduct and Ethics"
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and in compliance with applicable laws, regulations and internal policies. More specifically, for the regulatory topics within its scope
of responsibilities, Eurobank Holdings Compliance was mandated to:
●
raise compliance awareness in Eurobank Holdings
●
provide advice the Board of Directors and Senior Management on Eurobank Holdings compliance with applicable laws, rules
and standards and keeping them informed of related developments
●
issue, as necessary, policies and other documents, in order to provide guidance to staff on the appropriate implementation
of applicable laws, rules and standards as well as to assist the business to develop and implement regulatory compliant
policies and procedures
●
review new activities and advise on potential compliance risks
●
ensure that staff is adequately trained about compliance issues
●
provide support and challenge, if required, the business line management regarding the effectiveness of the compliance risk
management activities
●
monitor whether staff applies effectively the internal processes and procedures aimed at achieving regulatory compliance
●
monitor through appropriate procedures staff adherence to internal policies and the "Code of Conduct and Ethics" and
identify fraudulent activity
●
monitor timely submission of reports to Competent Authorities and report any delays and fines for any alleged breaches of
regulations to the AC
●
fulfil any statutory responsibilities and liaise with regulators and external bodies on compliance issues.
8.4
Personal Data Protection
8.4.1
Eurobank
Personal Data Protection Unit assists the Data Protection Officer (DPO) in performing his duties in an independent manner. Key tasks
include:
●
issues relevant guidelines on GDPR requirements and provides relevant advice to involved Units,
●
provides advice, where requested, for the appropriate technical and organizational measures to be implemented to ensure
compliance with the principles of privacy by design and privacy by default,
●
provides advice regarding the content of privacy notices,
●
provides advice on the appropriate handling of the GDPR requests and/or complaints,
●
upon request, provides advice regarding the categorization of the third parties, in accordance with the GDPR and any other
applicable data protection legislation (controller/ joint controller/processor/ sub-processor), and the relevant privacy terms
to be signed,
●
provides advice to the Incident Management Team on whether the incident must be reported to the data protection
authority,
●
provides advice, where requested, as regards the performance of Data Protection Impact Assessments,
provides advice where requested as regards the maintenance of the Register of Processing Activity.
8.4.2
Eurobank Holdings
In the context of Personal Data Protection, Eurobank Holdings had entrusted the following functions to the Bank’s Personal Data
Protection Unit with the support of Legal was needed:
●
consultation and advice regarding the drafting of privacy notices for the customers, employees, shareholders of the HoldCo
and/ or persons with voting rights and their representatives in the HoldCo meetings and committees,
●
provision of drafts of privacy policies, cookies policies and cookies management tool for the HoldCo's website,
●
provision of advice in handling requests and complaints of data subjects,
●
provision of advice for incident and data breach management and notifications to the competent authority, if was required,
●
provision of advice on GDPR policies and related guidelines.
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9
System of Internal Controls
9.1
Principles of Internal Controls
The Group has established a robust System of Internal Controls that aligns with international best practices and utilizes COSO
terminology. This system is designed to provide reasonable assurance regarding the achievement of objectives in key categories:
●
Efficient and Effective Operations: The Group's internal controls ensure that operations are conducted efficiently and
effectively, promoting productivity and optimal resource utilization.
●
Reliability and Completeness of Financial and Management Information: Internal controls are in place to ensure that
financial and management information is reliable, accurate, and complete. This helps in making informed decisions and
maintaining transparency.
●
Compliance with Applicable Laws and Regulations: The Group emphasizes compliance with all relevant laws, regulations,
and industry standards. Internal controls are designed to ensure adherence to legal requirements and mitigate regulatory
risks.
The key principles that underpin the Group’s System of Internal Controls are as follows:
●
Control Environment: The control environment serves as the foundation for all internal control components. It includes
factors such as management's integrity and ethical values, recruitment and training policies, organizational structure, and
delegation of authority. These elements contribute to a strong control consciousness among employees.
●
Risk Management: The Group recognizes the importance of risk management in its operations. It implements mechanisms
to identify, assess, and manage risks that may impact the achievement of objectives. The risk management framework is
dynamic and evolves to address new and emerging risks.
●
Control Activities: Internal control activities are documented in policies and procedures that ensure safe operations and
accurate record-keeping. Segregation of duties is a crucial organizational measure to enhance control effectiveness, ensuring
that key functions such as approval, dealing, administration, and controlling are separated.
●
Information and Communication: Effective information and communication channels are established to ensure that relevant
information is identified, captured, and communicated in a timely manner. This includes internal communication within the
organization and external communication with stakeholders such as regulators, shareholders, and customers.
●
Monitoring: The Group conducts ongoing monitoring of activities as part of its operations. This includes regular management
and supervisory activities, internal audits, and independent evaluations of the internal control system. Internal control
deficiencies are reported and escalated as necessary, with major issues reported to top management, the Audit Committee,
and the Board.
Additionally, the efficiency of the internal control system is independently evaluated every three years by a third-party auditing firm,
in accordance with regulatory requirements. The evaluation report is assessed by competent bodies within the Group and submitted
to regulatory authorities for review and acknowledgment.
9.2
Characteristics of the System of Internal Controls (SIC)
Eurobank have established key characteristics of its System of Internal Controls (SIC), which are indicative and not restrictive. These
characteristics include:
●
Code of Conduct: There is a defined Code of Conduct along with processes for monitoring its implementation to ensure
ethical conduct and adherence to standards.
●
Organizational Chart: An approved organizational chart is in place, depicting the hierarchy and functions of each
sector/department clearly defined to ensure effective management.
●
Audit Committee: The composition and function of the Audit Committee are outlined to oversee financial reporting and
compliance.
●
Strategic Planning: A description of strategic planning processes is provided, including development, implementation, and
periodic evaluation of strategic objectives.
●
Action Plans: Long-term and short-term action plans for important activities are established, with periodic reports and
identification of deviations along with justifications.
●
Articles of Association: The Articles of Association are complete and up-to-date, reflecting the objectives and operations of
the entity.
●
Directorates and Departments: Tasks of directorates, departments, and job descriptions are defined to ensure clarity in roles
and responsibilities.
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●
Policies and Procedures: Policies and procedures for important operations are documented, including internal controls for
risk management.
●
Compliance Processes: Processes for compliance with legal and regulatory frameworks are established to ensure adherence
to laws and regulations.
●
Risk Assessment and Management: Processes for risk assessment and management are in place to identify and mitigate risks
effectively.
●
Financial Information Integrity: Processes ensure the integrity and reliability of financial information through accurate
reporting and controls.
●
Executive Performance Evaluation: Processes for recruitment, training, delegation, targeting, and evaluation of executive
performance are outlined.
●
Information Systems Security: Processes for the security, adequacy, and reliability of information systems are established to
safeguard data.
●
Personnel and Asset Protection: Processes are in place to safeguard personnel and assets, ensuring security and protection.
●
Reporting and Communication: Reporting lines and communication channels within and outside the organization are
described for effective information flow.
●
Monitoring and Evaluation: Mechanisms are established for monitoring and evaluating the efficiency and effectiveness of
processes regularly.
●
Independent Evaluation: There is a process for periodic evaluation of the adequacy and efficiency of the SIC by an
independent auditor to ensure objectivity.
●
Environmental Policies: Policies for environmental management and other ESG factors are recorded to address sustainability
and social responsibility.
●
These policies and procedures are part of the corporate governance system's assessment and are regularly reviewed and
updated to align with best practices and regulatory requirements.
These policies and procedures are part of the corporate governance system's assessment and are regularly reviewed and updated to
align with best practices and regulatory requirements.
It is noted that throughout its operation and until 12 December 2025, HoldCo had adopted the key characteristics mentioned above.
9.3
Evaluation of the System of Internal Controls
The Bank's AC is responsible for annually reviewing and evaluating the adequacy of the Internal Control System (ICS) of both the Bank
and its subsidiaries. This evaluation is based on data and information provided by the Group Internal Audit (IA) of the Bank, external
auditors' findings and remarks, as well as feedback from supervisory authorities. The AC utilizes oversight and reporting mechanisms
established with the Audit Committees of the Bank's Subsidiaries to ensure a comprehensive assessment.
Similarly, until 12 December 2025, the HoldCo's AC was tasked with reviewing and evaluating the adequacy of the Internal Control
System (ICS) of the HoldCo itself. This evaluation was conducted based on relevant data and information from the Internal Audit (IA)
of the HoldCo, findings and remarks from external auditors, and feedback from supervisory authorities. The AC ensured a thorough
assessment of the HoldCo's ICS to uphold standards of governance and compliance.
9.4
Independent Evaluation of the HoldCo/Bank System of Internal Controls
In March 2024, Grant Thornton presented the scope, findings, and methodology of their Independent triennial Evaluation of the
HoldCoand Bank System of Internal Controls (SIC) to the HoldCo/Bank AC members, as per the Bank of Greece Act 2577/9.3.2006
(BoG Act) that was in force at that time.
Based on the procedures conducted and the evidence gathered, there were no indications that the SIC, at the time of assessment,
was not compliant in all material aspects with the requirements of the BoG Act.
Grant Thornton identified 21 observations during their assessment, categorized as 16 low-risk observations and 5 medium-risk
observation related to the IT issues in Eurobank Equities, and 7 recommendations for improvement. Management will take
appropriate actions in response to these observations.
9.5
Corporate Governance System Assessment in accordance with article 4 par. 1 of Law 4706/2020
In compliance with Article 4, Paragraph 1 of Law 4706/2020 (the Law), the Bank Boards of Directors (BoD) is responsible for
designating and overseeing the implementation of the corporate governance system (CGS) as outlined in Articles 1 to 24 of the Law.
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Additionally, the BoD must monitor and evaluate the application and effectiveness of the CGS at least every three (3) financial years,
taking necessary actions to address any deficiencies.
Given that the Law came into force on 17.7.2021, the Hellenic Capital Market Commission (HCMC) specified that the maximum
reporting period for the first CGS review should extend from 17.7.2021 to 31.12.2024. It also required that the 2024 Corporat
e
Governance Statement include a relevant reference to this review.
The above requirements were also applicable to HoldCo for the period of its operation until 12 December 2025.
In this context, on 24 February 2025, the HoldCo and Bank NomCos reviewed the CGS for the reporting period and updated the
HoldCo and Bank BoDs accordingly. The review concluded that HoldCo and Bank have taken all necessary actions to fully comply with
the Law, as no gaps were identified.
Furthermore, in line with supporting work related to the Corporate Governance Framework, performed both by external parties and
internally, HoldCo and Bank have taken proactive measures to exceed the Law’s provisions, enhancing their processes and practices
for more efficient governance. In this regard, HoldCo and Bank have effectively addressed identified issues and implemented
recommendations for improvement provided by external parties, including regulators and external advisors.
10
Sustainability
10.1
Sustainability Approach
Eurobank supports the transition towards a sustainable economy and considers sustainability and climate change as an opportunity.
A key strategic objective is to adapt the business and operation in a way that addresses climate change challenges, accommodates
social needs within its business model and safeguards prudent governance for itself and its counterparties, in accordance with
supervisory initiatives, and following international standards and best practice.
To this end, Eurobank has designed, approved and is currently implementing its Sustainability Strategy, including targets and
commitments, along with the two key pillars: Operational Impact Strategy (OIS) and Financed Impact Strategy (FIS), both of which
aim to address sustainability matters within the context of the Group’s business model and operations.
A.
Operational Impact Strategy (OIS):
The
Operational Impact Strategy
are sustainable, and aligning its operations with climate and sustainability goals. The key elements of this strategy are:
●
Environmental Impact:
a clear goal of achieving climate neutrality.
●
Societal Impact:
development and prosperity for the benefit of society.
●
Governance & Business Impact:
intensifying Eurobank's efforts for ethics and transparency.
The OIS is supported by a governance structure of multiple project streams (one per each commitment) and the supervisory ESG/OIS
Committee. Progress is regularly reviewed at the Sustainability Management Committee. Each project stream is planned with
milestones, KPIs, annual targets and long-term interim targets, serving the declared commitments, spanning over the next decade.
Links are established with Transformation streams as well as corresponding ISO Management System standards, to ensure
substantiation and certification of activities, validate target setting and measured performance, and systematically monitor progress
through internal reviews and external assurance.
B.
Financed Impact Strategy:
The
Financed Impact Strategy
financing activities, with a commitment to sustainability and responsible stewardship. To achieve this objective, the Financed Impact
Strategy is structured around the following 4 strategic pillars:
●
Client Engagement and Awareness:
climate change challenges and opportunities.
●
Supporting Clients in Transition:
solutions, that are guided by the financing approaches and the eligible activities of the Sustainable Finance Framework. goals
and ambitions.
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●
Enablers and Tools for Sustainable Financing:
●
Assessment and Management of sustainability-Related Risks:
within its loan and investment portfolios, including assessing exposure to transition and physical risks linked to climate
change.
The Financed Impact Strategy supports Eurobank's commitment to sustainable financing and ensuring that the Group’s financial
activities align with sustainability goals, such as reducing the carbon footprint of financed projects.
Main Challenges Ahead:
Both strategies face several challenges:
●
Operational Transition:
associated costs and risks. This involves transforming internal processes and aligning with evolving applicable regulatory
requirements and voluntary initiatives as well as adopted standards and guidelines enabling Eurobank’s contemporary and
continuously updated approach towards Sustainability, in line with international best practice.
●
Client Transition:
This may involve addressing different levels of maturity, overcoming resistance to change, and navigating and aligning to
complex regulatory requirements.
●
Sustainability-related Risks:
and physical risks (e.g., climate change impacts such as extreme weather) that could affect both the Group’s own operations
and the sectors in which it invests or lends to is dependent on data availability and commitment of involved counterparties
and stakeholders
●
Alignment with Global Standards:
disclosures (such as TCFD), and managing the increasing demand for transparency in sustainability reporting.
To overcome these challenges, Eurobank has implemented a series of strategic initiatives:
●
Operational Impact Strategy (OIS) key components:
o
Operational efficiency:
achieve Net Zero in its operations for Scope 1 & 2 by 2033 and Scope 3 by 2050. Promotion of environmental
stewardship by accelerating also transition towards a paperless banking network and preservation of natural
resources, as well as extending circular economy practices. Accommodation of social needs within its business
model and safeguarding prudent governance for itself and its counterparties, in accordance with supervisory
initiatives, and following international standards and best practice.
o
The OIS is supported by a governance structure of project streams per each commitment and the supervisory
ESG/OIS Committee. Regular review of progress via milestones and KPIs to ensure annual and long-term
sustainability goals related to Environmental, Societal, and Governance & Business Impact are met. Progress is
regularly reviewed at the Sustainability Management Committee.
●
Financed Impact Strategy (FIS) key components:
o
Sustainable Financing:
through sustainable financing.
o
Portfolio alignment:
with the 1.5°C climate transition scenario.
o
Net zero strategy:
setting up to 2050.
In line with its commitment to address climate change, the Group joined the Net-Zero Banking Alliance (NZBA), a bank-led, UN-
convened alliance of banks worldwide, reinforcing its dedication to aligning its lending and investment portfolios with net-zero
emissions by 2050 or sooner, in line with the most ambitious targets set by the Paris Climate Agreement.
The Group has developed sectoral, financed emissions reduction targets based on the NZBA framework, for some of the most carbon-
intensive and, therefore, most relevant and impactful sectors and portfolios. The Group applies established industry standards (e.g.
NZBA, PCAF) and accredited science-based decarbonisation scenarios, in line with a 1.5-degree Celsius objective by 2050.
While the Sustainability Strategy described above remains the formally approved and applicable strategic framework during the 2025
reporting period, Eurobank has, in parallel, initiated a structured process to review and update its Group Sustainability Strategy. The
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objective of this process is to build on the existing strategy, further strengthen its effectiveness and embed sustainability more deeply
across the Group’s operations, decision-making and business activities. In this context, the update of the Group Sustainability Strategy
has been developed through a structured and comprehensive, Group-wide process, aimed at strengthening the contribution of
sustainability to long-term value creation. This process includes research, benchmarking, and re-alignment on sustainability mega-
trends and regulatory developments to redefine the key sustainability topics based on assessment of the Group’s strategic priorities
and performance, and consideration of stakeholder expectations and leading market practices.
This work enables a more focused articulation of the Group’s sustainability strategic direction and leads to the identification and
prioritisation of strategic drivers and focus areas designed to enhance value creation, notably through supporting business growth,
strengthening risk management and improving operational efficiency across the Group.
Subsequent phases will focus on translating this strategic direction into defined targets, KPIs and detailed action plans, supported by
appropriate governance and monitoring frameworks, following formal approval of the updated Group Sustainability Strategy.
10.2
Sustainability Policies & Frameworks
Eurobank has taken action towards updating its Sustainability Policy Framework, to outline the approach for adherence to applicable
regulatory requirements and voluntary initiatives as well as adopted standards and guidelines enabling its contemporary and
continuously updated approach towards Sustainability, in line with international best practices. The Sustainability Policy Framework
sets the foundation towards integration of sustainability into Eurobank’s business model and operations.
Focusing on the social aspect of Sustainability, Eurobank has taken actions that outline its corporate values, principles and
commitments by issuing the Human Rights Statement, the Diversity, Equity and Inclusion Policy as well as the Policy against
Harassment and Violence in Workplace. In order to further enhance its efforts against Harassment and Violence in Workplace, the
Bank has introduced a relevant focused training program to all employees. This approach outlines zero-tolerance for various types of
violation and discrimination as well as for the equal opportunities with fairness and meritocracy and irrespective of gender,
nationality, age or other traits throughout the entire employee life cycle (i.e. recruitment and selection, learning, performance, talent
and career development, reward management).
Moreover, Eurobank has developed and implements three guiding frameworks, defining the approach and criteria for classifying its
financing and investing activities as sustainable:
●
its Sustainable Finance Framework (SFF), which supports the identification of sustainable/green financing opportunities and
provides a clear and comprehensive methodology for classifying, monitoring and reporting sustainable financing,
●
its Green Bond Framework. The Framework, which has been externally reviewed by an established second-party opinion
provider, facilitates the financing of projects that will deliver environmental benefits to the economy and support Bank’s
business strategy and vision,
●
its Sustainable Investment Framework, which describes the Bank’s potential sustainable investment approaches/strategies
and the process for selection of eligible investments, based on criteria observed in international market practices,
frameworks and guidelines.
The above-mentioned frameworks enable the Bank to pursue economic growth in line with sustainable criteria.
These frameworks are complemented by the adopted Environmental Policy, Energy Management Policy and Water Management
Policy, aiming to protect the environment in all aspects of its operations. In line with these policies, the Bank applies certified
management systems, in accordance with international standards, such as an Environmental Management System (ISO 14001, EMAS)
and an Energy Management System (ISO 50001).
Eurobank has taken action towards updating its Sustainability Policy Framework, to outline the approach for adherence to applicable
regulatory requirements and voluntary initiatives as well as adopted standards and guidelines, thus enabling a contemporary and
continuously updated approach towards Sustainability, in line with international best practice. The Sustainability Policy Framework
sets the foundation towards the integration of Sustainability principles into Eurobank’s business model and operations.
Focusing on the social aspect of Sustainability, Eurobank has taken actions that outline its corporate values, principles and
commitments by issuing the Human Rights Statement, the Diversity, Equity and Inclusion Policy as well as the Policy against
Harassment and Violence in Workplace. In order to further enhance its efforts against Harassment and Violence in Workplace, the
Bank has introduced a relevant focused training program to all employees. This approach outlines zero-tolerance for various types of
violation and discrimination as well as for the equal opportunities with fairness and meritocracy and irrespective of gender,
nationality, age or other traits throughout the entire employee life cycle (i.e. recruitment and selection, learning, performance, talent
and career development, reward management).
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Moreover, Eurobank has developed and implements three guiding frameworks, defining the approach and criteria for classifying its
financing and investing activities as sustainable:
●
its Sustainable Finance Framework (SFF), which supports the identification of sustainable/green financing opportunities and
provides a clear and comprehensive methodology for classifying, monitoring and reporting sustainable financing.
●
its Green Bond Framework. The Framework, which has been externally reviewed by an established second-party opinion
provider, facilitates the financing of projects that will deliver environmental benefits to the economy and support Bank’s
business strategy and vision,
●
its Sustainable Investment Framework, which describes the Bank’s potential sustainable investment approaches/strategies
and the process for selection of eligible investments, based on criteria observed in international market practices,
frameworks and guidelines.
The above-mentioned frameworks enable the Bank to pursue economic growth in line with sustainable criteria.
These frameworks are complemented by the adopted Environmental Policy, Energy Management Policy and Water Management
Policy, aiming to protect the environment in all aspects of its operations. In line with these policies, the Bank applies certified
management systems, in accordance with international standards, such as an Environmental Management System (ISO 14001, EMAS)
and an Energy Management System (ISO 50001).
10.3
Stakeholders engagement and double materiality assessment
An integral part of the Group's approach to sustainability is to foster strong relationships of trust, cooperation and mutual benefit
with all stakeholders affected by its activities, directly or indirectly. In this context, the Group promotes two-way communication and
develops ongoing dialogue with stakeholders, to be able to actively meet the expectations, concerns and issues raised by all its
stakeholders. A more detailed presentation of the cooperation framework, expectations and means of communication is included in
the Group’s Sustainability Statement for the year 2024.
Acknowledging the importance of double materiality, Eurobank conducted a comprehensive assessment to identify the most
significant sustainability issues for its business and stakeholders, following the evaluation of sustainability impacts from its activities,
and the assessment of risks and opportunities with financial influence across its value chain. This process included stakeholder
consultations and was guided by the European Sustainability Reporting Standards (ESRS). The Group’s double materiality assessment
is the process that shapes the contents of the Sustainability Statement and the Annual Report 2024 – Business & Sustainability. The
Double Materiality Assessment is conducted on an annual basis. The methodology was carried out in 4 phases, namely i.
Understanding of the business value chain and related activities, ii. Stakeholder engagement and identification of impacts, risks and
opportunities (IROs), iii. Assessment of IROs, and iv. Material topics. As per the final stage of the double materiality and as informed
by the results of the impact and financial materiality assessment process, a list of topics was prioritized as material, which in turn
formed the basis for determining the contents of the Annual Report 2024 – Business & Sustainability, as well as the disclosures of
relevant key performance indicators. Further details regarding the aforementioned process and its results are embedded in the
Group’s Sustainability Statement for the year 2024 and the Annual Report 2024 – Business & Sustainability.
Governance
Sustainability at Eurobank is deployed across a Governance structure that addresses both regulatory requirements and voluntary
sustainability commitments. Board oversight with respect to the Sustainability Strategy is addressed through the inclusion of
dedicated sustainability items in the Board Meetings agenda, as per international best practice. The Group applies the elements of
the Three Lines of Defense (3LoD) model for the management of climate-related, environmental and sustainability risks. The 3LoD
model enhances risk management and control by clarifying responsibilities within the organization. Eurobank’s Sustainability
Governance model supports the integration of its Sustainability Strategy and sustainability risks. Additionally, the Group Senior
Sustainability Officer (GSSO) plays a key role in leading and coordinating the Group’s sustainability initiatives, reporting directly to the
senior management and Board for sustainability matters and the Group Sustainability Coordination Office serves as the Secretary of
the Sustainability Management Committee.
In that context, the Group Sustainability Risk (GSR) is responsible for managing and monitoring sustainability risks, including preparing
and maintaining the Bank’s sustainability risks methodologies, performing the identification and materiality assessment process of
sustainability risks, supporting, reviewing, and challenging the involved stakeholders, across the Group, regarding the setting of the
Net Zero targets and of the Sustainability Strategy and monitoring of their implementation thereof. Moreover, the Board has assigned
an executive member as the Board Member responsible for climate-related and environmental risks. This member provides updates
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to the Board Risk Committee (BRC) at least semi-annually. As outlined in its Terms of Reference, the BRC is responsible for overseeing
(among others) sustainability issues, including sustainability risks.
A dedicated Sustainability Management Committee (SMC) complements the Sustainability Governance model. The SMC provides
strategic direction on sustainability initiatives, reviews the Sustainability Strategy, Net Zero targets and transition plans prior to
approval, ensures that the elements of the Sustainability Strategy and the Net Zero commitments are integrated into the Group’s
business model and operations, approves changes in eligible assets of Green Bond and Sustainable Finance Frameworks, regularly
measures and analyzes the progress of the Sustainability Strategy goals and performance targets and ensures the proper
implementation of sustainability-related policies and procedures, in accordance with supervisory requirements and voluntary
commitments.
A dedicated Group Sustainability Unit (GSU) is responsible for managing and coordinating sustainability strategy related issues, for
the development of action plans for the Group's Net Zero portfolio strategies, as well as for monitoring sustainability performance
and coordinating sustainability-linked activities that enhance the Group’s Impact. In this context, the Unit is responsible for facilitating
the development of the Sustainability data framework to coordinate and prepare external and internal sustainability-related reports.
10.4
Reporting and Transparency
In 2024, the Group began preparing its first Group Sustainability Statement in accordance with the Corporate Sustainability Reporting
Directive (CSRD), which was published in the first quarter of 2025. Under the Directive (EU) 2022/2464 and the Delegated Directive
(EU) 2023/2775 as in force, which were transposed into the Greek legislation pursuant to Law 5164/2024 as in force, the Sustainability
Statement for the year 2024 is an integral part of the Directors’ Report and provides the necessary information to understand the
impact of the Group’s activities on sustainability, as well as the impact of sustainability on the progress, performance and position of
the Group.
The Group leveraged the extended disclosures provided in the Sustainability Statement, incorporating references to the Annual
Report 2024 – Business & Sustainability. Bank issues its Annual Report – Business & Sustainability with a view to fully inform its
stakeholders about its performance in the sustainable development pillars: economy, society, and environment. The publication is
prepared in accordance with the Global Reporting Initiative (GRI) Standards (2021), applying the principles of accuracy, balance,
clarity, comparability, completeness, sustainability context, timeliness and verifiability. This approach ensures comprehensive and
transparent information, addresses stakeholders’ expectations and interests, and promotes ongoing dialogue with them. Through
the Report, Eurobank provides full disclosure on sustainability impacts such as environmental performance, energy and emissions,
social impact and corporate governance, information regarding the Group’s initiatives, while addressing all material stakeholder
interests across the sustai nability spectrum. The Annual Report - Business & Sustainability is accessible to all interested parties
through the corporate website. Additionally, besides the sustainability reporting frameworks of the GRI sectoral supplement on
Financial Services, the SASB Commercial Banks Standard, as well as the Athens Stock Exchange (ATHEX) ESG Reporting Guide (2024)
have been considered, while the double materiality assessment was conducted in accordance with the ESRS standards. This report
also incorporates the 10 Principles of the United Nations Global Compact (UNGC), as well as the Accountability AA1000 2018
Principles. The sustainability -related disclosures in the report are assured by a competent assurance provider in accordance with
International Standard on Assurance Engagements (ISAE) 3000 (Revised), Assurance Engagements Other Than Audits or Reviews of
Historical Financial Information, issued by the International Auditing and Assurance Standards Board (IAASB), as per the independent
auditor’s Limited Assuranc e Report which is disclosed as part of the Annual Report – Business & Sustainability. In addition, the
Eurobank reports disclosures as required by the EU Taxonomy Regulation. Specifically, upon reviewing its business activities, to align
taxonomy reporting with its core activities, provides the key performance indicators (KPIs) and other disclosure requirements related
to its dominant financial undertakings as laid down in Article 10 of the Art. 8 Delegated Act. Furthermore, in the context of Pillar III
disclosures on ESG risks, Eurobank discloses ESG risks information on a semi -annual basis. Also, the Bank's GHG financed emissions
for loans, bonds and shares positions and CRE investments, following the PCAF methodology, are disclosed in the Group’s
Sustainability Statement as at 31 December 2024.
Furthermore, the Bank’s environmental and energy management performance, with respect to the improvement of its operational
footprint, is monitored through specific indicators and associated targets disclosed also in the Environmental Report (EMAS). This
constitutes an environment and energy monitoring and self-improvement tool, in line with commitments, regulated by applicable
standards, audited & verified by independent third party. Within the EMAS Report framework, the Bank discloses the Green House
Gas emissions record in line with the ISO 14064 standard, as verified by external independent party and in line with the provisions of
the national Climate Law.
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Moreover, the Bank actively participates in internationally recognized Sustainability ratings to highlight the continuous improvement
in its environmental, social and governance performance, upgrade the relevant disclosures, and further enhance investor confidence
in its practices.
11
Other information required by Directive 2004/25/EU
The elements c), d), f), h), and i) of paragraph 1, Article 10 of Directive 2004/25/EC of the European Parliament and the Council have
been incorporated into elements c), d), e), g), and h) of Article 4, Paragraph 7 of Law 3556/2007. These elements are included and
referenced in the Report of the Directors, of which the present Corporate Governance Statement forms an integral part.
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SUSTAINABILITY STATEMENT
Index to the Sustainability Statement .......................................................................................................Page
1. General information
1.1 Basis for preparation ..........................................................................................................................115
1.2 Disclosures in relation to specific circumstances................................................................................115
1.3 Governance.........................................................................................................................................115
1.4 Strategy - Company, business model and stakeholder engagement..................................................125
1.5 Materiality analysis and results according to the concept of double materiality...............................137
2. Environmental information
2.1 Disclosures under Article 8 of Regulation (EU) 2020/852..................................................................141
2.2 Climate change ...................................................................................................................................145
2.3 Biodiversity and ecosystems...............................................................................................................180
2.4 Integration of sustainability in risk management ...............................................................................183
2.5 Sustainable financing and investment offerings.................................................................................190
3. Social information
3.1 Own workforce ...................................................................................................................................200
3.2 Consumers and end-users ..................................................................................................................226
3.3 Fostering innovation ...........................................................................................................................244
4. Governance information
4.1 Business conduct ................................................................................................................................255
4.2 Data security and customer privacy ...................................................................................................264
Appendices
A.
Disclosure requirements in ESRS covered by the undertaking’s sustainability statement [IRO-2] ....270
B.
Disclosures under Article 8 of Regulation (EU) 2020/852...................................................................285
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1 General Information
1.1 Basis for Preparation
General basis for preparation of sustainability statements [BP-1]
This sustainability statement for the fiscal year ended 31 December 2025, has been prepared on a consolidated basis.
The scope of the statement covers the same scope of consolidation as the Financial Statements.
For the purposes of this sustainability statement , the following general information applies: On 12 December 2025, the merger by
absorption of “Eurobank Ergasias Services and Holdings S.A.” (Eurobank Holdings) by Eurobank S.A. (Eurobank or the Bank) was
completed and Eurobank SA became the ultimate parent company of the Group. In accordance with ESRS 2.5(d), the Group has not
exercised the option to omit information relating to intellectual property, know-how, or innovation results in this Sustainability
Statement. Unless otherwise stated, the metrics disclosed in this Sustainability Statement have not been validated by an external
body other than the statutory assurance provider.
This sustainability statement covers the upstream and downstream value chain to the following extent: The upstream value chain
includes key suppliers such as those providing IT hardware, office supplies, energy, and capital, as well as the regulatory and voluntary
frameworks provided by bodies like the European Central Bank (ECB), the European Banking Authority (EBA), and the Single
Resolution Board (SRB). The downstream value chain includes Eurobank's corporate and retail clients who benefit from financing,
investment banking, advisory services, and leasing solutions.
The value chain has been considered in the materiality assessment to identify material impacts, risks, and opportunities by evaluating
the key activities and stakeholders in both the upstream and downstream segments, including the environmental and social impacts
of suppliers and customers. Moreover, Eurobank’s policies, actions, and targets extend to Eurobank’s value chain such as suppliers,
corporate and retail clients, ensuring sustainability considerations are integrated into decision-making processes for financing, capital
markets, and real estate. Finally, when disclosing metrics, upstream data on supplier performance and downstream data related to
customer engagement in sustainable financing has been considered along with assessments of Sustainability risks tied to both the
upstream and downstream sectors. In addition to core banking activities, the value chain also encompasses insurance services,
including those provided by CNP, which are included within the consolidated scope of the Sustainability Statement and have been
considered in the materiality assessment, although they are not presented as a separate value chain segment due to their lower
materiality.
1.2 Disclosures in relation to specific circumstances [BP-2].
Eurobank has adopted the following time-horizons as defined in ESRS 1: 6.4 Definition of short-, medium- and long-term for reporting
purposes:
●
for the short-term time horizon: the period adopted by the undertaking as the reporting period in its financial statements.
●
for the medium-term time horizon: from the end of the short-term reporting period defined above up to 5 years; and
●
for the long-term time horizon: more than 5 years.
1.3
Governance
1.3.1
The role of the administrative, management and supervisory bodies [ESRS 2 GOV-1]
Board of Directors and Board Committees - Eurobank Holdings (up to 12.12.2025) and Eurobank
Eurobank Holding’s / Eurobank’s Board of Directors (BoD) is comprised of 3 executive members, and 9 non-executive members. The
members of the Board of Directors and relevant Committees possess experience relevant to the sectors, products and geographic
locations: As presented in section Composition of the Board of Corporate Governance Statement, Eurobank Holding’s and Eurobank’s
Board is comprised of 3 female board members, and 9 male board members (average ratio of female to male board members, 33%).
Eurobank aims to ensure that at least 25% (rounded to the previous integer) of the Board is composed of members of the less
represented gender, with a target to increase this representation to a minimum of 33% (rounded to the nearest integer) as soon as
practicable, and in any case no later than mid-2026. This target aligns with legal and regulatory requirements and industry’s best
practices and shall be maintained at all times, reflecting evolving legal frameworks and market trends.
For a Board of Directors comprising 12 members, (as in the case of Holdings and the Bank BoDs) a minimum target of 25% this
corresponds to 3 female members. Currently, Eurobank is compliant with this requirement, as its Board includes 3 female members:
Ms. Rena Rouvitha Panou, Ms. Cinzia Basile, and Ms. Alice Gregoriadi.
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Moreover, 58,3% of the total BoD members are independent. The executive BoD members are representing the employees of the
Group in the Board of Directors.
For more information relating to the BoD please refer to the Corporate Governance Statement in the Board of Directors section.
Sustainability Governance
Eurobank has established the Sustainability Management Committee (Sustainability ManCo - SMC). The purpose of the Sustainability
ManCo is to:
●
provide strategic direction on sustainability initiatives,
●
review the Sustainability Strategy, Net Zero targets and transition plans prior to approval,
●
ensure that the elements of the Sustainability Strategy and the Net Zero commitments are integrated into the Group’s
business model & operations,
●
approve changes in eligible assets of Green Bond and Sustainable Finance Frameworks,
●
regularly measure and analyse the progress of the Sustainability Strategy goals and performance targets,
●
ensure the proper implementation of sustainability-related policies and procedures, in accordance with supervisory
requirements and voluntary commitments.
The Committee includes senior management roles such as the Deputy CEO, Group Chief Operating Officer (COO) & International
Activities , Deputy CEO, Head of Corporate & Investment Banking, Deputy CEO, Head of Retail & Digital Banking, Group Chief Ri
sk
Officer, Head of Group Strategy (Chairperson), Group Senior Sustainability Officer, Group Chief Financial Officer, Group Chief HR
Officer and several other senior leaders from Legal Services, Strategy, Markets, Strategic Development & Monitoring for International
Activities & Group Private Banking, Compliance, and Marketing & Corporate Communications Group units. The Group Senior
Sustainability Officer (GSSO) plays a key role in leading and coordinating the Group’s sustainability initiatives, reporting directly to
senior management and the Board for sustainability matters and the Group Sustainability Coordination Office serves as the Secretary
of the Sustainability ManCo.
Sustainability ManCo’s responsibilities are clearly outlined in its Terms of Reference, which guide its work, including approving and
monitoring Sustainability Strategy, Net Zero commitments, targets, action and transition plans, as well as Sustainability Frameworks
(e.g. Sustainable Finance Framework, Green Bond Framework) and Policies, ensuring that sustainability -related projects and
initiatives align with Sustainability Strategy targets, objectives, Net Zero commitments and sustainability -related KPIs.
Sustainability at Eurobank is deployed across a Group Governance structure that addresses both regulatory requirements and
voluntary commitments. Board oversight, with respect to the Sustainability Strategy, is addressed through the inclusion of
sustainability items in the Board Meetings agenda, as per international best practice. The Group’s Governance structure is introducing
and defining the roles and responsibilities in relation to sustainability risks, embedding regulatory guidelines and market practices.
Additionally, the Group applies the Three Lines of Defense model, which clarifies the responsibilities of each line for managing climate-
related, environmental and sustainability risks. This model, through structured policies, further delineates duties across each line,
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ensuring that each body and individual within the organisation has a defined responsibility for managing sustainability impacts,
mitigating risks and leveraging opportunities within their operational scope. The Sustainability Governance structure aims to further
enhance the effective oversight of sustainability matters at Management/Board level, through direct reporting lines. The GSSO as
represented in the chart, along with the Group Chief Risk Officer (GCRO), co-manages Group Sustainability Risk, which involves
coordinating sustainability efforts and ensuring the integration of sustainability principles across the organisation. The GSSO plays a
critical role in embedding sustainability into the Group’s strategic decision-making, ensuring that sustainability is considered in
policies, business and operational strategies.
To further strengthen the Group’s sustainability oversight and to support the consistent implementation of sustainability-related
requirements across all entities, the Group introduced in 2025 the Group Sustainability Integration & Data function. This new role
enhances coordination between central units and international subsidiaries, coordinates the implementation of sustainability-related
actions across the Group, oversees and harmonises the Group-wide data-collection processes, and ensures the integration of
sustainability data into common systems and central data-management structures.
In 2025 Eurobank continued to apply its Sustainability Governance model while supporting its Sustainability Strategy rollout and the
integration of sustainability risks.
Governance Structure and Committees:
●
Oversight of sustainability risks at management body level through allocation of responsibilities to Board and management
committees. Specifically, Chairman of the SMC is the General Manager, Group Strategy.
●
Appointment of an executive member by the Board, who is responsible for climate -related and environmental risks. This
member updates the Board Risk Committees (BRC) at least semi-annually.
●
Establishment of 2 Committees that supplement the governance arrangements on sustainability risk, i.e. Sustainability
Management Committee and Climate Risk Stress Test Committee.
●
Appointment of Group Senior Sustainability Officer to lead the Group’s sustainability initiatives.
Integration of Sustainability Risk Management across the 3 lines:
●
Dedicated teams within the CIB and Retail Banking units for overseeing sustainability and sustainable financing activities.
●
Automated process established to assess and classify sustainable financing opportunities.
●
Group Sustainability Unit responsible for managing and coordinating sustainability strategy related issues, the development
of action plans for the Group’s Net Zero portfolio strategies, as well as monitoring sustainability performance and
coordinating sustainability-linked activities that enhance the Group’s Impact. In this context, the Unit is responsible for
facilitating the development of the Sustainability data framework to coordinate and prepare external and internal
sustainability-related reports.
●
Group Sustainability Risk responsible for managing and monitoring sustainability risks, acting as PMO office for
implementing the sustainability risks roadmap and monitoring the Sustainability Strategy, and preparing and maintaining
the Bank’s Sustainability risk management policies, processes and methodologies, in collaboration with the Group
Sustainability Unit, Business and other Risk Units.
●
Training on sustainability, sustainable finance and sustainability risk topics to Group personnel.
Responsibilities for managing impacts, risks, and opportunities are defined and communicated through the Group’s governance
framework, including board mandates, committee charters where applicable, and internal policies and procedures, ensuring clarity
of roles and accountability across all relevant bodies.
The roles and responsibilities of the key governance bodies / committees / units-functions are outlined below:
Supervisory bodies:
Eurobank Holdings (up to 12.12.2025) / Eurobank Board of Directors (BoDs/Boards)
Eurobank Holdings / Eurobank Boards play a key role in overseeing the Group’s Sustainability Strategy. Sustainability items are
regularly included in Board agendas to ensure effective governance. The Boards have appointed an executive member responsible
for climate-related and environmental risks, who provides semi-annual updates to the Board Risk Committees (BRC). The BRC, in line
with its Terms of Reference, monitors sustainability risks and ensures alignment with international best practices.
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Eurobank Holdings / Eurobank Board Risk Committee (BRC)
The Eurobank Holdings / Eurobank Board Risk Committee (BRC) oversees sustainability risks as part of its mandate. These risks are
identified through the Risk Identification and Materiality Assessment (RIMA) process and assessed against the Group’s risk appetite
and strategy. The BRC approves principles, policies, and methodologies for managing sustainability risks, including the Sustainability
Risk Management Policy, ensuring proper identification, monitoring, and mitigation across the Group.
Audit Committee
In line with the stipulation of the
Law 5164 (Article 43),
Audit Committee (AC) has been entrusted with additional responsibilities
concerning the submission and assurance of the Sustainability Statement. The Audit Committee informs the Board of Directors about
the outcome of the statutory audit and the assurance of the sustainability statement. It explains how these processes contributed to
the integrity of the financial and sustainability information and clarifies the role of the Audit Committee during this process
For more detailed information regarding the Board Committees, please refer to the Corporate Governance Statement, Statement in
the section Board Committees.
Management bodies:
Eurobank Management Risk Committee (MRC)
The Eurobank Management Risk Committee (MRC) is responsible for overseeing the risk management framework of Eurobank. As
part of its responsibilities, the MRC facilitates reporting to the BRC on a wide range of risk-related topics under its purview, including
sustainability risks. The MRC ensures that material risks are identified and promptly escalated to the BRC and that the necessary
policies and procedures are in place to prudently manage risk and to comply with regulatory requirements.
Eurobank Sustainability Management Committee (Sustainability ManCo-SMC)
The Eurobank Sustainability ManCo provides strategic direction on sustainability initiatives, reviews the Sustainability Strategy, Net
Zero targets and transition plans prior to approval, ensures that the elements of the Sustainability Strategy and the Net Zero
commitments are integrated into the Group’s business model & operations, approves changes in eligible assets of Green Bond and
Sustainable Finance Frameworks, regularly measures and analyzes the progress of the Sustainability Strategy goals and performance
targets and ensures the proper implementation of sustainability-related policies and procedures, in accordance with supervisory
requirements and voluntary commitments.
Eurobank Climate Risk Stress Test Committee (CRSTC)
The Eurobank Climate Risk Stress Test Committee (CRSTC) is responsible for designing and executing the Group’s CRST Programme,
as well as for coordinating all activities relating to Climate Risk Stress Testing, including risk identification, scenario design and stress
test execution, and reviewing and challenging the output at each stage of the process prior to escalating to the Executive Board.
For more information regarding the Management Committees please refer to the Corporate Governance, Statement in the section
“Management Committees”.
Administrative bodies:
Group Senior Sustainability Officer (GSSO)
The Group Senior Sustainability Officer (GSSO) is responsible for leading and coordinating the Group’s sustainability initiatives, for
both Operational and Financed Impact. GSSO manages Group Sustainability, co-manages, as a secondary reporting line, along with
the Group Chief Risk Officer the Group Sustainability Risk, coordinates Sustainability Center of Excellence of CIB and Retail and
oversees the sustainability programs of international subsidiaries. The role of the GSSO is to foster a deep understanding of
sustainability principles and practices across the organisation by building a culture of sustainability and collaborating with senior
management, to embed sustainability into the Group’s strategic decision-making processes. GSSO secures and allocates resources
effectively to support the Group’s sustainability initiatives and advocates for necessary investments in sustainability projects and
technologies. GSSO serves as the liaison between the Group and Market/External Stakeholders, closely monitoring industry trends,
regulatory changes and best practices in sustainability and ensuring that the Group remains at the forefront of sustainability
innovation and compliance.
Group Sustainability Unit
The Group Sustainability Unit acts as a custodian of Sustainability Principles and Culture to enhance the Group’s Impact, and as a
cross-functional coordinator to ensure alignment on sustainability issues and interdependencies, as well as compliance with relevant
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existing and upcoming regulations. Specifically, the Group Sustainability Unit is responsible for managing and coordinating
sustainability strategy related issues, ensuring alignment of subsidiaries' programs with the Group's overall sustainability strategy and
goals, supporting their implementation efforts. The Group Sustainability Unit coordinates the development of action plans for the
Group’s Net Zero portfolio strategies and ensures the aligned development of corresponding plans for subsidiaries. It directs the
actions of the Bank's units and subsidiaries on sustainable financing matters and provides advisory support on broader sustainability
issues. The Unit facilitates the development of the Sustainability data framework and promotes sustainability knowledge and culture.
Furthermore, it coordinates and prepares external and internal sustainability-related reports in line with applicable
standards/regulations, in cooperation with involved subject-matter responsible Units, while it is responsible for the UNEP FI PRB
implementation. Being responsible for the oversight of the Bank’s overall sustainability performance, its key roles include the
centralized management of Sustainability Ratings, seeking continuous improvement in related scores. The Group Sustainability Unit
also manages the ISO Management Systems under the related provisions of equivalent policies and the Sustainability Strategy,
supporting also the development / maintenance of ISO Management Systems at Group level, where applicable. It collects, calculates
and reviews data, in line with the associated certified ISO Management Systems, while it also ensures implementation of
corresponding initiatives (e.g. operational net zero transition, energy self-production, energy and emission monitoring, green building
certifications, recycling and circular economy management). To further strengthen the Group’s sustainability oversight and to support
the consistent implementation of sustainability -related requirements across all entities, the Group introduced in 2025 the Group
Sustainability Integration & Data function. This new role enhances coordination between central units and international subsidiaries,
coordinates the implementation of sustainability-related actions across the Group, oversees and harmonises the Groupwide data
collection processes, and ensures the integration of sustainability data into common systems and central data management
structures.
Business Units
The Business Units – Corporate and Investment Banking, and Retail Banking – are primarily involved in executing all portfolio-related
sustainable activities, including the implementation of the Net Zero and Financed Impact Strategies. Key responsibilities are classified,
inter alia, under the following 3 main categories:
1.
Sustainability Strategy
●
Executing and monitoring financed and specific operational sustainable goals and performance targets in line with the
Net Zero Strategy.
2.
Sustainable Financing/Funding and Investments
●
Identifying sustainable financing opportunities and designing relevant solutions and sustainable products.
●
Performing the sustainable financing assessment, in line with the Sustainable Finance Framework.
●
Implementing and monitoring the Sustainable Investment and Green Bond Frameworks.
3.
Sustainability Risk Management
●
Performing the clients overall ESG Risk Assessment, where applicable.
●
Identifying and implementing mitigation action plans for sustainability risks.
Eurobank has established dedicated functions, namely the Sustainability Center of Excellence (CoE), within the Business Units
(Corporate & Investment Banking and Retail Banking) which are responsible for assessing, managing and monitoring risk levels in all
risk categories, including Sustainability risks. The Head of CIB Sustainability CoE is responsible for overseeing sustainable financing
activities, while two Retail Banking Sustainability Coordinators (for Business and Individual clients, respectively) are responsible for
organising and supporting sustainable-related financing activities.
Group Sustainability Risk (GSR)
The GSR has the overall responsibility for overseeing, monitoring and managing sustainability risks. More specifically, the GSR
prepares and maintains the Bank’s Sustainability risk management policies, processes and methodologies, in collaboration with the
Group Sustainability Unit, Business and other Risk Units. In addition, it leads the development and implementation of the
sustainability risk-related framework, policies and processes, in coordination with other units, monitors the progress of the Climate
Risk Action Plan and reports on its implementation to the Group Senior Sustainability Officer (GSSO), while also reporting on
sustainability risk matters to the Board of Directors. The GSR monitors and challenges the involved stakeholders in setting Net Zero
targets, the Financed Impact Strategy and and the development of the Transition Plan and reports financial targets and KPIs. The GSR
also leads the 2nd line of defense independent sustainable lending re-assessment process against the Sustainable Finance criteria,
including the classifications of Retail Portfolio products as sustainable. Additionally, the Unit reviews and confirms the outcomes of
the ESG Risk Assessment, evaluates their consistency and completeness and formally challenges the adequacy of the proposed
mitigating actions. Furthermore, the GSR develops and maintains the Climate Risk Stress Testing Framework, as well as the Scenario
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Analysis and Stress Testing methodologies, and coordinates the performance of sustainability risk scenario analysis and relevant stress
test exercises at Group level.
Group Compliance
Group Compliance’s key roles and responsibilities include:
1.
Regulatory compliance
●
Identifies and monitors on an ongoing basis the regulatory environment and emerging trends around sustainability and
suggests to the Group the respective changes/enhancements to the relevant policies and documents.
●
Issues a regulatory bulletin, which includes regulatory developments and their impact on the Bank’s operation.
●
Monitors the alignment of the Group’s activities with applicable laws, rules, regulations and standards, including
sustainability regulatory aspects.
2.
Regulatory Compliance Risk Assessment
●
Designs appropriate risk assessment methodologies for compliance risk.
●
Utilizes a range of processes and tools for managing compliance risk.
●
Maintains an overlay on risk assessment methodologies and is responsible jointly with the competent sustainability
units, so that an effective compliance monitoring program for the relevant activities is in place, the respective
compliance programs are monitored by Group Compliance.
●
Assesses conduct risk in relation to sustainability financing.
3.
Policy updates
●
Maintains the Bank’s conduct-related policies, including their sustainability components.
4.
Product offering monitoring
●
Provides advice and recommends controls over the Bank’s product offerings, while it also checks that promotional
statements do not misrepresent products or services offered to customers, through its participation in the Products
and Services Committee and related processes.
Within Group Sustainability, two FTEs maintain a secondary reporting line to the Group Chief Compliance Officer, supporting the
Group Compliance function on matters related to monitoring and analysing regulatory developments in sustainability, assessing
associated risks, providing supplementary advisory services and conducting controls, with an emphasis on identifying and preventing
greenwashing.
Group Compliance actively supports upskilling in key sustainability regulatory areas. Dedicated training, for example on Compliance
tools and Compliance Methodologies—ensures that Compliance officers remain equipped to meet evolving supervisory expectations
and to effectively advise the business on sustainability -linked regulatory requirements. It is also noted that the personnel of Group
Compliance include executives who hold recognized professional certifications in sustainability-related areas.
Group Internal Audit (Group IA)
The role of the 3rd line within Eurobank’s governance and organisational structure is allocated to the Group IA, for the independent
review of the adequacy and effectiveness of the internal control framework. The Group IA mandate covers all processes, risks and
mechanisms, for all business lines and internal units. In recent years, the Group IA has recognised sustainability internal controls and
the risk management framework as areas of focus and has taken several initiatives and actions within its strategy. These aim to ensure
adequate coverage of the area, in line with the Bank’s strategy, as well as industry and regulatory developments.
Specifically, the Group IA strategically focuses on the Sustainability risks, building on the following pillars:
●
Methodology/ Infrastructure
– The Management of sustainability risks and the Bank’s initiatives are recognised as a
separate auditable area, subject to risk assessment. Furthermore, climate-related and environmental risk is recognised as a
separate risk category, assessed in all relevant areas of the audit universe, in line with the Bank’s risk taxonomy. This category
will be extended to cover the entire spectrum of sustainability risks, in line with respective developments in the Bank’s risk
definitions.
●
Resources
with two staff members certified in Sustainability/ESG and Climate Risk through different professional bodies to diversify
relevant expertise and with additional auditors planned to pursue relevant industry-recognised professional body
certifications in the future. This comes simultaneously with other initiatives in place, aimed at further upskilling through
dedicated training sessions, on-the-job upskilling (participation in and consultation on the Bank’s projects and initiatives
around sustainability) and increased awareness (e.g. Group IA ESG Focus Group focused at sharing knowledge on sustainable
practices and regulatory initiatives). At this stage, the Group IA has opted to embed the right mix of skills and knowledge
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within its existing organisational structure, given the multifaceted nature of sustainability risks, affecting all businesses and
operations of the Bank, to a siloed approach, aiming at a holistic consideration of the Bank’s sustainability risks.
●
Sustainability / Audit Universe Coverage and Audit Planning
– Following the infrastructure steps described above, since
2021, the Group IA has been carrying out several assignments around sustainability, along with monitoring the Bank’s
initiatives in this area on a risk-based approach. Key areas of focus include risk materiality, governance and strategy,
Sustainability risk management framework, product design and offering, reporting disclosures, etc. For more information
regarding the responsibilities for impacts, risks and opportunities of the administrative, management and supervisory
bodies, please refer to: “1.3.2 Information provided to and sustainability matters addressed by the undertaking's
administrative, management and supervisory bodies [GOV-2]” and 1.5.1 Description of the processes to identify and assess
material impacts, risks and opportunities [IRO-1].
Overall Group IA follows a risk-based approach to independently review and provide objective assurance, advice and insight, having
in scope all activities, operations and units of the organisation. The Group IA’s multi-year audit plan ensures that all of the Group’s
activities/operations are subject to review, in compliance, inter alia, with EU laws and regulations and supervisory expectations, as
well as the Global Internal Audit Standards. The Group IA documents the outcome of audits in audit deliverables that are used to
provide information to several recipients (e.g. AC, Board Committee, Senior Management, external auditors). The Group IA attends
the Audit Committee meetings to present a summary of its activity and highlight key issues, at least on a quarterly basis.
Operating model
The Group has identified, assessed and implements relevant action plans addressing sustainability risks within the 3 lines.
Integration of Sustainability Risk Management across the 3 lines
The Group’s Sustainability Governance structure introduces and defines specific roles & responsibilities in order to support the roll-
out of the Sustainability Strategy and the integration of the sustainability risks, through the involvement of various key stakeholders
(e.g. Business & Risk Units, Committees etc.) across the three Lines of defense, embedding regulatory guidelines and market practices,
as follows:
1st Line:
Dedicated functions, namely the Sustainability Centers of Excellence (CoE), within the Business Units (Corporate & Investment
Banking and Retail Banking) are responsible for assessing, managing and monitoring risk levels in all risk categories, including
Sustainability risks. The Head of CIB Sustainability CoE is responsible for overseeing sustainable financing activities, while two Retail
Banking Sustainability Coordinators (for Business and Individual clients respectively) are responsible for organising and supporting
sustainable-related product financing activities. In addition, the role of the Group Sustainability Unit in the 1st Line includes the
responsibility for managing and coordinating sustainability strategy related issues, the development of action plans for the Group's
Net Zero portfolio strategies, the Group’s Transition Plan and the facilitation of the Sustainability data framework development, as
well as Sustainability Reporting, Environmental & Energy Reporting (EMAS Report, Greenhouse Gases Emissions Report per ISO
14064) and Sustainability ratings. The 1st Line, in coordination with other Units, execute and monitor financing, and specific
operational sustainable goals and performance targets based on the Group’s Sustainability Strategy and in line with the Net Zero
Strategy.
2nd Line:
Group Risk Management (GRM) is independent from the Business Units and has full responsibility in setting the Risk Strategy and Risk
Appetite Framework, including Sustainability risks. Within GRM, the dedicated GSR has the overall responsibility for overseeing,
monitoring and managing Sustainability risks in cooperation with the other GRM Units, as well as with Group Compliance.
3rd Line:
The Group Internal Audit (Group IA) independently reviews the adequacy and effectiveness of the internal control framework in place
regarding Sustainability risk management on a regular basis, following a risk-based approach in line with its Annual Risk Assessment
and Audit Planning Methodology.
ESG awareness and capacity building
Eurobank places great emphasis on building capacity among its employees, so they are able to support its clients on their sustainability
journey and their green transition. To this end, in addition to launching sustainability initiatives for its clients, Eurobank implements
an ESG upskilling plan for its employees. Eurobank’s ESG awareness program regarding sustainability matters, is directed to all of the
Group's personnel - employees and management. Additionally, the Group has offered training to stakeholders from all 3 lines (i.e.
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business units, risk management units, Group IA) regarding the SFF, to enhance their understanding. Finally, the Group conducts
training sessions/seminars tailored to its supervisory and management bodies, tailored to their specific areas of interest/expertise.
CIB Sustainability Academy
The CIB Sustainability Academy is a strategic internal awareness initiative designed to enhance ESG knowledge and strengthen
sustainability awareness across Corporate & Investment Banking employees. Delivered through short, interactive sessions via the
“Digital Academy for Business” platform, the Academy covers emerging and specialised topics related to sustainability, the banking
sector, and the Corporate & Investment Banking environment. Since its inception in October 2024, 9 ESG-focused sessions have been
delivered, and the programme continues on an ongoing basis to further reinforce the Bank’s commitment to cultivating a strong
sustainability culture within the CIB division. Specifically, the following awareness programmes are in place:
Employee ESG awareness training modules
Since 2022, the Group has launched “ESG Thinking”, an ESG awareness program for employees, consisting of the following modules:
●
Module 1
– ESG and World: Fundamentals of ESG, megatrends and related risk and opportunities as well as the importance
of ESG within an organisation described through business cases.
●
Module 2
ways in which the Bank engages with sustainability through frameworks, initiatives and products.
●
Module 3
by motivating employees to take personal action through practical steps personally and professionally.
Target setting
The Board of Directors, Board Committees, Management Committees and functions oversee the setting of targets related to material
impacts, risks, and opportunities through a combination of strategic review, decision-making, and continuous monitoring.
The Sustainability Management Committee (Sustainability ManCo - SMC) plays a central role in this process by reviewing the
Sustainability Strategy, providing strategic direction on sustainability initiatives, reviewing the Net Zero targets and Transition P
lan
prior to approval, integrating the elements of the Sustainability Strategy, the Net Zero commitments and the Transition Plan into the
Group’s business model and operations, while also ensuring that stakeholder interests and expectations are met. It also approves
changes in eligible assets of Green Bond and Sustainable Finance Frameworks, regularly measures and analyses the progress of the
Sustainability Strategy goals and performance targets, ensure the proper implementation of sustainability -related policies and
procedures, in accordance with supervisory requirements and voluntary commitments. The Committee further approves
Sustainability-related reports, including the Sustainability Statement and Green Bond Report, among others. Additionally, the
Sustainability ManCo reviews and endorses Sustainability-related KPIs linked to variable remuneration and incentive schemes, prior
to submission to the Incentive Plan Committee. Through this oversight, the Sustainability ManCo ensures the continuous
improvement and alignment of Sustainability-related ISO Management Systems, including ISO standards in the environmental and
energy domains, ensuring their ongoing suitability, adequacy, and effectiveness.
Sustainability-related expertise
The Board of Directors, Board Committees, Management Committees, functions and involved units possess a collective set of skills
and expertise that are crucial for overseeing sustainability matters. At the Board level, Sustainability Management Committee
(Sustainability ManCo - SMC) and senior management, expertise in sustainability is represented through a structured approach that
integrates both in-house knowledge and external expertise. The SMC provides strategic direction on Sustainability-related initiatives,
aligning them with the Group’s broader transformation plan. The members of the SMC, including senior roles like the Deputy CEO,
Group Chief Operating Officer (COO) & International Activities, the General Manager, Group Strategy, the Group Senior Sustainability
Officer (GSSO) and the Chief Risk Officer are responsible for ensuring that Sustainability issues are fully incorporated into the
operations and decision-making processes across the organisation. Furthermore, the SMC reviews and approves sustainability training
and awareness initiatives. Moreover, the BoD ensures that key individuals across the Group are equipped with necessary expertise
as it has the oversight over training and awareness initiatives as evidenced by its role. This structure ensures that expertise is both
possessed internally and is accessible externally, empowering the Group to manage sustainability challenges effectively.
The skills and expertise present within the Board of Directors, Board Committees, Management Committees, units and functions are
directly aligned with the Group's material impacts, risks, and opportunities. For instance, the Sustainability ManCo is tasked with
overseeing the integration of sustainability goals, including Net Zero Strategy, Transition Plan and Sustainable Financing activities,
into the Group’s broader strategic objectives. The expertise of senior executives such as the Deputy CEO, Group COO and International
Activities, the General Manager, Group Strategy, the GSSO and the CRO ensures that Sustainability considerations are embedded into
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the Group’s daily operations, enabling them to address and manage the material risks and opportunities tied to sustainability. The
Business Units (Corporate & Investment Banking, Retail Banking) are actively engaged in managing sustainability risks as part of their
operations, with specific responsibilities assigned through the Group Sustainability Unit, responsible to manage and coordinate
sustainability strategy-related issues. Through the structure, these bodies ensure that sustainability risks are appropriately assessed,
monitored, and mitigated at every level, from operational to strategic decision-making.
The Board is provided with semi-annual sustainability update sessions to support effective oversight of evolving regulatory
requirements, the Group’s mitigation strategy through key initiatives and actions, and emerging sustainability megatrends. These
sessions also incorporate sectoral benchmarking to evaluate the Group’s positioning and performance relative to peers and market
best practices.
1.3.2
Information provided to and sustainability matters addressed by the undertaking's administrative, management and
supervisory bodies [GOV-2]
The Sustainability Management Committee (SMC) is regularly informed about material impacts, risks, and opportunities through
multiple reporting channels. Specifically, the SMC meets quarterly and/or on an ad hoc basis, when necessary, to review and provide
strategic direction on sustainability -related issues, including material risks and opportunities. The Committee reviews and monitors
sustainability strategies, action plans, KPIs and progress towards sustainability goals to ensure they align with the Group’s objectives.
The SMC also reviews reports on sustainability issues, risk management processes, and performance metrics, ensuring that decisions
are aligned with sustainability goals.
Impacts, Risks and Opportunities consideration
The SMC carefully considers impacts, risks and opportunities when overseeing the Group’s strategy. The SMC plays a critical role in
providing strategic direction on sustainability matters, ensuring the Sustainability Strategy aligns with the Group’s overall Business
and Transformation Plan. The Committee is involved in the approval of action plans, project monitoring, and reviewing Sustainability-
related policies and frameworks. Policies affecting internal stakeholders are available to the Eurobank’s intranet, while those referring
to external stakeholders, such as the Group's Code of Conduct and Ethics, are available through the corporate site. Overall, the Group
ensures there is a high level of accountability in Policy development and implementation. Policies are approved by the appropriate
Governance bodies such as the Board of Directors or specialized committees, which ensure that there is alignment with the Group's
strategic goals and stakeholder interests.
Additionally, sustainability risks are assessed regularly, ensuring that sustainability factors are embedded in the Group’s strategic
decisions, including sustainability targets, major investments, and the overall risk management framework.
The Board Risk Committee plays a crucial role in ensuring that the Group Risk Strategy and Risk Appetite Framework inform the
business plan and decision-making, thus aligning risk management processes with the Group's broader objectives and actions. The
Committee considers trade-offs associated with material sustainability matters, for example by incorporating sustainability-related
risks and opportunities within the existing risk management frameworks. This ensures that sustainability considerations are evaluated
alongside financial and operational risks.
During the reporting period, the Board of Directors, Board Committees, Management Committees and functions, through the SMC,
addressed several material impacts, risks, and opportunities included the implementation of the due dilligence process. Through the
Double Materiality Assessment (DMA) exercise, the SMC reviewed the Impacts, Risks, and Opportunities (IROs) that were identified
as material for the Group. These IROs were assessed based on both impact and financial materiality to ensure comprehensive
consideration.
For a detailed list of the Impacts, Risks, and Opportunities (IROs) approved by the SMC, please refer to the respective section of the
Sustainability Statement, which outlines these material issues in further detail.
For more information regarding the due diligence process please refer to: 1.5.1 Description of the processes to identify and assess
material impacts, risks and opportunities [IRO-1].
1.3.3
Integration of sustainability-related performance in incentive schemes [GOV-3]
The Group has established a Remuneration Policy that is applicable to all Group employees and covers their total remuneration. The
Remuneration Policy forms an integral part of the corporate governance practice and is developed in accordance with its operational
model, business strategy, objectives, long-term interests of the Group and incorporates measures to avoid conflict of interest.
The Remuneration Policy promotes sound and effective risk management and is consistent with the objectives of the Group’s business
and risk strategy, corporate culture, values and risk culture. It also considers sustainability risk factors, as well as the long-term
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interests of the Group. Additionally, it includes measures to avoid conflicts of interest and excessive risk-taking on behalf of the Group.
The Group ensures that remuneration practices are aligned with their overall risk appetite, taking into account all risks, including
sustainability risks, reputational risks, as well as risks resulting from the mis -selling of products or services.
In addition, the Remuneration Policy has been enhanced with the establishment of a Variable Remuneration Framework, Key
Performance Indicators (to balance employees’ performance and encourage proper conduct) and Key Risk Indicators (to promote
sound and effective risk management including sustainability risks) at Group/ Unit/ Individual level, as appropriate. The Variable
Remuneration Framework aims at providing (i) an appropriate balance of variable remuneration elements, aligning the interests of
employees, shareholders and other stakeholders, strengthening the Group’s position as a leading European bank and (ii) effective
remuneration practices in compliance with the applicable regulatory environment. In this context, Key Risk Indicators are set at Group
level, whereas Eurobank underscores the significance of introducing more Key Risk Indicators linked to sustainability risks in the
following years.
The Remuneration Policy has been designed to:
●
Be consistent with and promote sound and effective risk management.
●
Stimulate behaviours consistent with the sustainability risks approach.
●
Comply with the Group’s regulatory obligations and voluntary commitments.
Its basic principles are to:
●
Be gender neutral and non-discriminatory in any aspect of its implementation.
●
Safeguard that remuneration is sufficient to retain and attract executives with appropriate skill and experience.
●
Monitor that internal equity between all Units is applied.
●
Avoid excessive risk-taking, even in the case of direct or indirect sustainability risks.
●
Link remuneration with long-term performance.
The Group’s sustainability-linked remuneration integrates the achievement of components / targets of the Group’s Sustainability
Strategy, to incentivise management and employees to contribute towards their achievement. (i.e. Bank’s CO2 Emissions, New CI
B
disbursements in Green/Environmentally sustainable loan).
The Remuneration Committee approves any incentive scheme both at Bank and Group level, while the Non-Executive Members of
the BoD approve and periodically review the Remuneration Policy and are responsible for overseeing its implementation.
1.3.4
Description of the due diligence on sustainability matters [GOV-4]
The following table shows how and where the application of the main aspects and steps of the due diligence process are reflected in
Eurobank’s Sustainability Statement:
Core elements of due diligence
Paragraphs in the Sustainability Statement
Description
a) Embedding due diligence in
governance, strategy and business
model
2.5.1 Governance - Sustainable financing and
investment offerings
2.4.4 Policies related to the integration of
sustainability in risk management [MDR-P]
1.3.3 Integration of sustainability-related
performance in incentive [ESRS 2 GOV-3]
The Group integrates sustainability into its
governance and strategy through
frameworks like the Climate Risk Scorecard
and Sustainable Finance Framework,
ensuring these principles guide decision-
making.
b) Engaging with affected stakeholders
in all key steps of the due diligence
1.4.3 Stakeholder interest and engagement
[SBM-2]
1.4.4 Material impacts, risks and
opportunities and their interaction with
strategy and business model [SBM -3]
2.4.4 Policies related to the integration of
sustainability in risk management [MDR-P]
The Group engages stakeholders to align
business practices with expectations,
informing its materiality assessment and
relative policies.
c) Identifying and assessing adverse
impacts
2.4.4 Policies related to the integration of
sustainability in risk management [MDR-P]
The Group conducted a DMA to identify
and assess adverse impacts, focusing on
both potential and actual effects on people
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Core elements of due diligence
Paragraphs in the Sustainability Statement
Description
2.5.1 Governance - Sustainable financing and
investment offerings
and the environment. In addition,
Eurobank uses the RIMA process and ESG
Risk Assessment to evaluate risks, applying
enhanced due diligence for high-risk
clients.
d) Taking actions to address those
adverse impacts
2.5.1 Governance - Sustainable financing and
investment offerings
The Group implements action plans for
workforce impacts and supports financial
inclusion through various initiatives.
e) Tracking the effectiveness of these
efforts and communicating
2.4.1. Governance - Integration of
Sustainability in risk management
2.5.1 Governance - Sustainable financing and
investment offerings
The Group ensures transparency through
risk management and internal controls
1.3.5 Risk management and internal controls over sustainability reporting [GOV-5]
The Group’s risk management and internal control system ensure the accuracy, completeness, and integrity of data included in the
Sustainability Statement. It includes dry run exercises, quality checks, workshops with relevant stakeholders, and assumptions made
when direct data could not be obtained from value chain stakeholders to ensure the accuracy and integrity of the data. To further
strengthen the 2025 Sustainability Statement reporting process, Eurobank has introduced an additional validation checklist layer,
creating multiple levels in the data collection process to enhance reliability and control, building on the comprehensive reporting
framework developed in alignment with the Corporate Sustainability Reporting Directive (CSRD) requirements. The Sustainability
Statement reporting process establishes a unified framework for data collection, quality assurance, and reporting across all
subsidiaries, ensuring transparency and compliance.
In addition, the relevant departments responsible for providing qualitative information are responsible for supplying accurate
qualitative information, by examining the data provided to ensure consistency and completeness. The reporting process outlines clear
roles and responsibilities for data and content owners and reviewers. This process aims to reinforce accountability within the Group
and foster a culture of continuous improvement, thereby upholding the Group’s enduring commitment to ESG excellence.
Eurobank adopted a risk assessment approach that incorporates regular evaluations of data completeness, accuracy, and integrity.
To prioritise risks, the Group utilises a risk-based approach, considering the potential impact on the Sustainability Statement reporting
process. The CSRD Operating Committee oversees this process, ensuring alignment with CSRD standards and supporting continuous
improvement. The main risks identified within the risk assessment performed are data gaps from value chain stakeholders, accuracy
of estimations, and timing of data availability. To mitigate them, Eurobank conducted dry run exercises, quality checks, workshops
with stakeholders, and made necessary assumptions to fill data gaps. Eurobank also conducted regular reviews to ensure the
coordination of data collection, consolidation, and verification to maintain high standards of quality and compliance.
The outcomes of the risk assessment and internal controls throughout the Sustainability Statement reporting process are integrated
into relevant internal functions and procedures with regular updates provided to the Group Senior Sustainability Officer and, if
necessary, to relevant Committees. Risks are prioritised based on their potential impact and likelihood, taking into account the
significance of their effect on the Sustainability Statement reporting process. The CSRD Operating Committee oversees the
sustainability reporting risk assessment process and, based on its outcomes, formulates recommendations which are incorporated
into the design and execution of the subsequent reporting cycle.
1.4
Strategy - Company, business model and stakeholder engagement
1.4.1
Information on the market position and strategy of the company [SBM-1]
The Group offers a broad range of financial products and services, including corporate and investment banking, retail banking
(personal banking, business and individual banking), wealth management, leasing, insurance, factoring, and specialized solutions such
as shipping finance and syndicated debt solutions. In the reporting period, the Group has expanded its digital transformation efforts,
offering services like digital banking solutions. Moreover, the Group has increased its focus on financing green projects and promoting
ESG (Environmental, Social, and Governance) criteria in its products, such as sustainability-linked loans, bridge financing programs for
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energy efficiency projects, financing for renewable energy projects and other activities with positive environmental and social impact.
Eurobank serves a wide range of customer groups, including large corporate clients, institutional investors, personal banking clients,
SMEs, and public-sector entities. Geographically, the Group is primarily active in Greece, Cyprus, Bulgaria and Luxembourg.
Furthermore, it has made strides in expanding its green financing services to support the transition toward sustainable business
practices.
Geographical area:
Headcount:
Bulgaria
3,678
Cyprus
2,905
Greece
6,042
Luxembourg
148
Eurobank’s sustainability-related goals include financing the transition to sustainable energy, enhancing the environmental impact of
its clients, and investing in technologies that reduce carbon footprints. These objectives are embedded in the Bank’s strategy and are
aligned with its participation in the Net Zero Banking Alliance (NZBA). In addition, these goals are embedded in the Group’s core
strategy, and a significant portion of its portfolio focuses on renewable energy projects, energy-efficient technologies, and
sustainability-linked financings. Eurobank’s commitment to sustainable finance also includes driving growth in digital services, which
helps reduce environmental impacts and promote green practices, aligning with the Group’s broader sustainability objectives.
Group Sustainability Strategy
Eurobank supports the transition towards a sustainable economy and considers sustainability and climate change as an opportunity.
A key strategic objective is to adapt the business and operation in a way that addresses climate change challenges, accommodates
social needs within its business model and safeguards prudent governance for itself and its counterparties, in accordance with
supervisory initiatives, and following international standards and best practice.
To this end, Eurobank has designed, approved and is currently implementing its Sustainability Strategy, including targets and
commitments, along with the two key pillars:
Operational Impact Strategy (OIS)
Financed Impact Strategy (FIS)
, both of which
aim to address sustainability matters within the context of the Group’s business model and operations.
1.
Operational Impact Strategy (OIS):
The
Operational Impact Strategy
are sustainable, and aligning its operations with climate and sustainability goals. The key elements of this strategy are:
●
Environmental Impact:
a clear goal of achieving climate neutrality.
●
Societal Impact:
development and prosperity for the benefit of society.
●
Governance & Business Impact:
intensifying Eurobank's efforts for ethics and transparency.
The OIS is supported by a governance structure of multiple project streams (one per each commitment) and the supervisory ESG/OIS
Committee. Progress is regularly reviewed at the Sustainability Management Committee. Each project stream is planned with
milestones, KPIs, annual targets and long-term interim targets, serving the declared commitments, spanning over the next decade.
Links are established with Transformation streams as well as corresponding ISO Management System standards, to ensure
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substantiation and certification of activities, validate target setting and measured performance, and systematically monitor progress
through internal reviews and external assurance.
2.
Financed Impact Strategy:
The
Financed Impact Strategy
financing activities, with a commitment to sustainability and responsible stewardship. To achieve this objective, the Financed Impact
Strategy is structured around the following 4 strategic pillars:
●
Client Engagement and Awareness:
climate change challenges and opportunities.
●
Supporting Clients in Transition:
solutions, that are guided by the financing approaches and the eligible activities of the Sustainable Finance Framework, goals
and ambitions.
●
Enablers and Tools for Sustainable Financing:
●
Assessment and Management of Sustainability-related Risks:
within the Bank’s loan and investment portfolios, including assessing exposure to transition and physical risks linked to
climate change.
The Financed Impact Strategy supports Eurobank's commitment to sustainable financing, ensuring that the Group’s financial activities
align with sustainability goals, such as reducing the carbon footprint of financed projects.
Main Challenges Ahead:
Both strategies face several challenges:
●
Operational Transition:
associated costs and risks. This involves transforming internal processes and aligning with evolving applicable regulatory
requirements and voluntary initiatives as well as adopted standards and guidelines enabling Eurobank’s contemporary and
continuously updated approach towards Sustainability, in line with international best practice.
●
Client Transition:
This may involve addressing different levels of maturity, overcoming resistance to change, and navigating and aligning to
complex regulatory requirements.
●
Sustainability-related Risks:
and physical risks (e.g., climate change impacts such as extreme weather) that could affect both the Group’s own operations
and the sectors in which it invests or lends to is dependent on data availability and commitment of involved counterparties
and stakeholders
●
Alignment with Global Standards:
disclosures (such as TCFD), and managing the increasing demand for transparency in sustainability reporting.
To overcome these challenges, Eurobank has implemented a series of strategic initiatives:
●
Operational Impact Strategy (OIS) key components:
o
Operational efficiency:
achieve Net Zero in its operations for Scope 1 & 2 by 2033 and Scope 3 by 2050. Promotion of environmental
stewardship by accelerating also transition towards a paperless banking network and preservation of natural
resources, as well as extending circular economy practices. Accommodation of social needs within its business
model and safeguarding prudent governance for itself and its counterparties, in accordance with supervisory
initiatives, and following international standards and best practice.
o
The OIS is supported by a governance structure of project streams per each commitment and the supervisory
ESG/OIS Committee. Regular review of progress via milestones and KPIs to ensure annual and long-term
sustainability goals related to Environmental, Societal, and Governance & Business Impact are met. Progress is
regularly reviewed at the Sustainability Management Committee.
●
Financed Impact Strategy (FIS) key components:
o
Sustainable Financing:
through sustainable financing.
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o
Portfolio alignment:
with the 1.5°C climate transition scenario.
o
Net zero strategy:
setting up to 2050.
In line with its commitment to address climate change, the Group joined the Net-Zero Banking Alliance (NZBA), a bank-led, UN-
convened alliance of banks worldwide, reinforcing its dedication to aligning its lending and investment portfolios with net-zero
emissions by 2050 or sooner, in line with the most ambitious targets set by the Paris Climate Agreement.
The Group has developed sectoral, financed emissions reduction targets based on the NZBA framework, for some of the most carbon-
intensive and, therefore, most relevant and impactful sectors and portfolios. The Group applies established industry standards (e.g.
NZBA, PCAF) and accredited science-based decarbonisation scenarios, in line with a 1.5-degree Celsius objective by 2050.
While the Sustainability Strategy described above remains the formally approved and applicable strategic framework during the 2025
reporting period, Eurobank has, in parallel, initiated a structured process to review and update its Group Sustainability Strategy. The
objective of this process is to build on the existing strategy, further strengthen its effectiveness and embed sustainability more deeply
across the Group’s operations, decision-making and business activities. In this context, the update of the Group Sustainability Strategy
has been developed through a structured and comprehensive, Group-wide process, aimed at strengthening the contribution of
sustainability to long-term value creation. This process includes research, benchmarking, and re-alignme nt on sustainability mega-
trends and regulatory developments to redefine the key sustainability topics based on assessment of the Group’s strategic priorities
and performance, and consideration of stakeholder expectations and leading market practices.
This work enables a more focused articulation of the Group’s sustainability strategic direction and leads to the identification and
prioritisation of strategic drivers and focus areas designed to enhance value creation, notably through supporting business growth,
strengthening risk management and improving operational efficiency across the Group.
Subsequent phases will focus on translating this strategic direction into defined targets, KPIs and detailed action plans, supported by
appropriate governance and monitoring frameworks, following formal approval of the updated Group Sustainability Strategy.
1.4.2
Description of business model and value chain [42a-42c]
Upstream value chain
In mapping the upstream value chain, Eurobank has identified the key activities and actors involved in supporting its operations. The
upstream value chain includes suppliers and stakeholders that provide critical inputs both non-financial (e.g. supply of goods and
services) and financial necessary for Eurobank’s operations to function effectively. Given the complexity of Eurobank’s operations,
Eurobank focuses on direct (Tier 1) suppliers for the upstream side of its value chain. These suppliers are identified as having the most
direct impact on Eurobank’s operations, providing capital, critical goods and services such as IT, real estate management, energy, and
shaping the surrounding legal, regulatory and voluntary framework.
Key Activities and Actors in the upstream Value Chain:
●
Supply of Goods and Services
goods and services. These include suppliers of IT hardware and software, office equipment, paper, and consulting services.
●
Supply of Capital
operations. This involves key activities such as deposit gathering, bond issuance, capital market transactions, and other
investor-related activities.
●
Regulatory and Voluntary Frameworks
of Eurobank’s upstream value chain. Regulatory bodies such as the European Central Bank (ECB), the European Banking
Authority (EBA), the European Insurance and Occupational Pensions Authority (EIOPA) and the Single Resolution Board (SRB)
provide the regulatory frameworks within which Eurobank operates.
Downstream value chain
For entities downstream from the reporting organisation, Eurobank has included categories such as customers, who receive or utilise
its products and services. The Group established the boundary of its downstream value chain to include corporate and retail clients,
but it does not extend to the clients of those clients.
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Key Activities and Actors in the downstream Value Chain:
●
Provision of Financing to Clients
activities. This includes supporting operational needs and facilitating growth for small and large corporations while offering
financial solutions for individual customers.
●
Capital Markets Activities
products, institutional asset management, private banking, insurance and other financial advisory services. Eurobank
participates in market-making and advisory roles for corporations, financial institutions, and governments, promoting
sustainable investments.
●
Real Estate
properties held for the purpose of leasing) and other real estate services.
Eurobank's Position in the Value Chain:
Eurobank is positioned as a central player in the financial services value chain, connecting a diverse set of upstream suppliers with
downstream customers. Specifically, key activities in its own operations include Banking activities, Global Markets & Asset
Management, Investment Property & Real Estate Management. Its role spans from sourcing capital and operational inputs to
providing key financial services and products to both corporate and retail clients. By fostering sustainability in its operations, especially
in sustainable financing, Eurobank is positioning itself as a leader in promoting sustainable business practices within the financing
sector.
In addition, Eurobank acknowledges that, beyond core banking activities, its value chain also includes other financial services such as
Insurance, which though presently of low materiality—are considered within the consolidated sustainability scope and materiality
assessment.
1.4.3
Stakeholder interest and engagement [SBM-2]
The Group has developed a robust
Stakeholder Engagement Plan
European Sustainability Reporting Standards (ESRS)
, which emphasise the importance of gathering diverse stakeholder perspectives
to identify impacts, risks, and opportunities (IROs) and align business practices with stakeholder expectations and sustainability
objectives.
Stakeholder Identification and Mapping
As part of the double materiality assessment, the Group established a systematic and dynamic process for identifying and mapping
stakeholders. This process includes:
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Stakeholder Engagement Disclosure
1.
Key Stakeholders
Eurobank has identified and classified stakeholders into three main groups to ensure effective engagement across various
perspectives:
o
Primary/Affected Stakeholders:
o
Secondary Stakeholders:
o
ESG and other Experts:
Key stakeholder groups include:
o
Internal Stakeholders:
o
External Stakeholders:
and Shareholders, as well as Government and Regulators.
2.
Engagement with Stakeholders
Eurobank engages with both internal and external stakeholders as part of its comprehensive impact and financial materiality
assessments. For impact materiality, stakeholders from the Group are engaged to understand the sustainability impacts
across various entities and geographic locations.
3.
Organisation of Stakeholder Engagement
Engagement is organised systematically through a variety of methods and classified into
Internal
External Stakeholder
Groups:
o
Identification and Classification:
include both “affected stakeholders” and “users of the Sustainability Statement.”
o
Engagement Methods:
engagement. In addition, focus groups for corporate clients are conducted for impact materiality, and internal
stakeholders for financial materiality to evaluate sustainability-related impact risks and opportunities.
o
Segmentation by Business Areas:
inclusion of diverse perspectives from each operational area.
4.
Purpose of Engagement
The purpose of Eurobank’s stakeholder engagement is to establish open communication channels with stakeholders to
understand their needs and concerns and integrate them into the Group’s Sustainability Strategy.
Key priorities
o
protection of their personal data,
o
leveraging new technologies to enhance service,
o
ensuring access to financial services,
o
respect for human rights and the environment, and
o
upholding corporate culture and governance values along with adequate risk management practices.
5.
Consideration of Engagement Outcomes
Eurobank integrates the feedback from stakeholders into its decision-making processes to ensure that the identified
impacts, risks, and opportunities are accurately reflected in Group’s Sustainability Strategy. Key outcomes are validated by
the Sustainability Management Committee to ensure alignment with ESRS standards and effective incorporation into
Eurobank’s risk management and sustainability frameworks.
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Furthermore, Eurobank promotes two-way communication and develops ongoing dialogue with internal and external stakeholders,
to be able to actively meet the expectations, concerns and issues raised by all its stakeholders. Further information and the means of
communication are presented in the table below:
Stakeholder group
Cooperation framework and
expectations
Means of communication
Board of Directors
•
BoD member assigned as
responsible for climate-related
and environmental risks at
Group level.
Communication with the Board of Directors is facilitated through regular
and ad-hoc meetings as well as Progress reports. Regular and ad -hoc
meetings ensure structured updates, while addressing urgent matters.
Progress reports are consistently shared to provide ongoing insights
ensuring the BoD is well-informed at all times.
Executive
Management
•
CEO-appointed Sustainability
Management Committee.
•
Sustainability-related issues
raised at ExBo level.
Communication with Executive management is maintained through
regular and ad-hoc meetings, along with periodic progress reports.
Investors,
Shareholders and
Investment
Community
•
Timely reporting of accurate
and complete information on
the Group’s performance and
strategy.
The Group engages in ongoing communication with its investors to
enhance their understanding of matters that may be relevant to them,
thereby enabling them to effectively exercise their voting rights and
make informed investment decisions. The Group organises Annual
General Meetings and Extraordinary General Meetings οf Shareholders
and publishes information in a continuous, regular and timely manner
(through the Annual Reports, Financial Results and announcements on
its corporate websites) ensuring that stakeholders have easy access to
essential updates and disclosures.
Employees
•
Timely information on issues
concerning the Group, the
development and progress of
skills, as well as employee
engagement and benefits.
The Group places a strong emphasis on the upskilling and reskilling of its
employees, upholding a high standard of professionalism while
implementing anti-discrimination policies to create an inclusive work
environment. The Group provides extensive benefits to all employees,
irrespective of gender, age, or marital status. Frequent meetings,
breakfast gatherings, and various events promote open communication
between management and staff representatives. Enhanced
communication channels like HR4U and the Connected portal ensure
responsiveness to employee inquiries. The Group promotes work-life
balance, social and environmental awareness, and volunteering and
implements an ESG upskilling plan and awareness initiatives for
employees and clients to support sustainability efforts.
Business Community
(including corporate
networks,
entrepreneurship,
industry associations,
financial institutions
and start-up
entrepreneurs
)
•
Mutual cooperation and open
communication driven by
ensuring the interests of the
business community.
•
Showcasing and promoting
new businesses based on
specified criteria and
transparent procedures.
The Group supports entrepreneurship, innovation, and
internationalization through strategic initiatives including dialogue with
professional associations and collaborations.
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Stakeholder group
Cooperation framework and
expectations
Means of communication
Civil Society
(including
communities, NGOs,
the academic and
scientific
community,
international
organisations, and
the Media)
•
Engaging 3rd parties in CSR
initiatives designed and
implemented by the Group
•
Responding to 3rd party
actions with a social cause
•
Cooperation with the Media
to ensure optimum and
effective promotion of the
Group and its products and
services.
The Group engages with non-governmental organisations, to maintain
transparent communication and prompt responses. The Group also
encourages organisations to take part in corporate social responsibility
initiatives, providing support through sponsorships and donations.
Employee volunteer efforts enhance community involvement.
Partnerships with academic institutions promote innovation in CSR
practices.
Customers and Clients
•
Responsible information,
customer service and provision
of products and services with a
deep sense of respect and
transparency.
The Group places customers at the centre of its activities and one of its
purposes is to help them in the transition to a more sustainable future,
accompanying them on their journey towards decarbonisation, offering
them innovative solutions to finance their investments with positive
environmental and social impacts and managing initiatives that better
respond to sustainability-related challenges. A focus group was held as
part of this year’s impact materiality assessment to capture corporate
client perspectives. For more information on the Bank’s communication
channels with customers and clients please refer to section 3.2.2 Policies
and Actions.
Government and
Regulators
•
Compliance and harmonisation
with the supervisory and
regulatory framework.
The Group supports open communication (meetings, consultation etc.)
with government and regulators in order to facilitate data sharing and
issue resolution.
Suppliers and Partners
•
Cooperation based on
transparent procedures and
specified criteria to achieve
mutually beneficial
agreements.
•
Communication with third-
party partners, to investigate
further tailor-made business
offerings.
The Group provides comprehensive and transparent information in
procurement processes to its suppliers, ensuring compliance with legal
requirements in labour and environmental matters, respecting human
rights and stimulating the demand for socially responsible products and
services.
On top, Eurobank implements an electronic tendering system
complemented by a supplier evaluation platform and procedure,
ensuring transparency and efficiency in supplier selection.
The Group’s understanding of the interests and views of its key stakeholders is shaped through its comprehensive stakeholder
engagement and DMA processes. By engaging with a wide range of stakeholders, including customers, employees, investors, business
community, suppliers and partners, regulators, and civil society, the Group gathers crucial insights into their expectations regarding
issues such as environmental sustainability, governance, human rights, and access to financial services. These insights are integrated
into the Group’s strategy and business model, ensuring that its actions align with stakeholder needs. Additionally, the materiality
assessment process identifies the actual and potential positive, as well as negative impacts of the Group’s activities on the
environment and society, guiding its decision-making and ensuring long-term value creation for all stakeholders.
Views and interests of affected stakeholders
The views and interests of affected stakeholders with regard to the Group’s sustainability -related impacts are communicated to the
Board of Directors, Board Committees, Management Committees and functions through a structured process. Stakeholder
engagement is integral to the Group’s materiality assessment, and relevant insights gathered from both internal and external
stakeholders are reviewed by the Sustainability Management Committee. These committees oversee the sustainability strategy and
ensure that stakeholder concerns regarding sustainability impacts are incorporated into the Group’s decision-making processes. The
Board of Directors (BoD) is informed about the interests and views of stakeholders through the presentation of the results of the
DMA, which includes an evaluation of the impacts identified by both internal and external stakeholders. The BoD is regularly updated
on the progress and outcomes, ensuring that stakeholder feedback is integrated into the Group’s strategy and operations.
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1.4.4
Material impacts, risks and opportunities and their interaction with strategy and business model [SBM-3]
The Group has conducted a comprehensive materiality assessment to identify its material impacts, risks, and opportunities in relation
to sustainability. This process allows the Group to prioritise the sustainability factors most pertinent to its strategy, business model,
and resource allocation. By identifying and assessing these key factors, the Group ensures that its sustainability initiatives are aligned
with regulatory standards and long-term business objectives. The business model of the Group is primarily focused on delivering
financial services to individual, corporate, and institutional clients. Therefore, the material impacts, risks, and opportunities identified
are concentrated in the provision of such services. The table below outlines the outcomes of the Group's impact materiality
assessment, presenting the identified material impacts:
Sustainability matter
Description
Positive/
Negative
Type of
Impact
Location in
the value
chain
Time-
horizon
Environmental
E1 Climate
change
Energy
Group contributes to climate change through its in-house
operations that contribute to the release of emissions.
Negative
Actual
Own
operations
Short-
term
Climate change
mitigation
Group implements a robust climate change mitigation
strategy aiming to minimise the impact of its portfolio to
climate change.
Positive
Actual
Own
operations,
Downstream
Long-term
Group engages with external stakeholders to promote
sustainability issues through various engagement
mechanisms.
(previously categorized under the ‘Capacity Building to
Promote Sustainability Issues to External Stakeholders’)
Positive
Actual
Downstream
Mid-term
Group’s portfolio faces negative impacts due to the
evolving nature of a climate change mitigation strategy.
Negative
Actual
Own
operations,
Downstream
Long-term
Capacity Building to promote sustainability issues to
external stakeholders is mostly limited to corporate
clients.
(previously categorized under the ‘Capacity Building to
Promote Sustainability Issues to External Stakeholders’
topic)
Negative
Potential
Downstream
Mid-term
Climate change
adaptation
Group actively contributes to GHG reduction ambitions
and targets, set by the EU, regulations, central
governments, and other bodies, through its sustainable
financings and integration of climate risk in the risk
management framework.
Positive
Actual
Own
operations,
Downstream
Long-term
Group's business strategy may encompass the
continuation of financing to carbon-intensive sectors.
Negative
Potential
Own
operations,
Downstream
Long-term
Entity-
Specific
Sustainable
financing and
investment
offerings
Group provides sustainable finance products and services
that promote green and social investments and incentivise
improvement of its clients’ sustainability performance.
Positive
Actual
Downstream
Long-term
Increase market awareness and provide services that
enable customers to make better informed decisions on
sustainable financing solutions.
(previously categorized under the ‘Engagement with
clients to support their sustainability transition’)
Positive
Actual
Downstream
Mid-term
Engagement with clients on sustainability issues is limited
to legal entities.
(previously categorized under the ‘Engagement with
clients to support their sustainability transition’)
Negative
Potential
Downstream
Mid-term
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Sustainability matter
Description
Positive/
Negative
Type of
Impact
Location in
the value
chain
Time-
horizon
Integration of
Sustainability in
risk
management
Group evaluates the impact of climate scenarios on the
resilience of its counterparties, resulting in the timely
identification of climate transition financing opportunities
for its clients.
Positive
Actual
Downstream
Mid-term
The ESG / climate risk assessment may require additional
effort by the clients in order to provide required ESG data
and may result in additional conditions to comply with for
financial agreements.
Negative
Potential
Downstream
Mid-term
E4
Biodiversity
and
ecosystem
Direct impact
drivers of
biodiversity loss
Group’s portfolio may negatively affect biodiversity and
ecosystems, including impacts arising from climate
change, pollution, and land use.
Negative
Potential
Downstream
Long-term
Social
S1 Own
workforce
Own Workforce
and Working
Conditions
Group’s operations generate direct, indirect, and induced
jobs across its value chain, provide competitive wages and
benefits in alignment with its remuneration policy, while
also incorporating Employee Engagement surveys to
quantify employees' opinions on well-being.
Positive
Actual
Own
operations
Short-
term
Group supports employees’ well-being through providing
satisfying and high-quality working conditions, including
adequate workspace and respect of privacy.
(previously, categorized under the ‘Other work-related
rights’)
Positive
Actual
Own
operations
Short-
term
Equal
Treatment and
Opportunities
for All
Group puts into action internal management systems and
initiatives that improve employees’ ability to live free from
gender / sexual / ethnic / racial discrimination and ageism.
Positive
Actual
Own
operations
Short-
term
S4
Consumers
and End-
users
Social inclusion
of consumers
and/or end-
users
Group provides specific products and services, including
microfinance, that promote a discrimination free
environment, equal opportunities, inclusion and diversity.
Positive
Actual
Downstream
Short-
term
Information-
related impacts
of consumers
and/or end-
users
Group provides to clients access to accurate, relevant and
high-quality secured information, fostering transparency
and promoting the principles of responsible banking.
Positive
Actual
Downstream
Short-
term
Governance
G1 Business
Conduct
Corporate
culture
Group achieves positive impacts by implementing
operational practices and initiatives that improve
stakeholders’ ability to benefit from effective,
accountable, and inclusive institutions, thereby promoting
business ethics and integrity.
Positive
Actual
Own
operations,
Upstream,
Downstream
Short-
term
Protection of
whistleblowers
Group's commitment to whistleblower protection
positively impacts society, employees, customers, and
shareholders, setting a precedent for ethical behavior and
fostering a secure environment where misconduct is
timely identified and stopped.
Positive
Actual
Own
operations
Short-
term
Corruption and
bribery
Group’s commitment to corporate integrity is
strengthened through the implementation of robust anti-
corruption and anti-bribery policies, promoting a culture
of transparency and ethical behaviour.
Positive
Actual
Own
operations
Long-term
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Sustainability matter
Description
Positive/
Negative
Type of
Impact
Location in
the value
chain
Time-
horizon
Entity
Specific
Data security
and customer
privacy
Implementation of internal management systems and
initiatives that protect stakeholders' data privacy.
Positive
Actual
Own
operations,
Downstream
Mid-term
Improper implementation of established cybersecurity
systems and processes results in incidents of data breach
and leaks of personal data.
Negative
Potential
Own
operations,
Downstream
Mid-term
For the fiscal year 2025, Eurobank Group did not provide specific financial figures regarding the current financial effects of material
risks and opportunities. The Bank has opted for a phased-in approach to report these anticipated financial effects, aligning with the
initial reporting period requirements under the European Sustainability Reporting Standards (ESRS).
The table below outlines the outcomes of the Group's financial materiality assessment, presenting the identified risks and
opportunities:
Sustainability matter
Description
Risk/
Opportunity
Location in
the value
chain
Expected time
horizons for
anticipated
financial effects
Environmental
E1
Climate
change
Climate
change
adaptation/
mitigation
Meeting climate objectives linked to legal, regulatory and other
stakeholders’ requirements for the Group’s clients, entails the
opportunity for the Group to finance the transition of its clientele.
Opportunity
Own
operations,
Downstream
Long-term
The actions required by the Group’s clients to address climate
change mitigation and adaptation requirements relating to
impacts deriving from climate change may impact the Group’s
credit risk.
Risk
Own
operations,
Downstream
Long-term
Entity
Specific
Sustainable
financing and
investment
offerings
Promoting green and social investments in line with requirements
to support climate transition and in response to changing
consumer preferences enhances the Group’s brand reputation,
attracting sustainability conscious investors.
Opportunity
Own
operations,
Downstream
Long-term
Evolving market preferences and regulatory shifts may impact the
demand for sustainable finance, posing risks to the Group’s
existing product offerings
Risk
Own
operations,
Downstream
Long-term
Integration of
Sustainability
in risk
management
Integrating Sustainability in risk management in response to
evolving regulatory requirements and business needs, improves
the Group’s resilience to sustainability-related risks, safeguarding
the Group against potential financial losses, strengthening its
overall risk management framework.
Opportunity
Own
operations,
Downstream
Mid-term
Failure to adequately address sustainability requirements and/or
manage respective risks could hamper Group’s market perception
and be a driver for other risks, such as credit risk.
Risk
Own
operations,
Downstream
Mid-term
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Sustainability matter
Description
Risk/
Opportunity
Location in
the value
chain
Expected time
horizons for
anticipated
financial effects
E4
Biodiver
sity and
ecosyst
em
Direct impact
drivers of
biodiversity
loss
Biodiversity loss due to clients’ operations may lead to financial
and reputational damage.
Risk
Downstream
Long-term
Social
S1 Own
workfor
ce
Own
Workforce
and Working
Conditions
Demonstrating commitment to exemplary working condition
expectations, such as offering adequate salaries, promoting work-
life balance, and ensuring workplace safety, can attract and retain
employees.
Opportunity
Own
operations
Short-term
Non-compliance with the modern workplace expectations such as
good working conditions, adequate salaries, and workplace safety,
can affect employees' motivation and performance, leading to
decreased productivity.
Risk
Own
operations
Short-term
S4
Consum
ers and
End-
users
Social
inclusion of
consumers
and/or end-
users
Contributing to financial inclusion aligns with social impact goals,
positively impacting brand reputation and offering financing to
underserved populations, such as students and geographically
isolated communities.
(previously categorized under ‘Financial Inclusion’)
Opportunity
Downstream
Mid-term
Entity
Specific
Fostering
Innovation
Meeting evolving customer expectations and modern lifestyle
needs through utilising digital tools and innovative services can
improve customer engagement.
Opportunity
Own
operations
Short-term
Rapid technological development in the banking sector may pose
competitive threats and risks if the Group fails to adapt and
innovate at the same pace.
Risk
Own
operations
Mid-term
Governance
G1
Busines
s
Conduct
Corporate
culture
Heightened investor and community expectations for sustainable
banking may trigger misleading disclosures on sustainability
achievements (greenwashing), that could damage the Group’s
reputation, leading to a decline in market share.
Risk
Own
operations,
Upstream,
Downstream
Mid-term
Entity
specific
Data security
and customer
privacy
Demonstrating compliance with data protection laws and privacy
regulations can boost the Group’s reputation, attracting new
customers.
Opportunity
Own
operations,
Downstream
Mid-term
Growing cybersecurity threats and cyber attacks targeting financial
institutions and their customer data may compromise the Group’s
systems, networks and sensitive information, leading to
operational disruptions and reputational harm.
Risk
Own
operations,
Downstream
Mid-term
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Double materiality matrix:
1
This double materiality matrix is an illustrative approach of the assessment results.
1.5
Materiality analysis and results according to the concept of Double Materiality
1.5.1
Description of the processes to identify and assess material impacts, risks and opportunities [IRO-1]
Materiality assessment is conducted through a comprehensive process that aims to identify, assess, prioritise and monitor both
potential and actual impacts on people and the environment, as well as risks and opportunities that may in turn have a financial effect
on the organisation.
To enhance efficiency and ensure full alignment with ESRS requirements, the materiality assessment process was refined this year by
merging related topics under common categories. Material topics were identified using the same methodology as last year, with
enhancements to streamline the Double Materiality Assessment (DMA) and improve stakeholder feedback. Certain topics were
merged under ESRS categories for clarity: Capacity Building under Climate Change (E1); workforce-related rights under Own workforce
and working conditions (S1); Accessibility and Financial inclusion under Social Inclusion (S4); and client engagement under Sustainable
financing. Impacts of merged topics remain within their new categories, and if any impact is material, the entire topic is considered
material.
Phase 1 – Understanding of the business, value chain & related activities
The first step is to understand the Group’s key business segments and partners influenced by and influencing those operations. Credit
institutions are complex entities that engage in a wide range of activities, varying significantly in both scale and scope. To effectively
evaluate these activities and include them within the context of DMA, value chain boundaries were established. Boundaries are
applied to the upstream side of value chain, that are limited to direct Suppliers, as well as to the downstream side which includes the
Group’s customers. The focus areas for the materiality assessment are identified and prioritised based on the potential significant
IROs. Business activities and partners are categorized based on their role in the value chain by identifying whether they operate
upstream, downstream, or within own operations.
The significant activities across Eurobank’s value chain have been systematically mapped to relevant ESRS Sectors as part of an
extensive value chain analysis. This mapping encompassed both upstream and downstream activities, along with Eurobank's own
operations, while carefully considering the interconnections between ESRS, rating agencies and industry specific standards. For this
purpose, the methodologies established by the SASB Materiality Map and the MSCI ESG Industry Materiality Map are utilised as
foundational tools to identify Sustainability issues. Expert judgment is applied throughout this process to ensure that the mappings
are accurate and relevant. In the identification of potentially material sub-topics a peer analysis of major Greek systemic banks and
foreign banks operating predominantly within the EU was also incorporated. The Risk Identification and Materiality Assessment
(RIMA) Framework was also utilised in the overall process. RIMA enables Eurobank to systematically build its risk inventory by
identifying and evaluating both current and potential risks. During 2025, the Group further enhanced the RIMA process through
targeted methodological improvements and a more granular sectoral breakdown, reflecting the relative significance and impact of
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each sector on Eurobank’s Sustainability Strategy, particularly in relation to its Net Zero aspirations. Moreover, the Group also
expanded the framework to explicitly incorporate social and governance risks, thereby extending the risk inventory and ensuring a
more holistic consideration of sustainability risks.
Phase 2 – Stakeholder engagement and identification of IROs
The materiality assessment process, in the second phase, included comprehensive consultation with affected stakeholders to
understand how they may be impacted by the organisation's activities. The affected stakeholders’ engagement is central to the
materiality assessment process and therefore it is critical to gather and assess diverse stakeholder perspectives to build a balanced
and comprehensive set of impacts, risks, and opportunities (IROs). Eurobank recognises the importance of due diligence processes
and thus plans to develop such processes and utilise its outcomes to inform the materiality assessment in the future. Through
stakeholder engagement, a wide range of diverse perspectives is gathered to identify and assess the full spectrum of impacts, risks,
and opportunities (IROs). Eurobank considered its stakeholder groups as well as the ESG experts and classified them in the following
3 categories:
i.
Primary/Affected stakeholders,
ii.
Secondary stakeholders,
iii.
ESG Experts
The stakeholder engagement for impact materiality involved identifying and categorizing stakeholders into two main groups: Internal
Stakeholders (Board of Directors, Senior Management, and Employees) and External Stakeholders (Business Community, Civil Society,
Customers and Clients, Suppliers and Partners, Investors and Shareholders, and Government and Regulators).
Internal Stakeholder Engagement
This year, survey questionnaires were conducted anonymously. An updated and extended impact materiality questionnaire was
distributed to Eurobank and its subsidiaries within the reporting perimeter.
External Stakeholder Engagement
Building on this year’s impact materiality assessment and in line with Eurobank’s commitment to stakeholder inclusiveness and
transparency, a dedicated focus group session was conducted with client representatives. This interactive session enabled clients to
provide real-time input on material topics, further strengthening trust and ensuring that client perspectives are directly reflected in
the assessment process. The responses from this year’s client focus group have been incorporated as an additional input to the
materiality assessment, alongside responses from all external stakeholder groups collected in the previous year, ensuring a more
comprehensive and up-to-date reflection of stakeholder perspectives. Notably, there was no overlap between clients participating
this year and those in the prior year’s survey.
In the context of impact materiality ("inside-out" perspective) causal links between Eurobank’s and its value chain’s practices and
their impacts on the environment and society were assessed. First, the topics are contextualized to explain why they are relevant to
Eurobank and its value chain from an impact perspective. For this purpose, Eurobank considered its value chain activities, prior year
reporting, as well as other sources (e.g. peers, indices). Then, for those that are deemed relevant, the impacts on society or the
environment are described. Finally, the impacts are classified as:
●
actual or potential,
●
negative or positive impacts on people or the environment,
●
over the short, medium and long-term time horizon.
Impacts arising from Eurobank's operations are considered negative, without factoring in the potential effectiveness of any mitigation
measures that may be implemented.
Regarding financial materiality Eurobank engaged with internal stakeholders, ensuring representation from across the organisation,
to assess risks and opportunities. The primary method for stakeholder engagement was through dedicated focus groups, designed to
evaluate the potential risks and opportunities associated with sustainability. Sustainability risks and opportunities were assessed
based on their likelihood of occurrence and the potential magnitude of their financial effects over the short, medium, and long term
time horizons.
Risks and opportunities are associated with financial materiality ("outside-in"). First, the topics are contextualized to explain why they
are relevant to Eurobank and its value chain from a financial perspective (i.e. from a risk and/or opportunity perspective). For this
purpose, the identification of impacts was utilised as a starting point, since the financial materiality assessment benefits from the
outcome of the impact materiality assessment. Eurobank considered its value chain activities, prior year sustainability reporting (e.g.
Pillar 3, UNEP FI), as well as other sources (e.g. peers, MSCI, etc.). Then, for those that are deemed relevant, the risks and/or
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opportunities are described in the short, medium, and long-term time horizon in line with ESRS definition. The analysis is risk-based
and hence opportunities are identified only when there is a direct business opportunity linked to a subject that does not result from
mitigating a risk. To ensure alignment with Eurobank’s existing risk management framework, the identification process incorporated
relevant inputs from the RIMA process, which provides a structured approach to assessing and prioritising risks. This integration helps
maintain consistency between the identification of material topics and the Group’s broader risk governance practices.
Finally, the draft list of IROs was subject to multiple iterations through discussions with key internal stakeholders involved in the
broader financial risks and opportunities identification process in Eurobank.
Phase 3 – Assessment of IROs
After having identified IROs, both an impact and a financial materiality assessment took place in the third phase of the process,
whereby each of the impacts, risks and opportunities are scored on predefined scales for severity and likelihood, as appropriate.
A sustainability matter is material from an impact perspective when it pertains to the Group’s material, actual or potential, positive
or negative impacts on people or the environment (environmental, social and governance matters) over the short, medium and long-
term time horizons. It includes impacts connected to Eurobank’s own operations and value chain, including through its products and
services, as well as through its business relationships. Impacts are assessed based on the following criteria:
●
Severity,
o
Scale:
o
Scope:
understood as the extent of environmental damage or a geographical perimeter. In the case of impacts on people, the
scope may be understood as the number of people adversely affected; and
o
Irremediable character:
environment or affected people to their prior state.
●
Likelihood
The significance of positive impacts is assessed by stakeholders, by considering the scale and scope of impacts, whereas the severity
of negative impacts was assessed by considering their scale, scope and irremediable character. For the assessment of potential
impacts, the likelihood factor is also considered. The qualitative thresholds for impact assessment were established by applying
experts’ judgment, in addition to the application of quantitative thresholds. Consequently, impacts (positive and/or negative) with an
impact materiality score exceeding these thresholds were classified as material.
The financial materiality assessment corresponds to the identification of information that is considered material for primary users of
general-purpose financial reports in making decisions relating to providing resources to the entity. Risk and Opportunities are
assessed based on severity and likelihood. Similarly to the impact materiality assessment, Eurobank developed a scoring mechanism
by applying thresholds as cut-off points. Eurobank performed the assessment of risks and opportunities, by engaging internal
stakeholders through workshops with experts from Eurobank’s key business units. The outcome of stakeholder engagement was a
list of scored risks and opportunities.
Phase 4 – Materiality overview
In the final step of the process, the Group undertook a comprehensive analysis of the collected data, prioritising impacts, risks and
opportunities (IROs) based on the scores obtained through structured questionnaires (Impact Materiality assessment) and targeted
focus group regarding corporate clients (Impact Materiality assessment) and (Financial Materiality assessment). Applying these
scoring mechanisms allows to further separate material and non-material impacts, risks and opportunities (IROs) and topics. A topic
is material if it scores ‘high’ from an impact (positive, negative and/or both) and/or financial perspective (risk, opportunity and/or
both). Materiality thresholds classify topics as material in terms of impact materiality, financial materiality or in case of both, double
materiality. The IROs assessed to be material are then grouped and mapped to a topic/sub-topic in order to report according to the
corresponding Disclosure Requirements of the relevant topic. The SMC oversees the Double Materiality Analysis (DMA) process and
approves the proposed contents of the Sustainability Statement that derive from the results of the DMA., in alignment with the
Committee’s Terms of Reference.
Strategic implication
The DMA strengthens the Group’s commitment to responsible risk management, fostering robust corporate governance practices
while advancing sustainability goals. The DMA process enables Eurobank to effectively manage and leverage risks and opportunities
in a way that not only supports its financial performance but also contributes to positive societal and environmental impacts.
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Risk management is a key component of the Group's operations to achieve its strategic and business objectives. As such, the Group
has put in place effective mechanisms to identify, monitor, and assess risks promptly, evaluating their potential impact on the
attainment of corporate objectives. The Risk Identification and Materiality Assessment (RIMA) process at Eurobank plays a crucial
role in managing effectively risks preventing significant impacts on the Group's financial performance, capital, liquidity, and business
objectives. This proactive approach helps identify emerging risks, especially those related to the interconnected nature of
sustainability risks, which are integrated into the Group's broader risk management framework. Given the increasing recognition of
both financial and non-financial impacts, Eurobank takes a holistic approach to manage sustainability risks, aligning these
considerations with other risk types within the organisation.
Eurobank places strong emphasis on managing social and governance risks as part of its sustainable business strategy. The Group has
adjusted its business model, strategy and processes, as well as its financial planning, to address these risks effectively. Social aspects
are assessed through Eurobank’s ESG Risk Assessment process, which evaluates clients at both obligor and transaction level and
incorporates topics such as occupational health and safety, community relations, diversity and inclusion. Similarly, governance
considerations are embedded in the same process, covering areas such as business ethics, anti-corruption, and corporate governance
practices. Through the implementation of robust internal governance arrangements and processes to mitigate social and governance
risks, Eurobank ensures that its strategic focus on sustainability not only helps the Group remain resilient and adaptable in a fast-
changing business environment but also recognises the importance of identifying material opportunities as a crucial source of
innovation and value creation.
Eurobank Group early adopted the European Sustainability Reporting Standards (ESRS) in 2023. In 2024, the Group conducted its
Double Materiality Assessment (DMA), and in 2025, leveraging the previous year’s results, it further enhanced and refined the DMA
analysis. Eurobank identified, assessed, prioritised and validated the sustainability impacts arising from its activities and assessed risks
and opportunities that may have material financial influence on Eurobank, throughout its value chain. For the current reporting year,
the Group continues to adhere to ESRS, ensuring alignment with all applicable regulatory requirements.
For more information regarding the internal control procedures for the identification and assessment of material impacts, risks, and
opportunities, please refer to: 1.3.2 Information provided to and sustainability matters addressed by the undertaking's administrative,
management and supervisory bodies [GOV-2].
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2. Environmental Information
2.1 Disclosures pursuant to Taxonomy Regulation
Disclosure pursuant to Article 8 of EU of Taxonomy Regulation (Regulation 2020/852)
The EU Taxonomy Regulation (EU) 2020/852 of the European Parliament and of the Council) was adopted in 2020 by the European
Parliament and represents an important step for the EU to achieve the Paris Agreement climate neutrality goals. It sets out the criteria
to establish a common classification system for sustainable economic activities. The EU Taxonomy Regulation determines whether
an economic activity is environmentally sustainable and requires financial and non-financial undertakings subject to the Corporate
Sustainability Reporting Directive (CSRD) to disclose the alignment of their activities. Separate disclosures requirements and extensive
criteria are in place for financial and non-financial undertakings under Article 8 of EU Taxonomy Regulation Delegated Act
(Commission Delegated Regulation (EU) 2021/2178).
In accordance with the requirements of the EU Taxonomy Regulation and related Delegated Acts, this report includes the alignment
of Eurobank’s activities with all six environmental objectives as set out in the Regulation:
a.
Climate change mitigation
b.
Climate change adaptation
c.
Sustainable use and protection of water and marine resources,
d.
Transition to a circular economy,
e.
Pollution control and prevention, and
f.
Protection and restoration of biodiversity and ecosystems.
Since Eurobank’s eligibility and alignment calculations rely on the prior-year Taxonomy disclosures of both financial and non-financial
counterparties, a structural one-year time lag is inherent in the data. As non-financial undertakings are required to report alignment
for the additional environmental objectives only from their 2024 disclosures (published in 2025), the Group applies a “best available
data” approach, consistent with regulatory expectations for managing transitional data.
Credit institutions publish the Green Asset Ratio (GAR), which determines the extent to which the Group’s assets finance and are
invested in taxonomy-aligned economic activities, that is the ratio of the Group's taxonomy-aligned assets to covered assets (total
assets excluding exposure to sovereigns, central banks and the trading portfolio). Moreover, as required by the EU Taxonomy
Regulation, activities must meet the specific taxonomy criteria and ensure that they cause no significant harm to any of the other
environmental objectives (DNSH) and meet minimum social safeguards (MSS), to be categorized as taxonomy-aligned. Additional KPIs
are required regarding the off-balance sheet exposures and specifically for financial guarantees to financial and non-financial
undertakings (FinGuar KPI) and assets under management (AuM KPI).
Simplification and Amendments to Article 8 Disclosures under Regulation (EU) 2026/73
On 4 July 2025, the European Commission adopted, as part of the Omnibus Delegated Act, the Commission Delegated Regulation (EU)
2026/73, which was published in the Official Journal on 8 January 2026, introducing targeted amendments aimed at simplifying the
Article 8 disclosure framework. A key modification concerns the further postponement of the applicability of the “Fees & Commissions
(F&C) KPI” and the “Trading Book KPI”, deferring their mandatory implementation from 2026 to 1 January 2028.
In addition to deferring specific requirements, under Article 4, undertakings may continue to apply the disclosure rules of Delegated
Regulations (EU) 2021/2178, (EU) 2021/2139 and (EU) 2023/2486, when preparing their Sustainability Statement disclosures for the
2025 financial year. Eurobank, therefore makes use of this transitional option upon preparing its 2025 Taxonomy disclosures. The
transitional application ensures continued adherence to the prevailing supervisory expectations for Article 8 disclosures, while
enabling Eurobank to align its reporting practices with the updated regulatory framework in subsequent reporting cycles.
Furthermore, selecting this transitional option does not alter the deferral of the Fees & Commission KPI and the Trading Book KPI.
Even where a credit institution chooses to apply the original disclosure rules for its 2025 reporting cycle, it is not required to publish
the Fees & Commission or the Trading Book KPIs, as clarified in the Draft Commission Notice of December 2025. As a result, and in
line with the applicable transitional provisions and supervisory guidance, Eurobank will not publish the Fees & Commission KPI or the
Trading Book KPI for the FY2025 reporting period.
Integration of Taxonomy in the Group’s business strategy, operating model, products and customers
In line with best established practices, the Group has integrated the requirements of the EU Taxonomy Regulation within its processes
with key roles consisting of:
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●
client engagement in the context of ESG Risk Assessment and Sustainable Finance Assessment,
●
establishment and monitoring of sustainability risk and EU Taxonomy-related KPIs to ensure alignment with risk limits and
sustainable financing strategy/targets as well as
●
the development of relevant disclosures.
As part of its sustainability strategy, the Group is implementing initiatives that will, among others, enable it to increase the share of
taxonomy-aligned assets in the coming years:
●
Development of sectoral near, mid and long-term financed emissions reduction pathways, in line with science-based
decarbonisation pathways, in alignment with Eurobank’s Net Zero commitments and Transition Plan.
●
Performing perimeter analysis of Taxonomy-related sectors, counterparties and financings affecting the GAR and developing
action plans for increasing Taxonomy -aligned financing in the future.
●
Further integrating sustainability risks and sustainable financing considerations in the business planning process (e.g.,
project budgeting and prioritisation), to reflect the Group’s business strategy and relevant targets.
Committed to being transparent about its approach and to ensure that decision-making is in line with best practices in environmental
protection and sustainability, Eurobank has developed guiding frameworks, defining the approach and criteria for classifying its
financing and investing activities as sustainable:
The Sustainable Finance Framework
Through its Sustainable Finance Framework (SFF), Eurobank is able to classify sustainable lending solutions offered to its clients,
specifying the applied classification approach and the activities defined as eligible to access sustainable financing. The purpose of
establishing the SFF is to provide a clear and comprehensive methodology for classifying, monitoring, and reporting sustainable
financing in line with the Financed Impact Strategy. The SFF has drawn from international best practices and is based on two key
guiding frameworks: The International Capital Market Association (ICMA) principles on sustainable financing (Green Bond Principles,
Green Loan Principles and Sustainability-linked Bond Principles) and the EU Taxonomy. Eurobank will closely monitor the
developments of the EU Taxonomy, to update its SFF as relevant. The SFF defines two levels of transaction alignment:
●
SFF alignment - Fulfilment of criteria dictated by established market practice
●
EU Taxonomy alignment - Fulfilment of criteria associated with each of the EU Taxonomy assessment steps (substantial
contribution, DNSH, MSS)
Through the dedicated purpose financing approach (i.e. where the use of proceeds is known) the Group assesses and classifies
financings / transactions as “Not SFF aligned”, “SFF aligned” or “SFF & EU Taxonomy aligned”.
For general purpose financing / transactions (i.e. where the use of proceeds is not known) the SFF defines two other approaches:
●
Company Business mix - Financing to companies that fulfil the eligibility green/ social criteria and derive most of their
revenues from eligible activities.
●
Sustainability-linked loans - Financing linked to ambitious and predefined Sustainability Performance Targets (SPTs).
To adequately embed sustainable financing and the SFF in its practices, the Group has developed governance structures and functions
as well as a digital tool (Framework SFF assessment tool) that facilitate the day-to-day implementation of the SFF.
The SFF assessment tool supports the process of assessing the financing / transactions against the criteria defined in the SFF and the
EU Taxonomy. Through the SFF assessment tool, users categorise financing to the applicable eligible activity and are guided through
the assessment steps which involve substantiating alignment with the criteria of each step, including Taxonomy alignment assessment
(TSC, DNSH criteria, MSS).
Approach for the preparation of disclosures relating to Article 8 of the Taxonomy Regulation
The preparation of mandatory disclosure in taxonomy eligibility and alignment is based on the prudential consolidation for the Group.
The consolidation is in accordance with the supervisory reporting of institutions according to the Commission Implementing
Regulation (EU) 2021/451 (FINREP).
The Group, upon reviewing its business activities, to map Taxonomy reporting requirements with its core activities, provides the KPIs
and other disclosure requirements as laid down in the EU Taxonomy Regulation and the EU Taxonomy Regulation Delegated Act.
For 2025, credit institutions shall disclose:
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●
The Green Asset Ratio (GAR) covered on-balance sheet assets and the breakdown by environmental objective and by type
of counterparty.
●
The percentage of their total assets that are excluded from the numerator and the denominator of the GAR.
●
A complementary ratio on the level of association with Taxonomy-aligned economic activities of off-balance sheet
exposures. These exposures include financial guarantees granted by the financial institution and assets under management.
As per EU Taxonomy Regulation Delegated Act, the calculation of KPIs for off-balance sheet exposures shall consider 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 shall be excluded from that calculation.
The application of the EU Taxonomy differs for general purpose financing and specific purpose financing (i.e. ‘known use of proceeds’).
General purpose financing
For general purpose financing, the Group uses counterparties’ reported eligibility and alignment information from the latest published
taxonomy information. Specifically for corporate counterparties, the Group uses actual information that has been disclosed by its
counterparties reporting under CSRD in 2024.
To determine which companies are subject to CSRD, an assessment is carried out to determine that all of the following criteria are
met; a) if the country of incorporation of the counterparty is in the EU, and b) whether the counterparty’s is either a listed company,
a credit institution, or an insurance company, and c) whether the entity’s net revenue exceeds €50m or its total assets exceed €25m
and d) the counterparty has over 500 employees.
The identification of counterparties subject to CSRD has been conducted through Eurobank’s internal customer segmentation
processes within the core banking systems, supplemented by verified external data sources, to ensure accurate classification for EU
Ta
xonomy eligibility and alignment assessments.
The Taxonomy eligible and aligned assets presented include the reported eligibility and alignment of non-financial and financial
counterparties, weighted to the Group’s exposures.
Financial and non-financial undertakings that do not meet the aforementioned requirements are identified as non-subject to CSRD.
Undertakings that are not required to report under the EU Taxonomy regulation (non-CSRD) are not included in the calculation of
eligible and aligned assets since estimations are not allowed in mandatory reporting. Assets of non-CSRD counterparties, derivatives,
hedge accounting and on-demand interbank loans are only included in the denominator of the Green Asset Ratio (GAR).
Specific purpose financing
For specific purpose financing where the use of proceeds is known, project-specific KPIs are used in the assessment of Taxonomy-
eligibility and Taxonomy -alignment to the extent that Taxonomy eligibility and Taxonomy alignment can be demonstrated for the
underlying transaction. As part of Eurobank’s Sustainable Finance assessment process, standalone dedicated purpose financings are
assessed to evaluate alignment with the EU Taxonomy requirements. The assessment is carried out, based on available documentary
evidence provided by the counterparties, required to ensure adherence to EU Taxonomy and based on applicable National Legislation
in specific financing cases (i.e. Resilience and Recovery Fund investments, which embedded the DNSH assessment).
Other matters
In relation to households, loans collateralised by residential real estate, loans granted for renovation purposes and loans granted with
purpose to finance the purchase of vehicles were assessed for taxonomy-alignment. The Group is also reporting its exposure to
economic activities related to fossil gas and nuclear energy according to Commission Delegated Regulation (EU) 2022/1214, which
amended the EU Taxonomy Delegated Act. Hence, the taxonomy-non-eligible nuclear energy related activities are included in the
denominator of Eurobank’s key performance indicators. The Group also uses the relevant templates included in the Delegated Act to
disclose information about nuclear and fossil gas related activities.
The Group’s approach for the disclosures prepared as of 31 December 2025 reflects its understanding and interpretation of the EU
Taxonomy requirements and is based on the best effort to adhere to the applicable regulations and new regulatory developments.
In accordance with the European Commission guidance published in December 2024 FAQs, no estimates were included in the
calculation of eligibility and alignment for mandatory disclosures presented.
The Group continues its work on implementing the EU taxonomy requirements and further enhancing its reporting methodology to
ensure transparency and completeness of the information disclosed as further robust information becomes available from
counterparties. For the Group’s processes to ensure data quality, please refer to the [“ESG data” section of management report].
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Results
The Group’s total GAR based on turnover and total GAR based on CapEx, as at year-end 2025, cover the six climate -related EU
environmental objectives and are presented in the summary below:
Summary EU Taxonomy KPIs
Million EUROS
Gross
carrying
amount
2025
Gross
carrying
amount
2024
Turnover KPIs
2025
Capex KPIs
2025
Turnover KPIs
2024
Capex KPIs
2024
Taxonomy-eligible assets
19,691
25.1%
22,458
28.6%
17,868
24.6%
19,408
26.7%
Taxonomy-aligned assets
3,013
3.8%
4,494
5.7%
1,908
2.6%
2,658
3.7%
Assets
GAR- Covered assets in both
numerator and denominator
33,154
29,506
Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
45,430
43,257
Total GAR assets
78,584
72,762
Total assets
108,691
102,567
Impairment for loans and
advances at amortised cost,
debt instruments and other
adjustments, according to EU
taxonomy methodology
(715)
(1,417)
Total assets according to the
consolidated balance sheet
107,976
101,150
The increase in the Group’s Taxonomy-aligned assets from FY2024 to FY2025 is primarily attributable to two factors. Obligors and
investees reported significantly enhanced EU Taxonomy disclosures in prior year, particularly with respect to CapEx alignment,
reflecting a more complete identification of EU Taxonomy economic activities. As a result, the alignment ratios applied to
general-purpose financing improved materially compared to the prior year. Moreover, during FY2025 the Group provided substantial
new disbursements under known use-of-proceeds structures, mainly relating to the financing of Renewable Energy Sources (RES)
projects that meet the technical screening criteria for substantial contribution to Climate Change Mitigation. These developments,
combined with the expansion of the eligible asset base and refinements in internal classification processes, contributed to the
year-on-year increase in the Group’s GAR alignment.
The reported main and additional KPIs calculated on 31 December 2025 for the Group, including the reporting templates as set out
in the EU Taxonomy Regulation, EU Taxonomy Regulation Delegated Act and the European Commission FAQs, are presented in the
Appendix.
Moreover, comparative information for 2024 is also reported, which has been adjusted to reflect newly issued guidance and
interpretations of the existing EU taxonomy Regulation. The adjustments aim to ensure that our disclosures are fully aligned with the
latest regulatory expectations, thereby enhancing the transparency and consistency of our reporting.
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2.2
Climate change [E1]
2.2.1 Strategy
Transition plan for climate change mitigation [E1-1]
The Group supports the transition towards a sustainable economy and considers sustainability and addressing climate change as an
opportunity. A key strategic objective is to adapt the business and operation in a way that addresses climate change challenges,
accommodates social needs within its business model and safeguards prudent governance for itself and its counterparties, in
accordance with supervisory initiatives, and following international standards and best practice. Following the completion of the
onboarding of Hellenic Bank during 2024, along with the upskilling achieved for the rest of international subsidiaries, the Group aims
to align all entities’ Sustainability Strategies to converge to a Group-wide Sustainability Strategy in both pillars.
Sustainability Strategy Structure
To this end, for the current reporting period, Eurobank is implementing its Sustainability Strategy, including targets and commitments,
along with two key pillars:
●
the Operational Impact Strategy, which refers to the impact arising from the Bank’s operational activities and footprint in
Greece, and the
●
Financed Impact Strategy, which refers to the impact arising from the Bank’s lending and investing activities to specific
sectors and clients.
Operational Impact Strategy: Objectives and Net Zero Targets
The Operational Impact Strategy defines the operational sustainability priorities and objectives. The strategy is deployed through
milestones and KPIs that support the annual and long-term targets set across multiple project streams, and key pillars spanning over
the next decade. The operational impact strategy is developed and deployed along three pillars, of which the environmental impact
is a key pillar which aims at minimizing negative impact of Eurobank’s operations to promote environmental stewardship with a clear
goal to attain climate neutrality.
The underlying target of the environmental impact pillar is the achievement of Net Zero emissions from Eurobank’s operations by
2033 for Scope 1 & 2 emissions and by 2050 for Scope 3 emissions, with 2019 as the baseline year. The action plan for achieving this
target and tracking the progress against it is informed by transition pathways that are aligned with the Paris Agreement target of
limiting global warming to 1.5°C.
Financed Impact Strategy: Sustainable Finance and Portfolio Alignment
The Group recognises that the most significant part of its impact on climate arises from the financing it extends to its clients.
Therefore, the second pillar of its Sustainability Strategy, Financed Impact Strategy, evolves around the following key components:
●
Sustainable financing: Development of strategies that will promote the green transition of the Group’s clients through
sustainable financing.
●
Portfolio alignment: Gradual alignment of the Group’s portfolio with sectoral transition pathways that are aligned with the
1.5°C climate transition scenario.
●
Net Zero strategy: Sectoral decarbonisation targets covering the Group’s lending portfolios, with phased target -setting up
to 2050.
The references to Eurobank’s Sustainability Strategy in this section relate to the Strategy currently in force during the 2025 reporting
period. In parallel, the Group is progressing the update of its Group Sustainability Strategy, which will build on the existing framework
and further strengthen the integration of sustainability across its operations and activities.
The core activity of the Group (banking services) is part of the EU Paris-aligned Benchmark activities. As part of the Pillar 3 disclosures,
the Group discloses the counterparties in its portfolio that are excluded from the Paris Aligned Benchmark (Consolidated Pillar 3
Report - 11.4.1 Template 1: Banking book - Climate Change transition risk: Credit quality of exposures by sector, emissions and residual
maturity). Information on how sustainability related performance, including climate related objectives, is incorporated into
remuneration and incentive schemes is provided in section “Integration of sustainability related performance in incentive schemes”
[ESRS 2 GOV 3].
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Decarbonisation Levers and Key Actions
In support of its transition plan for climate change mitigation, the Group has identified a set of decarbonisation levers and key actions
that underpin its overall strategy. In accordance with ESRS E1-3 (Climate change mitigation actions) and ESRS E1-4 (GHG emission
reduction targets), the specific details regarding the Group’s GHG emission reduction targets, the associated actions, and the
explanation of the decarbonisation levers—including planned changes in the product and service portfolio, the adoption of new
technologies, and measures across the value chain—are provided in the dedicated sections of this report:
Actions and resources in relation to climate change policies [E1-3]
Targets related to climate change mitigation and adaptation [E1-4]
Pathway to Net Zero and Sectoral Targets
Eurobank’s commitment to sustainability is at the heart of its strategic vision. Aligning with global climate goals and addressing the
urgent need to tackle climate change, it has committed to aligning the Group’s portfolio emissions with 1.5°C climate transition
pathways.
The following table presents key information regarding the emission reduction targets for the first 4 carbon-intensive sectors:
Sector
Boundaries
Scopes
covered
Target
Metric
Scenario
/
Pathway
Base
year
Baseline
value
Eurobank’s emission reduction targets
2030 target
2030
reduction
2025
Performance
2024
Performance
Power
generation
Fossil and RES
electricity
generators
1, 2
Intensity
tCO2e /
MWh
IEA NZE
2050
(2023
Update)
2023
244
220
-10%
199
(-18% vs
baseline)
193 (-22% vs
baseline
)
Oil and
gas
Mid /
Downstream
activities
1, 2
Absolute
tCO2e
IEA NZE
2050
(2023
Update)
2024
558
(100
indexed)
530
(95 indexed)
-5%
636
(+14% vs
baseline)
n/a (base
year)
Iron and
steel
Up / Mid /
Downstream
manufacturer
1, 2
Intensity
tCO2e / t
steel
IEA Net
Zero by
2050
(2021)
2023
0.37
0.33
-11%
0.30
(-19% vs
baseline)
0.42 (+14%
vs baseline)
Cement
Cement and
concrete
manufacturers
1, 2
Intensity
tCO2e / t
cement
IEA NZE
2050
(2023
Update)
2023
0.67
0.59
-12%
0.63
(-6% vs
baseline)
0.66 (-1% vs
baseline)
Power generation
Methodological approach
Boundary
The scope of this sector includes counterparties operating in the power generation sector and, more specifically, clients with power
generation activities from fossil fuels (lignite, oil, natural gas) and renewable energy (soler, wind, hydro etc.). The sectoral perimeter
excludes companies operating downstream the power generation value chain (transmission, distribution and trade).
Emissions coverage
The target covers Scope 1 and 2 GHG emissions, which account for the vast majority of the power generation footprint.
Decarbonisation scenario
Eurobank's emission reduction target for the power generation sector draws upon the trajectory outlined in the IEA NZE scenario,
aiming for substantial reductions in carbon emissions and the promotion of sustainable energy practices. The power generation sector
plays a crucial role in global efforts to mitigate climate change, accounting for a significant portion of GHG emissions. By adopting the
IEA NZE scenario as the reference transition pathway for the power generation sector, Eurobank aims to support the rapid
deployment of renewable energy sources (RES), such as wind, solar and hydroelectric power, while also supporting the stability of
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the energy transition through less carbon intensive energy generation technologies. Additionally, its target focuses on reducing
emissions from fossil fuel-based power generation through investments in energy efficiency measures, grid modernization and the
integration of clean technologies.
For this target, Eurobank has also considered the national plans to decarbonise the sector in the Group’s main countries of operation.
However, the driving force is Greece’s national plan, which can be found both in the Greek National Energy and Climate Plan (NECP)
and the National Climate Law. NECP sets an 82% target for the share of RES in the total domestic electricity production by 2030,
through increasing RES generation to 23.5 GW by 2030 (i.e. around a 150% increase from 2021). The rapid increase in the level of RES
penetration requires the development of different types of RES and reliable energy storage solutions. To this end, NECP foresees the
increase of onshore wind capacity by 65%, solar by 212% and pumped storage by 214%. It also includes the development of new
technologies, such as offshore wind (1.9 GW by 2030) and battery energy storage systems (3.1 GW by 2030). The Climate Law forbids
electricity generation from solid fossil fuels by 2028.
Eurobank’s sectoral approach
Eurobank recognises that a fully decarbonised power generation sector is the essential foundation of a net-zero energy system, which
will also play a key role to leading decarbonisation across all sectors, from transport and buildings to industry.
Electricity generation will need to reach net-zero emissions globally in 2040 and be well on its way to supplying almost half of total
energy consumption. This will require huge increases in electricity system flexibility, investments in new services and technologies
such as batteries, demand response and green hydrogen, while renewable energy technologies remain the key to reducing sectoral
emissions. A more electrified, renewables-based and efficient energy system brings clear environmental benefits as well as important
gains for affordability.
Eurobank’s financed emission intensity baseline sits below the sectoral pathway, at 244 kgCO2e/MWh, mainly due to the significant
share of financed RES production output in relation to fossil fuel-based production. Drawing from sources such as national and client-
specific investment plans, as well as the Group’s sectoral business plan, the Group has set the target to reduce the sectoral financed
emission intensity by 10% by 2030, which is above the respective pathway reference value.
This target is based on prudent projections about the timing and emission reduction effect of the key sectoral decarbonisation levers,
decommissioning of lignite and oil plants, and emission reduction investments of key counterparties as well as the Group’s additional
financing in renewable energy projects. Recognising that a key element in the sectoral transition is safeguarding the stability of the
energy supply, the Group will also continue considering financing projects in lower emitting power generation technologies, such as
Combined Cycle Gas Turbine (CCGT) power plants, in Greece and abroad.
While CCGT plants will add to the Group’s overall emission profile in the short-term, they are considered a critical component of the
energy transition, providing the necessary flexibility and reliability to support the integration of intermittent RES, and ensuring energy
security during the transition period. Their role is especially important in maintaining grid stability as legacy high-emission assets are
phased out. Looking beyond 2030, the Group is committed to aligning with more ambitious decarbonisation trajectories, potentially
exceeding the reference values of the pathway, reflecting its long-term vision for a sustainable and resilient energy system.
In 2025, the Group’s sectoral performance demonstrated a non-significant increase compared to 2024 performance (2025: 199 tCO2e
/ MWh, 2024: 193 tCO2e / MWh), with the overall sectoral intensity at 18% in relation to the 2023 baseline, and well below the
sectoral decarbonisation pathway of the IEA NZE 2050 scenario. The increase in 2025 is mainly driven by the financing to CCGT plants.
To reach its sectoral emission reduction target, Eurobank plans to further mobilise its strategy to finance the upgrade of energy
transmission and distribution systems, and promote innovative energy saving and storage technologies, in line with the NECP and its
ambitious energy efficiency targets by 2030. Eurobank’s commitment in supporting the increase in renewable energy share in the
total energy mix has been evident, with substantial year-on-year increase in RES project financing and an outstanding balance of over
€1.61 billion at the end of 2025. It will intensify even further its financing towards RES projects, conventional as well as emerging
technologies, contributing to the increase in RES share in the total energy mix and the country’s lignite phase out plan.
Oil and Gas
Methodological approach
Boundary
The target-setting focuses on counterparties engaged in:
•
Midstream activities – Transportation, storage and liquefaction of oil, natural gas or LNG.
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•
Downstream activities – Refining activity.
Eurobank’s portfolio does not include counterparties engaged in upstream activities, such as exploration and production. Also, the
target-setting does not include oil and gas companies operating in the product marketing and retail sub-segment.
Emissions coverage
The indicator used for target-setting encompasses Scope 1 and 2 GHG emissions, excluding the emissions associated with the end use
stage of oil and gas products (Scope 3 GHG emissions), which often constitute the majority of sectoral emissions.
This exclusion is primarily due to lack of readily available and reliable data from clients, which introduces inaccuracies and
uncertainties into the measurement and reporting processes. Oil and gas Scope 3 emissions are expected to be tackled through a
dedicated sectoral target that focuses on the sector’s downstream value chain.
Decarbonisation scenario
By using the IEA NZE scenario as the reference transition pathway for the oil and gas sector, Eurobank aims to facilitate investments
in technologies that will enable the sector’s transition, such as carbon capture and storage (CCS), methane reduction initiatives and
the development of low-carbon fuels. The oil and gas sector represents a significant source of carbon emissions and is critical for
global efforts to achieve net-zero emissions by 2050. Eurobank’s emission reduction target for the oil and gas sector focuses on
promoting sustainable practices, reducing emissions, and supporting the transition to a more diversified and resilient energy system.
The analysis is almost exclusively driven by sector developments in Greece, due to the structure of the sector and consequently, the
non-material sectoral exposure, in the other countries of operation. According to the Greek Climate Law, facilities with significant
environmental impact have an obligation to reduce their emissions by 30% by 2030 (reference year: 2019). The NECP does not include
sectoral targets, but rather a general 9% reduction target for the entire industry by 2030 (reference year: 2020). Considering that the
oil and gas sector is a hard-to-abate sector, with limited capacity in relation to process electrification, alternative solutions will have
to be adopted (e.g. CCUS, green hydrogen). However, based on the current progress, their implementation timeline is post-2030.
Eurobank’s sectoral approach
Eurobank recognises the critical importance that the oil and gas sector has in the global transition to a sustainable and low-carbon
energy system. Given the sector's substantial contribution to GHG emissions, particularly through the combustion of fossil fuels,
decarbonising oil and gas operations throughout the entire value chain is essential for achieving global climate targets.
Eurobank’s financed emissions in the oil and gas sector amounted to 558 ktCO2e (indexed at 100% based on the sectoral
methodology) as of the 2024 baseline year. The Group’s approach to target-setting considered the emission reduction effect,
application feasibility and timing of the sector’s key decarbonisation levers. In addition, a key element in the process was the fact that
clients in the Oil and Gas sector often have substantial and time-sensitive capital requirements, leading to significant fluctuations in
financing activity. These fluctuations—driven by withdrawals or repayments—can materially affect exposure levels and,
consequently, the attribution of financed emissions. As such, 2024 was selected as the base year because it more accurately reflects
typical exposure levels across key clients, providing a sounder foundation for setting and tracking emission reduction targets.
Based on the above, Eurobank set its target reduction target at -5% by 2030 in relation to its 2024 baseline. This target is based upon
the emission reduction effect of more mature decarbonisation levers that are part of its key counterparties’ investment plans, which
include energy efficiency measures (energy consumption optimisation, heat capture and integration, improved combustion efficiency,
setup upgrades etc.) and the adoption / expansion of green hydrogen and biofuels, as these are expected to produce results by 2030.
However, key sectoral decarbonisation drivers, such as Carbon Capture and Storage (CCS) and process electrification, are not expected
to be widely deployed by 2030 due to current market immaturity. As a result, these technologies have not been included in the
Group’s 2030 target. Their limited near-term feasibility means that the majority of substantial emission reductions in the oil and gas
sector are anticipated to occur post-2030, once these advanced technologies become commercially viable and supported by a more
solid regulatory framework and appropriate infrastructure.
Accordingly, the Group expects its post-2030 target to reflect the effect of these transformative solutions. This will enable a more
accelerated decarbonization trajectory, positioning the Group to adopt more ambitious goals that may potentially exceed the
International Energy Agency’s Net Zero Emissions (IEA NZE) pathway.
In 2025, the Group’s sectoral performance demonstrated an increase compared to 2024 performance (2025: 636 ktCO2e, 2024: 558
ktCO2e), The increase in 2025 is mainly driven by an increase in the sectoral exposure (+ €225 million).
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To achieve the 2030 target, Eurobank will implement a multifaceted strategy, focusing on the sector’s priority areas. It will mobilise
financing towards cleaner technologies, such as carbon capture, utilisation and storage (CCUS), and support the shift to low carbon
energy sources, such as green hydrogen and biofuels. Additionally, it will invest in energy efficiency improvements, reduce methane
emissions through advanced detection and capture technologies, and engage with clients and stakeholders to promote best practices
and collaboration on sustainability initiatives across the oil and gas value chain. This approach ensures its financing activities support
the broader transition to a low-carbon economy.
Iron and steel
Methodological approach
Boundary
The iron and steel sector is split into 4 segments:
●
Upstream: Scrap pretreatment (e.g., shredding, sorting)
●
Midstream: Electric arc furnace (EAF), Refining furnace, Casting
●
Downstream: Reheating furnace, Hot rolling, Cold rolling, Cold drawing, Forming,
●
Coating
For target setting in the sector, Eurobank has included all counterparties that have operations in any of the above-mentioned
segments in its countries of operations.
Emissions coverage
The indicator covers Scope 1 and 2 GHG emissions, which are responsible for the vast majority of the Group’s iron and steel value
chain footprint.
Decarbonisation scenario
Eurobank's emission reduction targets for the iron and steel sector align with the trajectory outlined in the IEA Net Zero by 2050
scenario, focusing on reducing emissions intensity, increasing energy efficiency, and promoting the adoption of sustainable
steelmaking practices. Eurobank is committed to supporting the transformation of the iron and steel sector towards sustainability,
fostering innovation, and driving progress towards a carbon-neutral future.
Eurobank’s sectoral approach
The iron and steel sector plays a key role in the decarbonisation of industry and poses a great challenge due to its energy intensive
nature and reliance on fossil fuels. To achieve meaningful emission reductions, numerous technologies, including green hydrogen,
need to be applied at scale. Additionally, there should be a focus on using scrap steel, increasing energy efficiency, and electrifying
the processes.
Eurobank’s financed emissions intensity in the iron and steel sector stood at 0.37 tCO2e per tonne of steel as of 2023 (baseline year).
In alignment with the IEA NZE scenario, Eurobank has set a target to reduce emissions intensity by 10% by 2030, bringing it down to
0.33 tCO2e per tonne of steel.
As of 2025, Eurobank’s financed emissions intensity decreased to 0.30 tCO2e per tonne of steel, representing a 19% decrease
compared to the 2023 baseline.
Leveraging national and European strategies such as the European Green Deal Industrial Plan and the National Energy and Climate
Plan, Eurobank will implement a comprehensive strategy that includes prioritising financing for projects incorporating innovative
technologies and low-emission fuel consumption, such as green hydrogen, as well as electric arc furnaces powered by renewable
energy. It will promote sustainable practices, such as adopting material efficiency, and strategies to reduce losses, and optimise steel
use. Furthermore, it will engage with clients and stakeholders to foster collaboration on sustainability initiatives and encourage the
sharing of best practices and innovative solutions.
Cement
Methodological approach
Boundary
The scope of this sector focuses on clients with activities related to the manufacture of cement and concrete products.
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Emissions coverage
The indicator covers Scope 1 and 2 GHG emissions, which are responsible for the vast majority of Eurobank’s cement value chain
footprint.
Decarbonisation scenario
Eurobank's emission reduction targets for the cement sector are aligned with the goals outlined in the IEA NZE scenario, focusing on
reducing emission intensity, promoting circular economy principles and supporting innovation in sustainable cement manufacturing
processes. By adopting the IEA NZE scenario as the transition pathway for the cement sector, it aims to incentivise investments in
sustainable cement production methods, including the use of alternative fuels and raw materials, enhancing energy efficiency, and
implementing carbon capture and utilization technologies.
Eurobank’s sectoral approach
Concrete and cement are important for essential economic development; however, reducing sectoral emissions while producing
sufficient cement to meet demand poses a great challenge. Reduction of the clinker-to-cement ratio through the uptake of clinker
substitutes, continuous energy efficiency improvements, adoption of low-carbon fuels, material efficiency improvements, and
deployment of innovative technologies, such as Carbon Capture and Storage (CCS), will play a significant role in achieving this goal.
Eurobank’s financed emission intensity in the cement sector stood at 0.67 tCO2e per tonne of cement as of 2023 (baseline year). In
alignment with the IEA Net Zero by 2050 scenario, Eurobank has set a target to reduce emissions intensity by 12% by 2030, bringing
it down to 0.59 tCO2e per tonne of cement. This target has been developed by analysing the implementation maturity and emission
reduction potential of the sectoral decarbonisation levers in conjunction with the investment plans of its key counterparties. The
result was that the levers that are considered mature enough to result in emission reductions by 2030 included the procurement of
carbon-free electricity through RES self-generation, PPAs and Guarantees of Origin, energy efficiency measures such as strategic
maintenance practices and fuel selection, process optimisation, diagnostic tools and application of mineralizers, reducing the clinker-
to-cement ratio and the use of alternative fuels.
However, the key decarbonisation levers for the sector which include the adoption of green hydrogen and Carbon Capture
technologies, are not considered mature enough to be able to yield results by 2030, due to market immaturity. Thus, as advancements
in technology and policy will remove these barriers, Eurobank anticipates that these technologies will become viable and scalable in
the post-2030 period. As a result, the Group’s targets will become more ambitious beyond 2030, potentially exceeding the IEA Net
Zero by 2050 pathway, as the full suite of decarbonisation solutions becomes available, economically feasible and supported by
appropriate infratsructure.
Eurobank's 2025 sectoral progress demonstrates a decrease in emission intensity, from 0.66 tCO2e in 2024 to 0.63 tCO2e in 2025.
This continuous progress, reflects the initial impact of mature decarbonization efforts taking effect. These developments sig nal
positive momentum toward its 2030 target and reinforce the importance of sustained investment and engagement with
counterparties to accelerate the sector’s transition. Eurobank will focus on financing investments that will decrease process emissions
from clinker production, which accounts for most of the sector’s emissions, and reduce its reliance on fossil fuels for its high-
temperature production process, by promoting the utilization of green hydrogen and other low carbon fuels. It will support its clients'
efforts to optimise their production processes to lower energy consumption, while also financing the deployment of innovative
technologies, such as Carbon Capture and Storage (CCS), which will play a significant role in achieving the decarbonization of the
sector. Furthermore, Eurobank will engage with clients and stakeholders to foster collaboration on sustainability initiatives,
encouraging the adoption of best practices and innovative solutions.
The Group is currently in the process of finalising its Transition Plan in line with the EBA Guidelines on the management of ESG risks,
and the sectoral analyses presented in this chapter form the fundamental building blocks of this work. As the Transition Plan
progresses, this approach will be expanded to all other material sectors, ensuring that each sector is integrated into a coherent,
Group-wide transition framework with sector-specific pathways and objectives.
Material impacts, risks and opportunities and their interaction with strategy and business model [ESRS 2 SBM-3]
The Group identifies and assesses sustainability -related risks, including Climate-Related and Environmental risks, within the context
of the Risk Identification and Materiality Assessment (RIMA) process, which is performed at least on an annual basis, or ad-hoc, if
necessary. Through the RIMA process, the Group identifies material risks that could potentially have a significant adverse impact on
its financials, capital base, liquidity position or business model, as well as any possible emerging risks that the Group might be exposed
to. In this context, the Group takes into consideration several different sources to identify new risks, such as the Single Supervisory
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Mechanism (SSM), the Supervisory Priorities, the EU & national legislation changes, developments in the regulatory landscape in
general, along with EBA Guideline or Basel Committee on Banking Supervision (BCBS) reports.
The Group has identified as sustainability risks, the risks deriving from potential loss or negative impact to the Group, including
loss/damage to physical assets, disruption of business or system failures, transition expenditures and reputational effects from the
adverse consequences of climate change and environmental degradation.
As sustainability risks interact with other risks and result in both direct distributional impacts and indirect macroeconomic impacts,
the Group understands that careful consideration of the cross-cutting nature thereof is necessary to ensure the appropriate
implementation of adaptation activities. Thus, the Group considers sustainability risks as drivers of existing risk types, undertaking a
holistic and systemic approach when examining the complex links between sustainability risks and both financial and non-financial
risks. Eurobank has integrated sustainability risks elements into its existing risk management processes, creating additional
procedures, policies and tools so that these risks can be properly identified and measured.
The Group has identified the risk drivers related to climate change and environmental degradation, through internal and external
sources of knowledge, that are most relevant for the business environment in which it operates. In this context, the Group has
identified the following list of climate-related and environmental risk drivers:
Climate-related Risks
Transition risk
Financial loss that can result, directly or indirectly, from the
process of adjustment towards a lower-carbon and more
environmentally sustainable economy. This transition may entail
extensive behavioral, policy and regulatory, as well as
technological changes, to address mitigation and adaptation
requirements relating to impacts deriving from climate change
and environmental risks. Depending on the nature, speed, and
focus of these changes, transition risks may pose varying levels of
financial and reputational risk to organisations.
Physical risk
Financial impact of a climate change, including more frequent
extreme weather events and gradual changes in climate, as well
as the impact of environmental degradation, such as air, water
and land pollution, water stress, biodiversity loss and
deforestation.
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Climate-related Risks
Behavioural Changes
Behavioral changes of consumers, suppliers, employees and
investors could trigger shifts in supply and demand for certain
commodities, products, services and capital as climate -related
and environmental risks and opportunities are increasingly taken
into account. Changing client or community perceptions of an
organisation’s contribution to or detraction from the transition
to a lower-carbon economy and developments aimed at halting
or reversing damage to nature, can all result in decreased
revenue, changes in the revenue mix and major capex
requirements, while they are also a potential source of
reputational risk for many entities.
Acute Hazards
Extreme weather-related events such as storms, floods, fires or
heatwaves and other environmental hazards such as geologic
events or changes in ecosystem equilibria (e.g., soil pollution)
that may damage production/ operation facilities and disrupt
value chains.
Policy & Regulatory Changes
The objectives of policy actions and regulatory requirements
generally fall into two categories:
1.
Policy actions that aim at constraining actions that contribute
to the adverse effects of climate change (e.g., implementing
carbon-pricing mechanisms to reduce greenhouse gas
emissions, energy use toward lower emission sources) and
environmental degradation (e.g., restrictions on water
consumption levels, ban of certain environmentally
damaging materials/chemicals).
2.
Policy actions that seek to promote adaptation to climate
change (e.g., adopting energy-efficiency solutions,
encouraging greater water efficiency measures, and
promoting more sustainable land-use practices) and
environmental degradation (e.g., more efficient water
management practices).
Both the nature and the timing of policy changes determine the
extent of the associated risk and its subsequent financial impact.
Another important risk is litigation or legal risk. As the value of
loss and damage arising from climate change and environmental
degradation grows, litigation risk is also likely to increase.
Chronic Hazards
Progressive shifts, such as increasing temperatures, sea level rise,
water stress, biodiversity loss, land use change, habitat
destruction and resource scarcity. This can directly result in, for
example, damage to property or reduced productivity, or
indirectly lead to subsequent events, such as the disruption of
supply chains.
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Climate-related Risks
Technological Changes
Technological improvements or innovations that support the
transition to a lower-carbon, energy efficient economic system as
well as the substitution of products or services with a lower /
improved impact on nature or reduced dependency on nature
can have a significant impact on organisations, as different
industries may encounter difficulties in adapting to technology
advancements toward greener practices. For example, the
development and use of emerging technologies such as
renewable energy, battery storage, energy efficiency, and carbon
capture and storage will affect certain organisations, their
production and distribution costs, and ultimately the demand for
their products and services from end users. The timing of
technology development and deployment is also a key
uncertainty in assessing technology risk.
Environmental Risks
Water Scarcity
Water scarcity is assessed in the context of environmental risk.
However, environmental risk is not further split into physical and
transition hazards at this stage, due to a lack of appropriate data
and the overall early stage of the corresponding environmental
risk management framework; rather, water scarcity assessment
embodies both components altogether. The analysis for
environmental hazards will resemble the analysis for climate risk
going forward, as the risk environment matures.
Biodiversity Loss
Biodiversity loss is an average loss in biological diversity over time
and/or space that leads to a decline in the ability of the natural
world to generate flows of ecosystem services, with negative
economic impacts on individuals, households, organisations and
countries.
As the global financial sector is increasingly recognising the importance of understanding and managing sustainability risks, scenario
analysis has emerged as a valuable tool for assessing the potential impacts of climate change on financial institutions.
Scenario analysis enables Eurobank to evaluate its resilience and adaptability in different climate-related scenarios. The
methodological approach adopted allows the measurement of impacts, based on different scenarios and time horizons (2030, 2040
and 2050). The analysis aims to enhance Group’s understanding of climate-related risks, inform strategic decision making, and
facilitate the integration of climate considerations into its risk management framework.
The purpose of the scenario analysis is to inform the Group to proactively identify potential vulnerabilities, seize opportunities, and
align its business strategies with the transition to a low-carbon economy. The integration of scenario analysis, plays a crucial role in
shaping its strategy, by providing valuable insights into the potential impacts of climate-related risks and opportunities on its financial
performance and long-term sustainability.
Forward-looking analysis is especially important but also challenging. Efforts to mitigate and adapt to climate change are without
historical precedent, and many aspects regarding the timing and magnitude of climate change in specific contexts are uncertain.
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The set of scenarios that are utilised by the Group, include four representative scenarios by the Network for Greening the Financial
System (NGFS) and two Representative Concentration Pathways (RCPs) climate scenarios. More specifically, the scenarios used are:
NGFS scenarios
Representative Concentration Pathways (RCPs)
climate scenarios
1.
Orderly: Net Zero 2050,
ambitious action and the impacts are low for both physical and
transition risks.
1.
RCP2.6,
policies and limit the increase in average global
temperature to below 2
o
C.
2.
Disorderly: Delayed Transition,
introduced until 2030 and the outcome has a higher impact on
transition risk.
3.
Hot house word:
severe physical risks and irreversible changes, including higher sea
level
2.
RCP8.5,
the necessity of strong adaptation to the new
conditions.
4.
Too-little-too-late:
divergent climate policy ambition globally, leads to elevated transition
risks due to the overall ineffectiveness of the transition.
The scenario analysis, also integrated into the Group’s ICAAP process, supports strategic planning and capital adequacy assessments
by evaluating financial outcomes across sectors and geographies under multiple climate transition and physical risk scenarios.
Specifically, scenario analysis serves as a primary tool within the ICAAP to quantify risks, assess capital needs under stress, and ensure
the Bank remains adequately capitalized against both traditional and emerging risks. A major application of scenario analysis within
Eurobank's recent ICAAP exercises (2024 and 2025) is the assessment of Climate -Related and Environmental (CR&E) risks. The Bank
utilises specific climate scenarios to quantify credit risk impacts across two distinct perspectives:
•
Economic Perspective:
o
The Bank uses a long-term climate scenario extending to 2050 to assess the impact on sectoral Gross Value Added
(GVA) and GDP. This scenario is based on the NGFS 'Orderly Scenario' (Network for Greening the Financial System),
which aligns with Net Zero 2050 targets. It incorporates impacts from both transition risks and chronic physical risks
affecting the Probability of Default (PD) models. The outcome is integrated as an internal capital requirement.
• Normative Perspective:
o
The Group performs an individual assessment of its top corporate clients in sectors most sensitive to transition risk.
This utilizes a short-term disorderly climate scenario (aligned with NGFS) to reflect macroeconomic and counterparty-
level effects. Additionally, real estate collateral values are stressed to capture the impact of acute physical climate
hazards under a high-emissions scenario.
2.2.2 Identified impacts, risks and opportunities
Description of the processes to identify and assess material climate-related impacts, risks and opportunities [ESRS 2 IRO-1]
Eurobank identifies material impacts, risks, and opportunities related to climate—such as climate change mitigation, climate change
adaptation and energy—through a comprehensive DMA. This approach integrates industry benchmarks, stakeholder insights, and
financial relevance to ensure a robust evaluation of climate -related topics.
The impacts, risks and opportunities associated with Climate change are displayed in the table below:
Climate change mitigation
Impact
Positive
Actual
Eurobank implements a robust climate change mitigation strategy aiming to minimise the
impact of its portfolio to climate change.
Positive
Actual
Eurobank engages with external stakeholders to promote sustainability issues through
various engagement mechanisms.
Negative
Actual
Eurobank’s portfolio faces negative impacts due to the evolving nature of a climate change
mitigation strategy.
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Negative
Potential
Capacity Building to promote sustainability issues to external stakeholders is mostly limited
to corporate clients.
Risk
The actions required by Eurobank’s clients to address climate change mitigation and
adaptation requirements may impact Eurobank’s credit risk.
Opportunity
Meeting climate objectives for clients creates the opportunity for Eurobank to finance the
transition of its clientele.
Climate change adaptation
Impact
Positive
Actual
Eurobank actively contributes to GHG reduction ambitions and targets, set by the EU,
regulations, central governments, and other bodies, through its sustainable financings and
integration of climate risk in the risk management framework.
Negative
Potential
Eurobank’s business strategy may encompass the continuation of financing to carbon-intensive
sectors.
Risk
The actions required by Eurobank’s clients to address climate change mitigation and adaptation
requirements relating to impacts deriving from climate change may impact Eurobank’s credit
risk.
Opportunity
Meeting climate objectives linked to legal, regulatory and other stakeholders’ requirements for
Eurobank’s clients, entails the opportunity for Eurobank to finance the transition of its clientele.
Energy
Impact
Negative
Actual
Eurobank contributes to climate change through its in-house operations that contribute to the
release of emissions.
Eurobank has performed an in-depth analysis regarding climate change transition and physical risks within the context of the Task
Force on Climate-related Financial Disclosures (TCFD) recommendations.
The analysis aims to enhance Eurobank’s understanding of sustainability risks, inform strategic decision-making, and facilitate the
integration of climate considerations into its risk management framework, as well as to inform Eurobank’s approach on identifying
vulnerabilities, seizing opportunities and aligning business strategies within the context of the Task Force on Climate-related Financial
Disclosures (TCFD) recommendations. Please refer to the E1 – Climate change: Material impacts, risks and opportunities and their
interaction with strategy and business model [ESRS 2 SBM-3].
Transition Risk Impact
The Bank utilises a large-scale applied Computable General Equilibrium “CGE” model, developed by an external provider, to quantify
the macroeconomic impacts of the different NGFS scenarios. The model, which was first introduced in 2023, is dynamic, global and
specific for Greece. The model represents 46 countries and 60 economic activities linking simultaneously all countries and economic
sectors through bilateral trade flows. It represents in detail the economic transactions of all economic agents (firms, households,
government and the external sector) and features a bottom up representation of the energy system and all sources of GHG emissions.
By explicitly modelling all sources of GHG emissions, their associated abatement options
and their costs it is possible to estimate
the impact that the adoption of these technologies by firms and households will have on production costs, competitiveness,
disposable income and consumption. In particular the model calculates / simulates in each scenario the optimum mix of technologies
and measures that have to be adopted so as to deliver the desired (as defined by the NGFS scenarios) GHG emission reduction
pathways.
The mix of technology and measures is different by country depending on its abatement potential, its capacity to provide the
necessary materials and services for the transition, financial adequacy to support clean energy investments, labour skill availability
and existing status of energy assets
. The model captures how the adoption and transition to a low carbon energy system affects
firms’ productions costs (explicit representation of energy prices and technologies in firms’ production decision), household
s
20
21
overall cost of adjustment.
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consumption and savings decisions. In this way the model calculates how changes in firms’ competitiveness and aggregate demand
impact the Greek economy.
To this end the CGE model provides a robust framework to capture the complex energy-economy-climate interactions. The model,
by capturing in full detail the energy-environment systems and their interaction with the economy, is able to account for all
transitional impacts.
The model can assess:
1.
Direct (cost on carbon intensive economic activities, the emergence of clean technology etc.),
2.
Indirect (value chain effects) and
3.
Induced (economy feedback, price and income effects).
Our analysis provides detailed insights into:
●
What is the impact of carbon pricing on the use of energy technologies
●
How the adoption of new energy technologies affects production costs.
●
How changes in production costs due to climate and energy policies affect competitiveness, sectoral production and
disposable income.
●
Attribute economic benefits to the sectors contributing to the decarbonisation process and account for the losses in sectors
that are directly or indirectly linked to fossils and conventional technologies.
●
Which is the level of carbon prices to achieve different GHG emission reduction pathways.
The Bank explored 4 different scenarios (depicted in the previous page) as part of its strategic planning and risk management with
time horizons up to 2050. Key features of the climate -related scenarios (i.e. NGFS) are presented below.
Summary of transition risk scenarios
Orderly: Net zero 2050
Disorderly: Delayed
transition
Hot house world:
Current Policies
Too-little-too-late:
Fragmented world
Ambition
High ambition for
EU and non-EU to
reduce GHG
emissions.
No action until 2030.
High ambition after
2030 for EU and
non-EU to reduce
GHG emissions.
Low ambition for
EU and non-EU to
reduce GHG
emissions.
No action until
2030 and
moderate
ambition after
2030 (slightly
above of Hot
House World).
International
Energy prices
Oil: Significant
reduction as
compared to Hot
House World.
Gas: High increase in
short and medium
term and
accelerated
reduction after
2040.
Oil: Similar to Hot
House World until
2030 and moderate
reduction as
compared to Hot
House World after
2030.
Gas: Similar to Hot
House World until
2030. High increase in
2035 and accelerated
reduction after 2035.
Energy prices
increase steadily.
Oil: Similar to
Hot House
World until
2030 and
slightly below
Hot House
World after
2030.
Gas: Similar to Hot
House World.
Cost of clean
energy
technologies
Clean energy
technologies
through R&D and
economies of scale
will have significant
cost reductions.
Clean energy
technologies
will have
moderate cost
reductions in short
term and significant
Clean energy
technologies
will have
moderate
cost
reductions.
Clean energy
technologies will
have moderate
cost reductions.
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Orderly: Net zero 2050
Disorderly: Delayed
transition
Hot house world:
Current Policies
Too-little-too-late:
Fragmented world
cost reductions in
long-term.
Growth Path
Balanced growth path
driven by concerted
action, lower than Hot
House World.
Balanced growth path
driven. Similar to Hot
House World until 2030
and significantly lower
afterwards.
Balanced growth
path.
Balanced growth
path lower than Hot
House World.
Investment
requirements
Significant both in short-
term and long-term
driven by
decarbonisation and
massive deployment of
clean energy
technologies.
Significant in long-
term.
Follows GDP
trajectory by
country.
Slightly higher as
compared with Hot
House World.
Market size of
clean energy
technologies
Countries with
established competitive
advantage will benefit
from exports as the
market size of clean
energy technologies
increases (rate of
increase moderated by
the cost reductions).
After 2030 countries
with established
competitive advantage
will benefit from
exports as the market
size of clean energy
technologies increases
(rate of increase
moderated by the cost
reductions).
Not significant
competitive
advantage
possibilities as the
market size of clean
energy technologies
increase with a
slow pace.
Limited deployment
and fragmented
markets do not
drive cost
reductions to their
full potential
decelerating the
adoption rate and
hence growth of
the market.
GHG intensive
Industries
Significant increases in
carbon price leading to
increases in production
costs of carbon intensive
industries. EU industries
better positioned due to
ambitious 2030 targets.
Impact on
competitiveness
worldwide driven by
changes in relative
production costs.
Lower increases in
production costs than
the net zero 2050
scenario but also lower
mitigation of climate
change.
Limited impact on
production costs.
Industrial
competitiveness
marginally affected.
Moderate increase
in production costs.
Moderate impact
on relative prices
and
competitiveness.
The different NGFS scenarios imply a smooth or fast change of the following channels:
Energy efficiency:
•
Expenditures on energy efficient equipment
•
Expenditures on building renovation
•
High upfront cost with long-term benefits from energy efficiency (reducing energy bills)
•
Financing scheme of these expenditures affect s the transition cost over time
RES:
•
Domestic content of the manufacture of Clean Technologies (EV, Batteries, Wind, PV)
•
Investment for RES technologies (installation of PV, Wind, etc.)
•
Financing scheme of these investments affects the transition cost over time
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Energy mix & production cost:
•
Energy policies (i.e., carbon price) affect the energy mix by increasing the price of energy (fossil fuels and electricity) in short
term but with possible benefits in the long term through electrification and the energy efficiency (lower energy cost).
•
Capital and energy cost in the short-term increase the unit cost of production and deteriorate competitiveness as opposed
with long-term that lower energy cost and adoption of more efficient technologies imply competitiveness improvement.
•
The change in the energy mix decreases the energy dependency with a positive impact on balance of trade.
The impact on GDP and sectoral economic activity is driven by changes in production costs, in households’ disposable income, in
competitiveness and current account.
In the
high ambition scenarios
EU (and Greece - as an ETS (Emissions Trading Scheme) price taker) has a higher than key competitors
carbon price as low-cost abatement options have been already taken up (EU being the front-runner in GHG emission reductions) and
further decarbonizing the energy system comes at higher marginal cost.
•
In both high ambition scenarios EU has a small but negative impact on its GDP which impacts Greece through the trade
channel: lower demand for Greek exports – EU countries being the main trading partner of Greece.
•
Greek energy and carbon intensive firms (steel, cement) also face high production costs. The ultimate impact on firms that
fall under the cement and steel industries greatly depend on their ability to pass through cost reductions, existing RES PPAs
(Power Purchase Agreement) and the application of Carbon Border Adjustment Mechanism “CBAM” measures that
moderate the impact on firms’ competitiveness.
•
The high ambition scenarios entail significant deployment of clean energy technologies which reduces their capital costs
through economies of scale, learning by doing and research. Lower costs significantly benefit the Greek economy that is
dependent on imports (PV, WindTurbines, Electrolysers, Electric Cars) to decarbonize its energy system.
•
Households in the high ambition scenarios and in the short run face higher energy costs that have a negative impact on their
disposable income, which bring benefits in the long term (despite the intense adoption of energy saving measures) as more
expensive technologies are used and electricity price increases due to carbon pricing. It should be noted that the positive
effects of energy saving expenditures come in the long term.
•
Decarbonising the Greek energy system entails a transition from a high OPEX low CAPEX expenditure profile to a high CAPEX
low OPEX profile. Despite the long-term benefits that energy saving and energy efficient technologies are bringing the short-
term impact on capital requirements is sufficient to reduce available funds for consumption and investment. In other words,
high upfront payments require available capital either through self-financing (out of pocket) or loans. Economic agents that
are not eligible for low-cost financing are negatively affected.
In the
low ambition scenarios
energy technologies and decarbonisation related investments.
•
The low climate ambition scenarios do not lead to significant clean energy costs reductions (cost maturity is achieved late in
the simulation – mostly driven by autonomous technical progress).
•
Low investment and financing requirements do not put any pressure in the capital market and costs.
Impact in terms of sectoral production, Orderly: Net Zero 2050 vs Hot House World Scenario
Sector
2030
2040
2050
Agriculture
Moderate Negative
Moderate Negative
Moderate Negative
Mining and Quarrying
Strong Negative
Strong Negative
Strong Negative
Other Manufacturing
Moderate Negative
Moderate Negative
Negative
Electricity Supply
Moderate Positive
Positive
Positive
Water Supply
Same Level
Same Level
Same Level
Construction
Moderate Positive
Positive
Positive
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Sector
2030
2040
2050
Wholesale & Retail Trade
Same Level
Same Level
Same Level
Transporting and Storage
Negative
Negative
Strong Negative
Real Estate Activities
Same Level
Same Level
Same Level
Oil and Gas
Strong Negative
Strong Negative
Strong Negative
Renewable Energy Sources
Strong Positive
Strong Positive
Strong Positive
Basic Metals
Negative
Negative
Negative
Non-Metallic Minerals
Moderate Negative
Moderate Negative
Negative
Chemicals
Negative
Negative
Strong Negative
Consumer Goods industries
Moderate Negative
Moderate Negative
Moderate Negative
Accommodation
Same Level
Same Level
Same Level
Shipping
Negative
Negative
Strong Negative
Overview of horizontal Impacts
•
Overall, the net impact on the economic activity (GDP) of Greece is found to be small but negative in the long term in
all scenarios examined, compared with Hot House World Scenario. However, changes in the energy system in any
scenario examined do not have any critical impact on the structural growth drivers of the economy, hence a stable
economic growth is projected in all scenarios examined.
•
The low ambition scenarios do not have any significant impact on the short term.
•
Positive impacts are brought into the economy mainly through energy efficiency improvements as these are characterized
by high multipliers and domestic content. Energy efficiency improvements mainly address the construction sector (domestic
capacity) that is characterized by a high output and employment multiplier. Energy efficiency improvements also reduce
the dependency on imported fossil fuels and on electricity.
•
In the high ambition scenarios, the Greek economy benefits from reducing its dependency on fossil imports as gradually its
system is fully decarbonized. However, increased penetration of RES further burdens the trade balance as most of the
equipment is imported.
•
The impact on household income is mixed: An increase in employment in high value-added sectors takes place in order
to support the deployment of clean energy technologies. A decrease in employment in brown sectors leads to skills
shortage and increasing unemployment in ages where upskilling – reskilling has low potentials – leading to long term
unemployment. The impacts are highly contrasted among regions within Greece although the net impact is small.
•
The key sectors benefiting in the high ambition scenarios are the power generation utilities. Significant positive effects on
electricity production driven by the electrification of the energy system (despite the energy efficiency improvements the
electrification of the economy is significant – in particular through the electrification of the transport sector the net
demand for electricity increases significantly).
•
Negative impacts are mainly driven by import requirements (assuming that the market share of Greece in clean energy
technologies will not change considerably in the future - significant share of the equipment required to decarbonize the
energy system is im ported – PV, wind turbines, electric vehicles, batteries).
Key outcomes from scenario analysis
•
Low ambition scenarios in the short-term have moderate impacts on GDP and sectoral production as carbon prices do not
increase much production costs but also provide a weak signal for investments.
•
Too
Little too late
Delayed
transition scenarios have marginal virtually zero impact on the short term.
•
Net zero 2050
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•
Services benefit to the extent that operate supplementary to the deployment of the clean energy technologies (design,
implementation, financing etc.). Services are characterized by low dependency on energy and openness to trade hence
higher energy costs leave the competitiveness of the sector virtually unaffected.
•
The demand for clean technologies increases with positive impact in their production. Biofuels, batteries, PV, energy saving
equipment/ materials and Wind are essential for the decarbonization of the system. Cost maturity achieved both in the Net
Zero 2050 and Delayed Transition Scenarios.
•
The higher carbon price in Emissions Trading Scheme - ETS (incl. the extended ETS, Transport & Services)
Net Zero and
Delayed Transition
international competitiveness.
Physical Risk Impact
Eurobank assesses the physical climate risks related to its clients’ activities following an analytical and transparent methodological
approach, considering both:
•
Chronic effects: impact on companies’ revenue or operating costs due to the long-term changes in weather patterns.
•
Acute effects: damages to companies’ assets or revenue losses attributed to extreme weather events.
To this end, the Bank utilises two Climate Scenarios for the analysis of physical impacts, namely:
1.
RCP 2.6, which is a stringent mitigation scenario with the aim to keep global warming below 2ºC, consistent with the
goals of the Paris Agreement.
2.
RCP 8.5, which is a scenario with weak and delayed action for reducing global GHG emissions. It is a “reference” or worst-
case scenario where GHG emissions keep increasing throughout the whole century as it incorporates weak policies for
tackling climate change. In other words, it is associated with hot house world scenarios, with average temperature
increases exceeding 4°C.
Climate data and indices used in the analysis have been derived from Copernicus Climate Data Store and the Adaptive Greece Hub
databases. Historical values have been calculated by using ERA5 reanalysis data, while future projections derived from climate model
simulations with general circulation and regional climate model pairs under the EURO-CORDEX programme. A total of 4 to 8 model-
combinations (depending on the climate index and variable) at a horizontal resolution of 0.11 x 0.11 degrees (approximately 11.5 x
11.5 km) have been used. Multi-model mean values are used in order to minimize the range of uncertainty in climate model
simulations while both historical data and future projections are bias-adjusted versus the ERA5 reanalysis data.
The methodological approach developed is applied at the appropriate level of spatial analysis (i.e., at NUTS 2 level for chronic effects
and at Postal Code level for acute effects). It takes into account the different levels of vulnerability that the various economic activities
have to these phenomena (the analysis is performed at NACE code 2- digits level) and is extended to the time horizon of 2050
(providing where possible also estimates for 2030 and 2040) for chronic effects and the period 2031-2060 for acute effects. At the
end of this process, the climate risk attributed to the Bank’s financing to companies belonging to an economic sector operating in a
specific region is categorized on a 5-point RAG scale, rating them from Negligible to Very High.
More detailed information about the applied methodological framework is given below.
Analysis of chronic effects
The analysis of chronic climate change effects was carried out for 2030 (as a representative year of the period 2020-2040), 2040
(representative for the period 2030-2050), and 2050 (representative for the years 2040-2050) at the NUTS 2 level, covering the 13
regions in Greece for the two climate scenarios. In this context, the Bank utilizes a diverse set of indicators derived from European
and internationally recognized databases to estimate climate impacts of chronic changes of climate patterns (e.g. mean temperature
increase, precipitation changes etc.) on sectoral revenues. These indicators include measures of productivity and yield in primary
sector, industrial labour productivity, tourism performance indicators and climate-driven changes in energy production and demand.
More specifically, we have utilised:
●
The outcomes of research projects as regards the impact of climate change on the yield/revenue of the primary sector (i.e.,
agriculture, fishery, and forestry).
●
The outcomes of research projects as regards the impact of climate change on the productivity of the mining, manufacturing,
and construction sectors.
●
The outcomes of research projects as regards the impact of climate change on the productivity of different power generation
technologies (both renewables and fossil-fuelled) in Greece.
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●
The number of heating and cooling degree days attributed to various climatic scenarios in order to assess the changes in
heating and cooling needs of the non-residential buildings, which usually affect the operating costs of the companies of the
services sector.
●
The changes on the Tourism Climate Index associated with the different climatic scenarios that affect tourism activity and
associated companies.
The above-mentioned climate indicators are considered as the drivers of the potential chronic impacts of climate change on the
companies of the respective economic sectors, affecting either their operating costs or their revenues. In the context of the present
analysis, these effects either directly (due to the structure of the climate indicators used) or indirectly (through the input-output
tables of the respective economies or other econometric models) were expressed as percentage changes in the turnover of the
respective businesses. At the final stage of the process, specific thresholds were adopted as regards the estimated losses due to
climate change, with a view the related risks to be characterized as negligible, low, medium, high or very high.
Impact in terms of sectoral production, RCP 8.5
Sector
2030
2040
2050
Agriculture
High
High
High
Mining and Quarrying
Low
Low
Medium
Other Manufacturing
Low
Low
Low
Electricity Supply
Medium
Medium
Medium
Water Supply
Low
Low
Low
Construction
Low
Low
Low
Wholesale & Retail Trade
Minor
Low
Low
Transporting and Storage
Low
Medium
Medium
Real Estate Activities
Minor
Minor
Minor
Oil and Gas
Minor
Minor
Minor
Renewable Energy Sources
Minor
Minor
Minor
Basic Metals
Minor
Low
Low
Non-Metallic Minerals
Low
Low
Low
Chemicals
Low
Low
Low
Consumer Goods industries
Low
Low
Medium
Accommodation
Low
Medium
Medium
Shipping
Minor
Minor
Minor
Analysis of Acute effects
During the analysis of acute effects, the Bank takes into consideration several extreme phenomena, such as:
•
fluvial floods (high-water levels in river channels, causing dyke breach)
•
pluvial floods (rainfall intensity exceeding infiltration capacity)
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•
extreme heat
•
wildfires
•
water scarcity
•
landslides
•
coastal floods
The quantitative analysis is performed at Local Administrative Unit (LAU) level in Greece, as well as per NACE code at 2-digit level.
The effects are then integrated at Postal Code level, and they are expressed in quantitative categorical scales. The analysis is
conducted uniformly for the entire period 2031-2060 and the two RCP Scenarios.
Risk = ƒ(Hazard, Exposure, Vulnerability)
The overview of our approach is depicted in the Figure above (source: MacFarlane, 2021), and considers three main dimensions:
1.
Climate Hazards: concern the severity of climate events that have the capacity to damage or destroy a particular
geographical area and/or the assets that are located there. It is characterized by the frequency and intensity of acute climate
events, such as floods, heatwaves, or wildfires, and is quantified on a scale from negligible to very high.
2.
Exposure: is defined as the amount of natural or anthropogenic capital that is exposed to the hazard in a given space and
time. For instance, a typical measure of exposure is the proportion of a region’s area situated within a high-risk flood zone.
3.
Vulnerability: is defined as the susceptibility or potential damageability of an area and/or asset to a specific hazard intensity.
It measures the extent to which assets are likely to be negatively impacted by an event, based on their intrinsic
characteristics or resilience.
In the next stage of the methodological framework developed, the climate risk attributed to each extreme phenomenon under
consideration, is calculated by geographical area and economic activity as the product of the three indicators formulated to evaluate
the abovementioned dimensions. The extreme event with the highest score is considered to be the one shaping the climate risk for
that activity in that area.
ACRs,r = max (Hi,r x Ei,r x Vi,s)
Where ACR the acute climate risk attributed to a company operating in industry s and region r, H the severity of the hazard faced by
area r due to phenomenon i, E the degree of exposure of the area r to the extreme effect i, and V the vulnerability of the economic
sector s to the extreme event i.
Ultimately, adopting appropriate thresholds, this climate risk attributed to acute effects is characterized, similarly to chronic effects,
as negligible, low, medium, high, or very high.
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Acute Risk Assessment, RCP 8.5
Sector
Assessment
Agriculture
High
Mining and Quarrying Construction
Low
Other Manufacturing
Minor
Electricity Supply
High
Water Supply
Minor
Construction
Minor
Wholesale & Retail Trade
Minor
Transporting and Storage
Minor
Real Estate Activities
Minor
Oil and Gas
Minor
Renewable Energy Sources
Minor
Basic Metals
Minor
Non-Metallic Minerals
Minor
Chemicals
Minor
Consumer Goods industries
Low
Accommodation
Low
Shipping
Minor
2.2.3 Policies, actions and performance
Policies related to climate change mitigation and adaptation [E1-2]
Τhe Group has adopted policies to manage material impacts, risks, and opportunities related to climate change mitigation and
adaptation and the environment. Policies affecting internal stakeholders are available to the Group's intranet, while those referring
to external stakeholders, are available through the corporate website. Eurobank is committed to engaging with stakeholders by
ensuring a high level of accountability in policy development and implementation. Policies are approved by the appropriate
Governance bodies such as the Board of Directors or specialized committees, which ensure that there is alignment with the Group's
strategic goals and stakeholder interests. The relevant policies are outlined in the table below as per the Minimum Disclosure
Requirements with regards to policies (MDR-P) defined in ESRS 2.
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Name of key policy
Addressed key areas of policy
Relevant material identified impact,
risk or opportunity
Operational impact climate change-related policies
Environmental & Energy Management
Systems
- Energy management
- Energy assessment of facilities
- GHG emissions
- Environmental & Energy targets
- Waste management
- Νatural resources management
- Water resources management
Energy (Negative impact)
Climate change adaptation (Positive
impact)
Climate change mitigation (Positive
impact – Opportunity)
Energy Management Policy Statement
-Energy performance improvement
-Renewable energy deployment
-Regulatory compliance
Energy (Negative impact)
Climate change mitigation (Positive
impact – Opportunity)
Climate change adaptation (Positive
impact)
GHG emissions Inventory Report
- Energy management
- GHG emissions
- Operational GHG emissions
- Operational Net Zero
Energy (Negative impact)
Climate change adaptation (Positive
impact)
Climate change mitigation (Positive
impact – Opportunity)
Environmental Report
-Energy management
-Operational GHG emissions
-Operational Net Zero
-Water consumption
-Solid Waste Management and Recycling
-Noise
Energy (Negative impact)
Climate change mitigation (Positive
impact – Opportunity)
Climate change adaptation (Positive
impact)
Water Management Policy Statement
- Water resources management
- Water consumption
-
Environmental Policy Statement
-Energy management
-Climate change adaptation
-Climate change mitigation
-Impact of activities
Energy (Negative impact)
Climate change mitigation (Positive
impact – Opportunity)
Climate change adaptation (Positive
impact)
Financed impact climate change-related policies
Sustainable Finance Framework
-Renewable energy deployment
-Climate change adaptation
-Climate change mitigation
Climate change mitigation (Positive
impact – Opportunity)
Climate change adaptation (Positive
impact – Opportunity)
Sustainable Investment Framework
-Renewable energy deployment
-Climate change adaptation
-Climate change mitigation
Climate change mitigation (Positive
impact – Opportunity)
Climate change adaptation (Positive
impact)
Green Bond Framework
-Energy efficiency
-Renewable energy deployment
-Climate change adaptation
-Climate change mitigation
Climate change mitigation (Positive
impact – Opportunity)
Climate change adaptation (Positive
impact)
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Name of key policy
Addressed key areas of policy
Relevant material identified impact,
risk or opportunity
Sustainability Risk Management Policy
-Climate change adaptation
-Climate change mitigation
Climate change mitigation (Risk)
Climate change adaptation (Risk)
Integration of sustainability in risk
management (Positive impact –
Opportunity)
Climate Risk Stress Test Framework
-Climate change adaptation
-Climate change mitigation
Climate change mitigation (Positive
impact – Opportunity)
Climate change adaptation (Positive
impact)
Eurobank recognises the interdependency between impacts on the environment, as well as the risks and opportunities they present.
As such, we have implemented policies that cover several material sustainability matters, including matters addressed by more than
one topical ESRS. The following policies address more than one sustainability matter.
The overarching
Sustainability Policy Framework
voluntary initiatives as well as adopted standards and guidelines enabling Eurobank’s current and continuously evolving approach
towards Sustainability, in line with international best practices. The Sustainability Policy Framework sets the foundation towards
integration of Sustainability into Eurobank’s business model and operations. Accountability for the implementation of the
Sustainability Policy Framework lies with the Group Senior Sustainability Officer (GSSO), under the oversight of the Sustainability
Management Committee, whose key tasks and responsibilities, include the following:
●
Approve the Sustainability Frameworks (e.g. Sustainability Finance Framework, Transition Finance Framework, Green Bond
Framework, Sustainability Policy Framework and Sustainability Investment Framework) as well as other sustainability-
related Policies.
●
Review the sustainability related frameworks and other related sustainability issues, prior to submission to the appropriate
Committee.
The subject matter of the operational impact policies is outlined below:
The
Environmental & Energy Management Systems
as well as environmental management practices, responsibilities and targets. These ISO certified Management Systems cover waste,
natural resources, water and energy systems management, GHG emissions, environmental and energy targets, obligations
compliance, training and staff awareness of Eurobank’s operations and upstream and downstream value chain. Eurobank monitors
and reviews the information related to interested parties and stakeholders and their related requirements, defining a specific
cooperation framework and communication method for each case. The Sustainability Management Committee is accountable for
overseeing the Environmental, Energy and other sustainability-related ISO Management Systems, Policies and Procedures, ensuring
their continuing suitability and adequacy. In addition, the Environmental System Manager, Environmental Coordinators and Building
Administrators play a key role in the maintenance of the pertinent ISO certified Management Systems.
The
Environmental Policy
Statement outlines Eurobank’s commitment to the protection of environment, seeking the optimum use
of natural resources, mitigating its environmental impact, adapting to climate change, protecting biodiversity and ecosystems, and
preventing waste pollution.
The
Energy Management Policy
facilities, including branches and administration buildings. Key objectives include the continuous improvement of the energy
performance and the Energy Management System (EnMS), providing the information and resources needed to achieve the goals and
energy objectives, and ensuring compliance with applicable legal/regulatory requirements, and other commitments of the Bank
regarding energy use, energy consumption and energy efficiency. Eurobank aims to streamline the energy use by minimising the
energy costs, the environmental impacts, and fossil fuel use, while promoting renewable energy sources and maintaining
business/operational goals and a suitable working environment for its employees. The policy applies across the Bank’s operations,
focusing on enhancing energy efficiency and supporting the use of energy-efficient equipment. It is backed by top management,
which is responsible for providing resources to implement and improve energy performance.
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The
Water Management Policy
the optimal use of natural resources as part of the overall Environmental culture.
The
Environmental Report
performance. This report covers the operating context, the environmental legislation, targets and performance and personnel
training. The Report applies across the Bank’s operations, focusing on communicating about energy performance and setting targets.
Eurobank recognises the importance of engaging closely and promoting dialogue with all stakeholders, both natural and legal entities.
Accountable for the implementation of the Report is the Sustainability Management Committee, chaired by the General Manager,
Group Strategy.
The
GHG emissions Inventory Report
calculation of the Bank’s greenhouse gas (GHG) emissions for all its facilities in Greece. It covers 100% of its operations and has been
prepared in accordance with the requirements of the ISO 14064-1:2018 standard.
For the efficient implementation of these policies, the Bank applies certified management systems, in accordance with international
standards, such as an Environmental Management System (ISO 14001, EMAS) and an Energy Management System (ISO 50001).
Through these certified management systems, the Bank monitors its performance and minimises its carbon footprint.
The subject matter of selected financed impact policies is outlined below:
The
Sustainable Finance Framework
applied classification approach and the activities defined as eligible to access sustainable financing (eligible green and social assets).
The SFF scope encompasses a wide range of sustainable lending products, covering both corporate and retail banking portfolios. The
purpose of establishing the SFF is to provide a clear and comprehensive methodology for classifying, monitoring and reporting
sustainable financing. Eurobank has drawn on internationally recognised industry guidelines and principles for the development of
the SFF and is fully committed to being transparent about its sustainability approach. The Group Senior Sustainability Officer (GSSO)
holds the highest level of accountability for the implementation and oversight of the policy within the organisation.
The
Sustainable Investment Framework
alignment with long-term sustainability goals. Its scope includes both direct and indirect investments across all sectors, regions, and
value chains, with exclusions in areas such as high-risk fossil fuels and activities detrimental to biodiversity or human rights. The policy
applies to all stakeholders involved in the investment process. Accountability for its implementation lies with the organisation's Group
Senior Sustainability Officer (GSSO).
The
Green Bond Framework
projects that contribute to climate change mitigation and other environmental goals. Its general objectives include promoting green
investments, while ensuring transparency and accountability in the use of proceeds. The scope of the framework covers both
upstream and downstream activities related to eligible projects, across global geographies, with exclusions for projects involving fossil
fuels, or other environmentally harmful practices. Accountability for its implementation lies with the organisation's Group Senior
Sustainability Officer (GSSO).
The purpose of the
Sustainability Risk Management Policy
main governance arrangements, as well as tasks performed by the Group Sustainability Risk (GSR) unit, in the context of the Group’s
overall Sustainability Risk management activities. This policy additionally covers the Group’s main Sustainability Risk management
pillars, lists the key responsibilities of GSR for the development and implementation of the Sustainability Risk framework and
describes the quantitative and qualitative sustainability risks measurement methodologies. Ongoing dialogue with the Group’s
relevant stakeholders, as well as close monitoring of the regulatory framework and best market practices, ensure the establishment
of a well-defined and robust Sustainability Risk Management Policy. Accountable for the implementation of the policy is GSR and the
policy is approved by Management Risk Committee and Board Risk Committee.
The
Group Climate Risk Stress Test (CRST) Framework
requirements for designing, executing, approving, and applying the climate risk stress test. The Framework provides a transparent
and repeatable process for designing and executing the climate risk stress test, as well as for reporting and evaluating stress test
outcomes and determining management actions. The CRST Framework has been developed as per the overall Stress Testing Policy of
the Group, also taking into account the provisions of the ECB Guide on climate-related and environmental risks and the requirements
of the 2022 ECB Climate Risk Stress Test. Additionally, the Framework complies with other best practices and supervisory
requirements, such as the EBA Guidelines on institutions’ stress testing (EBA/GL/2018/04).
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The Group is currently advancing the development of its
Transition Finance Framework
, which will serve as a core tool for facilitating
both client-level and portfolio-level transitions. By providing clear eligibility criteria and guidance for financing transitional activities,
the Framework will strengthen the Group’s ability to support counterparties in decarbonising their operations and align the overall
portfolio with credible transition pathways. Through its
Exclusion List
, Eurobank also maintains a list of activities that are excluded
from financing, in line with the exclusion lists of the EBRD. For all financing transactions, the Group ensures that its clients
demonstrate an organised and systematic approach to E&S risk management that complies with applicable local, national and
international environmental, health and safety, and labour legislation and standards, relevant permits, as well as public disclosure
requirements.
The material impacts, risks and opportunities that the policies are related to are referenced above in the table.
Actions and resources in relation to climate change policies [E1-3]
Eurobank’s Operational Impact Strategy aims to achieve Net Zero operational impact for Scope 1 & 2 emissions by 2033 and for Scope
3 by 2050, with 2019 as the baseline year. The main decarbonization levers and actions include:
Energy Efficiency and Self-Generation of Electricity (Scope 1 & 2)
To
reduce emissions from operations, the Bank focuses on improving building efficiency and generating renewable energy:
●
Building Upgrades:
technical interventions such as LED light fixture installations, minimum energy class of A+ air conditioning, heat recovery
ventilation systems, and system -level building upgrades.
●
Energy Self-Production:
1,203 PV panels were installed on the roof of Nea Ionia complex and 376 on the roof of Acharnes building. In 2024, energy
self-production began in May (N.Ionia) and July (Acharnes). For 2025, energy production was 922.28MWh (N.Ionia) and
315.31 MWh (Acharnes).
●
Renewable Energy Procurement:
of origin). In 2025, 98.04% of total electricity consumed was sourced from RES (certified guarantees of origin and self-
production).
●
Virtual net billing scheme:
electricity supplies of its properties with a remote photovoltaic electricity generation station with an installed capacity of 8
MWp. The expected electricity production of the station is estimated at 13 GWh, aiming to simultaneously cover
approximately 10.3 GWh of energy consumption of the Bank's properties.
Energy Management System (EnMS) and Monitoring
To
monitor and improve energy performance, the Bank applies structured processes under its EnMS:
●
Energy Identity Communication:
●
Performance Metrics:
●
Technical Interventions:
required.
Green Building Certifications
Eurobank invests in upgrading its real estate portfolio and certifying buildings as green:
●
Portfolio Upgrade:
buildings are certified as green buildings, and certified properties have been included in the SBC Yearbook for Green
Buildings. (Four certified green buildings were sold in 2025, while two additional buildings were certified, resulting in a
current total of 18 certified green buildings.).
●
Nature-Based Features:
carbon transportation, promote biodiversity, and encourage water-efficient strategies and reuse. They also incorporate
water reuse through alternative sources, im proved management, and potable water quality considerations, ensuring
efficient utilization of this finite resource.
Electromobility (Scope 1)
To
reduce fleet emissions, Eurobank is transitioning to electric mobility. The Group is gradually increasing the share of plug-in and
electric vehicles in its fleet and installing EV charging infrastructure at its buildings.
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In 2025, 72.88% of the Bank’s leased vehicles are plug-in/electric (88.39% of the new contracts), as part of its efforts to accelerate
the complete replacement of its fleet with electric or hybrid vehicles.
Management Systems & Buildings (Scopes 1, 2, 3)
The Bank ensures compliance and performance through the application of certified ISO Management Systems across all its facilities,
covering 100% of its operations. These include the Environmental Management System (ISO 14001, EMAS) and the Energy
Management System (ISO 50001), which have contributed to substantial reductions in energy consumption and greenhouse gas
emissions. Additionally, the Bank verifies its greenhouse gas emissions in compliance with ISO 14064-1, ensuring accuracy and
transparency in reporting.
Performance and Results
The Bank monitors progress against its targets and reports measurable reductions achieved in 2025, compared to 2024. These include
a 4.40% reduction in purchased electricity consumption, a 24.78% reduction in Scope 1 emissions, a 28.54% reduction in Scope 2
emissions, and a combined 28.24% reduction in Scope 1 and 2 emissions —surpassing the 2% target set for 2025.
Planned Initiatives
To
achieve its Net Zero commitments, Eurobank plans a series of strategic initiatives. These include maintaining and updating its
Operational Net Zero Action Plan aligned with SBTi, expanding energy self-production through the development of standalone PV
parks by 2028, and increasing electromobility for leased vehicles. The Bank also aims to achieve 100% electricity consumption from
renewable sources by 2028, continue energy upgrades and green building certifications, and utilize carbon credits for natural gas
emissions (up to 3% of total Scope 1 and 2 emissions) by 2028.
Technical Energy Saving Actions for 2026
The Bank will implement targeted technical actions to enhance energy efficiency across its operations. These include continuing the
installation of LED lighting, VRF air conditioning systems, autonomous air-conditioning units and air-cooled air-conditioning systems
with energy class of A+, and heat recovery ventilation in new branches and refurbishment projects, as well as conducting energy
audits during renovations.
Comletped actions in 2025
2025 was the fourth year of implementation of the Bank’s operational impact strategy, with the following completed actions
demonstrating progress:
●
Update of the operational Net Zero Roadmap and transition curves with 2024 data, in line with the transition pathways that
are aligned with the Paris Agreement target of limiting global warming to 1.5
o
C.
●
Verified operational carbon footprint for 2024 as per ISO 14064, in line with National Climate Law stipulations.
●
Considerable reduction of 4.40% in purchased electricity consumption, reduction of 28.54% of equivalent Scope 2 emissions
and reduction of 28.24% of equivalent Scope 1 &2 emissions (surpassing the 2% 2025 target) in 2025, compared to 2024.
●
98.04% of total electricity consumed in 2025 was sourced from Renewable Energy Sources (certified guarantees of origin
and self-production).
●
There was an 84.59% increase in paper recycling, with 97.56% originating from the disposal of physical historical archives.
●
14.3tn of small electrical appliances, mobile phones, tablets, ink and ink cartridges were placed in the recycling Hungry Bins
installed in 11 locations throughout Greece, since the launch of the programme.
The Group has integrated the Financed Impact Strategy into its operations and made significant progress towards achieving its targets.
1.
Operationalised its Sustainable Finance Framework
The Group has developed governance structures, processes and tools that enable the identification of sustainable financing
opportunities, engagement with clients on sustainable financing offerings and assessment of financings against the SFF criteria into
daily operations.
Key elements include the introduction of dedicated roles for guiding relationship managers, the integration of the wider process for
classification and evaluation according to the SFF within the Bank’s systems, and the extension of the approach to retail business
banking with co-financing programmes and tailored products.
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2.
Enhanced its capabilities for the collection of sustainability risk data
The Group is continuously enhancing its capabilities for the collection of Sustainability risk data, through the integration of additional
information requirements in the credit process, as well as cooperating with third-party data providers. It has implemented a set of
tools for identifying, measuring and managing sustainability risks, including the credit granting and monitoring processes.
These are used by the Units involved across the Group’s both 1st and 2nd lines, with the relevant tasks being performed in a
collaborative and efficient way. Having already performed an assessment of sustainability data availability in its internal systems
against regulatory requirements / expectations, the Group continues to enhance its sustainability risk data aggregation capabilities
and IT infrastructure accordingly, while also using appropriate controls and safeguards to ensure the accuracy and completeness of
the compiled information. The Group seeks to further improve environmental risk data granularity, through the allocation of detailed
roles and responsibilities for the purposes of sustainability data management and addressing identified data needs (i.e., engagement
with external data providers, development of methodological approaches for the estimation of required information).
3.
Intensified engagement with its counterparties on sustainability risk mitigation
Aiming to facilitate the green transition of its clients, the Group has developed a dedicated approach to increase client engagement
and awareness regarding environmental risks. Besides the initiatives launched aiming to build sustainability literacy and capacity
among its clients (e.g. online events, articles and webinars, digital academy for businesses), the Group also uses tools to engage with
its counterparties in the context of its credit granting and asset management activities, so as to understand their strategies and
mitigate their sustainability risks exposures.
4.
Expanded its sustainable offerings
As part of the periodic revision of its SFF, the Group introduced new activities that contribute to sustainable objectives through the
inclusion of emerging technologies as well as national and sectoral investment plans. Additionally, it leverages all available co-
financing programmes with sustainability objectives to promote the green transition of its entire client base.
5.
Achieved the sustainable financing targets set as part of its financed impact strategy
For the fourth consecutive year, Eurobank achieved the sustainable financing targets related to its corporate portfolio, set as part of
its Financed Impact Strategy. New SFF-aligned annual disbursements met the 20% target of total corporate disbursements, while
corporate sustainable exposures increased from €2.98 billion in 2024 to €4.11 billion in 2025, posting a 38% year-on-year growth.
More information on the Group’s actions on climate change related matters is detailed in the chapters “Sustainable financing and
investment offerings” and “Integration of sustainability in risk management”.
Subsidiaries Climate Change Actions
In addition to Group-level climate change initiatives, Eurobank’s subsidiaries in Bulgaria, Cyprus, and Luxembourg implement targeted
actions to reduce greenhouse gas emissions, improve energy efficiency, and support the transition to a low-carbon economy. The
following sub-sections summarize each subsidiary’s key climate-related measures and achievements.
Bulgaria (Postbank)
Postbank has in place a strategy for minimization of its environmental impact and GHG emissions reduction through measures
focusing on optimization of energy consumption, resource consumption and recycling. In 2025 the bank made significant progress in
energy management and decarbonization. In 2025, the bank’s photovoltaic plant in Sofia, produced 341 MWh electricity covering
approximately 20% of the head office’s energy needs. As of 31/12/2025, over 96% of the branch network has been renovated for
energy efficiency, including advanced HVAC and building management systems. These efforts resulted in 25% decrease in diesel
consumption for heating and emergency power generation YoY and 73% since 2022. Natural gas use was reduced by 21%. More than
80% of the company vehicle fleet is now hybrid and automobile fuel consumption decreased by 2.5% YoY. Four charging stations for
electric vehicles are available for employees in the Head Office. As part of its commitment to accelerate the transition to paperless
banking, in 2025 Postbank continued investing significant resources in digitalization, process optimization and systems upgrades that
decrease office paper use and offer improved customer experience. In 2025, the bank purchased around 8% less office paper than in
2024.
Cyprus (Eurobank Limited and insurance subsidiaries)
Eurobank Limited continued to advance its energy transition and energy efficiency agenda in support of its decarbonisation objectives.
In 2025, photovoltaic systems were installed in five buildings, generating approximately 210,000 kWh per year, with a further six
installations planned, expected to generate an additional 230,000 kWh per year, increasing on-site renewable energy generation and
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lowering the carbon intensity of electricity consumption. In parallel, the bank transitioned its electricity procurement towards
suppliers generating power from photovoltaic parks, strengthening the renewable profile of purchased electricity. Energy efficiency
initiatives were launched in 2025 across eight buildings, with one
project successful completed within the year and the remaining
improvements scheduled for completion in 2026, contributing to reduced energy demand and associated greenhouse gas emissions.
Eurobank Limited maintains the ISO 14001 certification for environmental management, while for ex Hellenic Bank buildings it also
holds the ISO 50001 certification for energy management, reinforcing structured governance and continuous improvement of
environmental and energy performance. In addition, Eurobank Limited implemented staff awareness initiatives on recycling and
responsible energy use, supporting behavioural change and the effective execution of the decarbonisation strategy.
The Action Plans for decarbonisation of own operations (scopes 1 and 2 emissions) will be updated for the merged entity within 2026.
ERB CIH conducted a mandatory energy audit in 2021, which identified several energy-efficiency measures. Since then, the company
has implemented upgrades such as LED lighting and photovoltaic installations on two buildings (one operational in 2025, the second
planned for 2026). All owned buildings were also assessed for further photovoltaic potential, resulting in two additional suitable sites
for future installation.
Luxembourg (Eurobank Private Bank Luxembourg)
Eurobank Private Bank Luxembourg has continued focusing on sustainable energy sourcing and infrastructure upgrades. All new
leased vehicles are electric or hybrid. The building management system has been upgraded for more efficient temperature and
humidity control, optimizing energy consumption. Importantly, 100% of the electricity consumed by the Bank is sourced from
renewable energy, resulting in zero Scope 2 market -based emissions. The Bank is crystallizing its ESG strategy, which will include
further targets for energy optimization and emission reduction, in alignment with Group objectives.
2.2.4 Metrics & Targets
Targets related to climate change mitigation and adaptation [E1-4]
Through its Sustainability Strategy, the Bank’s overarching climate-related target for its operational impact is to achieve Net Zero
emissions by 2033 for Scope 1 & 2 and by 2050 for Scope 3. The interim targets supporting the Net Zero commitment are the following:
Reduction in Electricity Consumption and Greenhouse Gas Emissions – Operations in the Bank
Performance -
2024
Target 2025
(%)
Target value -
2025
Performance
2025
Change (%)
Status
Target 2026
(%)
Target value -
2026
Reduction in total
electricity
consumption
(ΜWh)
33,771
-2
33,096
32,709
-3.15
Target
achieved
-1
32,382
Reduction of GHG
Emissions Scope 1
(tCO
2
e)
1,435
-2
1,406
1,079
-24.78
Target
achieved
-1
1,068
Reduction of GHG
Emissions Scope 2
(tCO
2
e)
16,676
-2
16,343
11,916
-28.54
Target
achieved
-1
11,797
Reduction of GHG
Emissions Scope 1
& 2 (tCO
2
e)
18,111
-2
17,749
12,996
-28.24
Target
achieved
-1
12,866
(1)
The reduction in electricity consumption concerns the total amount of electricity consumption including purchased and self-generated electricity
The targets concern all Bank’s office buildings and branches and cover 100% of its operations. As presented above, during 2025 the
electricity consumption and Scope 1 & 2 emissions have been reduced and the targets set for reduction of total electricity
consumption and of Scope 1 & 2 emissions for 2025 have been achieved.
Additional Operational Targets and Milestones
●
Establish a centralized web-based platform for energy, emissions, and environmental data by end of 2026.
●
Implement energy self-production activities:
o
Installation of rooftop PVs on Eurobank buildings by 2024 (implemented).
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o
Develop standalone PV parks by 2028.
●
Electromobility:
o
>25% of leased vehicles to be EV or plug-in hybrid (new contracts and renewals) by 2024 (implemented).
o
>75% of leased vehicles to be EV or plug-in hybrid (new contracts) by 2028.
●
100% of electricity consumed to be sourced from RES by 2028.
●
Energy efficiency upgrade of buildings contributing to Scope 1 & 2 emissions by 2033.
●
Increase the number of certified green buildings in Eurobank’s portfolio by 2 by 2033 (baseline: 2023).
●
Monitor, certify, disclose, and optimize Scope 1, 2, and 3 operational emissions in line with GHG Protocol by 2028.
●
Carbon credits (nature-based carbon removal projects in line with SBTi) for natural gas emissions, up to 3% of total Bank’s
Scope 1 & 2 emissions by 2028.
●
Maintain and update detailed Operational Net Zero Action Plan (SBTi aligned, baseline year 2019) for Scope 1 & 2 (Net Zero
by 2033) and Scope 3 (Net Zero by 2050).
Financed Impact Strategy: Net Zero Targets
Eurobank’s commitment to sustainability is at the heart of its strategic vision. Aligning with global climate goals and addressing the
urgent need to tackle climate change, the Group has committed to aligning its portfolio emissions with 1.5°C climate transition
pathways and achieving Net Zero by 2050. These commitments demonstrate Eurobank’s dedication to supporting the low-carbon
economy transition and ensuring its financial practices are responsible and forward-thinking.
The Group has developed its first set of 2030 sectoral emission reduction targets for the most carbon-intensive and influential sectors
in its portfolio. These targets are based on science-based decarbonization pathways and internationally recognized standards, such
as the Partnership for Carbon Accounting Financials (PCAF), and follow the International Energy Agency’s Net Zero Emissions (IEA
NZE) scenario.
Sectoral Net Zero Targets for 2030
Eurobank’s approach focuses on four priority sectors, namely Power generation, Oil and gas, Iron and steel, Cement, that represent
a substantial share of its financed emissions.
For further details on Eurobank’s Net Zero approach, please refer to the section
“Pathway to Net Zero and Sectoral Targets”
. This
section provides an in-depth overview of the methodological framework, including the decarbonisation pathways, science-based
scenarios, and Eurobank’s sector-specific approach to target-setting. It also explains the rationale behind the selected sectors, the
reference scenarios used (such as IEA NZE), and the process for monitoring and updating progress toward the 2030 and 2050 Net
Zero commitments.
In addition to the sectoral Net Zero targets mentioned above, Eurobank has also set specific sustainable finance and investment
targets that support climate change mitigation and adaptation objectives. These targets are explicitly referenced in the section
“Targets – Sustainable Finance and Investment Offerings.” They reflect the Group’s commitment to integrating sustainability factors
into its financial services and funding projects that deliver positive environmental and social impact, guiding the transition to a more
sustainable economy.
Energy consumption & mix [E1-5]
According to the energy review conducted in the context of the EnMS implementation, the Energy consumption at Eurobank occurs
from:
●
Burning of natural gas and oil for heating,
●
The use of diesel and petrol by vehicles used for transporting materials between its buildings within Attica, as well as its
corporate leased cars for staff, and
●
The use of electricity for the organisation’s operations.
The table below outlines the total energy consumed by the Group’s operations, along with the breakdown of the energy sources
used, including the share of renewable and non-renewable energy. By sharing this information, the Group aims to provide a clearer
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understanding of its efforts to manage energy usage, reduce carbon emissions, and transition to more sustainable energy practices
in line with its broader environmental goals. The table below details the Group’s energy consumption and mix for the reporting period.
Unit
2025
2024
Total energy consumption and mix (including purchased or acquired electricity, heat, steam, and cooling from fossil sources)
(1) Fuel consumption from coal and coal products
MWh
0
0
(2) Fuel consumption from crude oil and petroleum products
MWh
5,384
5,427
2.1 Fuel consumption from petrol
MWh
3,010
2,921
2.2. Fuel consumption from diesel
MWh
2,100
2,233
2.3. Fuel consumption from LPG (Liquefied Petroleum Gas)
MWh
157
171
2.4 Fuel consumption from heating oil
MWh
117
101
2.5 Fuel consumption from other crude oil and petroleum products
MWh
0
0
(3) Fuel consumption from natural gas
MWh
3,800
4,066
3.1 Fuel consumption from natural gas
MWh
3,798
4,066
3.3 Fuel consumption from CNG (Compressed Natural Gas)
MWh
1
0
(4) Fuel consumption from other fossil sources
MWh
0
0
(5) Consumption of purchased or acquired electricity, heat, steam, and cooling from
fossil sources
MWh
23,427
23,611
(6) Total energy consumption from fossil sources
MWh
32,611
33,105
Share of fossil sources in total energy consumption
%
49
49
(7) Total energy consumption from nuclear sources
MWh
0
0
Share of consumption from nuclear sources in total energy consumption
%
0
0
(8) Fuel consumption from renewable sources, including biomass (also comprising
industrial and municipal waste of biologic origin), biofuels, biogas, renewable
hydrogen, etc.
MWh
0
0
(9) Consumption of purchased or acquired electricity, heat, steam, and cooling from
renewable sources
MWh
31,681
33,037
(10) The consumption of self-generated non-fuel renewable energy
MWh
1,907
1,450
(11) Total renewable energy consumption
MWh
33,587
34,487
Share of renewable sources in total energy consumption
%
51
51
Total energy consumption
MWh
66,198
67,592
In 2025, the Group’s total energy consumption amounted to 66,198 MWh, compared to 67,592 MWh in 2024, reflecting a marginal
decrease mainly driven by lower electricity consumption across the Group.
Despite the slight reduction in total consumption, the composition of the energy mix remained stable. Renewable energy
consumption reached 33,587 MWh in 2025 (2024: 34,487 MWh), representing 51% of total energy consumption, consistent with the
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prior year. This result reflects a modest decrease in purchased renewable electricity, partially offset by an increase in self-generated
renewable energy, which rose to 1,907 MWh (2024: 1,450 MWh).
Figure 1
:
Total energy consumption
At the same time, the share of fossil energy sources remained stable at 49% in both 2025 and 2024. Total fossil energy consumption
amounted to 32,611 MWh in 2025 (2024: 33,105 MWh), reflecting a slight decrease, driven by lower natural gas consumption (3,800
MWh in 2025 vs 4,066 MWh in 2024) and marginally lower consumption of crude oil and petroleum products. The Group did not
consume energy from nuclear sources in either 2025 or 2024, and therefore nuclear energy represents 0% of total energy
consumption in both years.
Figure 2: Share of energy sources to the total enegy consumption
Overall, the Group maintained a stable energy mix, with continued reliance on renewable sources and fossil energy use, supporting
the Group’s progress toward its longer-term decarbonisation objectives.
Data Verification and Methodology
The above consumptions have been based on actual consumption data for a 10-month period of 2025, while for the remaining 2
months where actual data were not available, due to timing constraints, consumptions were extrapolated based on the same period
in previous years. Actual consumption data for the Bank have been verified according to ISO 14064-1 while the estimation
methodology has been validated according to ISO14064-2 by an independent certification body. For 2024, actual consumption data
were collected from the entities and incorporated into the reported figures where available. Following a refinement in the
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methodology used to calculate the share of energy consumption by source, the 2024 comparative figures have been restated to
ensure consistency and comparability with the 2025 disclosures. The Group does not have material biogenic CO₂ emissions arising
from the combustion or bio-degradation of biomass; therefore, the separate disclosure of biogenic CO₂ emissions is not applicable.
Energy Self-Production
Energy self-production is a crucial element of Eurobank’s journey towards Operational Net Zero. The relevant project stream of the
Operational Impact Strategy includes 2 distinct self-production initiatives:
●
Rooftop photovoltaic (PV) stations installed on Eurobank buildings.
●
Standalone PV parks.
These initiatives are implemented as cross-unit projects with the support of dedicated consultants and with regular updates to Senior
Management. The energy and emission benefits of these projects are calculated in the Operational Net Zero transition path to carbon
neutrality for Scope 1 & 2 by 2033, per the respective commitments of Eurobank.
Furthermore, the Group has produced 2,019 MWh of energy from renewable sources. This includes energy produced from PV panels
in Group’s operations in Greece, Bulgaria, and Cyprus.
Gross Scopes 1, 2, 3 and Total GHG emissions [E1-6]
Commitment and Standards
Eurobank is committed to reducing its environmental footprint and actively contributes to the reduction of greenhouse gas emissions.
As part of this effort, the Bank applies the International Standard ISO 14064-1:2018 for the quantification and reporting of greenhouse
gas emissions (Category 1-6) as well as GHG removals. The pertinent correspondence with the International Standard “GHG Protocol
Corporate Accounting and Reporting Standard” (Scope 1, 2 & 3) is also mentioned. In this context, energy consumption is recorded
and allocated as well as the direct and indirect greenhouse gas emissions are calculated.
Scope Definitions and Sources
Direct emissions (Scope 1) resulting from the Group’s operations reflect GHG emissions released by burning oil and natural gas to
heat buildings and oil used to power generators (Direct emissions from stationary combustion), the use of diesel and petrol by the
Group’s owned transport vehicles, from the leased corporate cars for the staff (Direct emissions from mobile combustion) and the
fugitive emissions from the Group’s air conditioning systems and the automatic extinguishing systems (Direct fugitive emissions from
the release of GHGs in anthropogenic systems).
Indirect emissions are those released by the consumption of electricity (Scope 2) as well as other indirect emissions (Scope 3)
associated with employee business travel (air travel and hotel stay) , employee commuting (including homeworking), waste
management, transportation and distribution of goods, capital goods, purchased good and services, fuel and energy related activities,
downstream leased assets and emissions from cloud computing usage have also been included.
When a new category is added, the amount for that category is added to the previous year to normalise the baselines for comparison
reasons. The emissions from new categories will also be included in the operational Net Zero for Scope 1 & 2 by 2033 and for Scope
3 by 2050 project, according to the SBTi methodology.
Emission Factors and Verification
As per emissions, the Eurobank Group in Greece utilises emissions conversion coefficients from National Inventory Report (NIR)
Greece, Renewable Energy Sources Operator & Guarantees of Origin (DAPEEP SA), Department for Environment, Food & Rural Affairs
(UK- DEFRA) (full set, version 1.0 of2025), EXIOBASE (2019 emission factors for Greece), BEIS (2022 and 2025 emission factors,
Greenview, EPA database (2022 emission factors) and Global Warming Potential (GWP), as needed for each specific case.
The Bank verifies the above greenhouse gas (GHG) emissions in compliance with ISO 14064-1, which provides a framework for
quantifying and reporting GHG emissions and removals.
The table below demonstrates the breakdown of the Group’s Scope 1,2,3 emissions:
Total Scope 1,2,3 emissions
Breakdown of Greenhouse Gas emissions
2025
2024
Gross Scope 1 GHG emissions (tCO
2
e)
3,091
3,532
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Breakdown of Greenhouse Gas emissions
2025
2024
Percentage of Scope 1 GHG emissions from regulated emission
trading schemes (%)
0
0
Gross location-based Scope 2 GHG emissions (tCO
2
e)
23,063
27,742
Gross market-based Scope 2 GHG emissions (tCO
2
e)
10,951
10,713
Total Gross indirect
(2)
2
e)
117,755
82,987
1 Purchased goods and services
45,231
39,409
Cloud computing and data centre services
183
211
2 Capital goods
36,424
28,277
3 Fuel and energy-related Activities (not included in Scope 1 or
Scope 2)
14,796
6,476
4 Upstream transportation and distribution
517
492
5 Waste generated in operations
1,169
719
6 Business traveling
765
444
7 Employee commuting
7,513
7,170
8 Upstream leased assets
0
0
9 Downstream transportation
0
0
10 Processing of sold products
0
0
11 Use of sold products
0
0
12 End-of-life treatment of sold products
0
0
13 Downstream leased assets
11,158
0
14 Franchises
0
0
15 Investments
Please refer to financed emissions table below
Total GHG emissions (location-based) (tCO
2
e)
143,909
114,261
Total GHG emissions (market-based) (tCO
2
e)
131,798
97,232
Luxemburg is only included in investments emissions (Scope 3 Category 15)
In 2025, the Group’s total GHG emissions increased to 143,909 tCO₂e on a location-based basis (2024: 114,261 tCO₂e) and to 131,798
tCO₂e on a market-based basis (2024: 97,232 tCO₂e).
Scope 1 emissions decreased to 3,091 tCO₂e in 2025, down from 3,532 tCO₂e in 2024, reflecting lower direct fuel consumption across
the Group’s operations. As in previous years, none of the Group’s Scope 1 emissions fell under regulated emission trading schemes.
Scope 2 emissions also continued their downward trend, amounting to 23,063 tCO₂e (location-based) in 2025 compared to 27,742
tCO₂e in 2024. In terms of market-based emissions, those demonstrated a slight increase from 10,713 tCO₂e in 2024 to 10,951 tCO₂e
in 2025. Overall, the reduction in Scope 2 emissions demonstrates the Group's improved energy mix and its continued use of
renewable electricity sources across operations.
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By contrast, Scope 3 emissions increased significantly, rising to 117,755 tCO₂e in 2025 compared to 82,987 tCO₂e in 2024. This increase
is the main driver behind the overall rise in total GHG emissions.
Scope 3 emissions increased in 2025 compared to 2024, becoming the main contributor to the overall rise in the Group’s GHG
footprint. This change is mainly the result of an expanded reporting perimeter: Eurobank Cyprus reported its Scope 3 emissions for
the first time, and CNP Insurance in Cyprus was also incorporated into the Group’s sustainability reporting. As a result, categories
such as Capital Goods, Fuel and Energy-Related Activities, and Downstream Leased Assets now capture activities that were previously
outside the boundary. In parallel, higher levels of capital expenditure across the Group led to greater associated upstream emissions,
while improved data completeness and methodological refinements strengthened the overall accuracy and coverage of the inventory.
In Greece, the increase in Scope 3 emissions reflects more comprehensive reporting rather than a deterioration in performance.
Capital Goods emissions rose due to an increase in the value of fixed assets, which resulted in higher calculated upstream emissions.
Fuel and Energy-Related Activities also expanded to include for the first time emissions from the off-site ATMs, following a more
complete accounting of upstream energy consumption impacts. Additionally, in the Downstream Leased Assets category, commercial
real estate owned by the Bank and leased to third parties was incorporated for the first time.
Despite this broadening of coverage and the resulting increase in Scope 3, the Group maintained reductions or stability in its direct
(Scope 1) and energy-related indirect (Scope 2) emissions, demonstrating continued progress on decarbonising its own operations.
The overall rise in Scope 3 therefore reflects improved transparency, expanded organisational and reporting boundaries, and
enhanced data completeness rather than an underlying escalation in the Group’s operational footprint.
I
n addition, some entities calculated and reported Scope 3 emissions for the first time in 2025; these newly included datasets have
further contributed to the overall increase, as their emissions are now incorporated into the Group’s consolidated Scope 3 total.
Overall, while direct emissions (Scope 1) and energy-related indirect emissions (Scope 2) decreased, the rise in Scope 3 emissions
reflects the expanded scale of the Group’s activities in 2025 and underscores the need for continued engagement and collaboration
with value-chain partners to support the Group’s decarbonisation objectives.
Figure 3: 2024 vs 2025 Scope 1,2 emissions
Operational GHG emissions
The above data may be modified due to issuance of new version of emissions conversion coefficients (emissions factors) during 2026
from the Ministry of Environment and Energy, due to the new climate law 4936/2022 (Government Gazette 105/A/ 27.05.2022), for
operations in Greece, or relevant Laws in the countries where the Eurobank Group operates.
The location-based method reveals what is physically emitted by the Group, while the market-based approach concerns residual
emissions for which the Group does not procure Guarantees of Origin (GO’s). 94.49% of the Bank’s operations in Greece electric
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energy will be certified from Renewable Sources (Guarantees of Origin will be acquired during 2026). The Bank has an annual
Guarantee of Origins (GOs) contract with the electricity provider.
The Group has identified the significant Scope 3 categories for its operational impact, by considering estimated GHG emissions
alongside criteria outlined in the GHG Protocol Corporate Value Chain (Scope 3). This identification process involved factors such as
financial spend, influence, transition risks and opportunities, and stakeholder perspectives. The categories include:
●
Employee commuting and homeworking
●
Business travel (air -travel and hotel-stay)
●
Upstream transportation and distribution
●
Purchased Goods and Services
●
Capital Goods
●
Fuel and Energy related activities
●
Waste disposal and Water consumption
●
Cloud Computing Usage
●
Downstream leased assets
When a new category is added, the amount for that category is added to the previous year and the base year to normalise the
baselines for comparison reasons.
Assumptions applied
The calculation of the Scope 1 and Scope 2 emissions was made using actual data for a 10-month period and estimated / extrapolated
data for a 2-month period. Emissions for the Bank’s operations (including the assumptions / extrapolations approach) has been
verified/validated by an independent certification body according to ISO14064-1 and ISO 14064-2 respectively.
Eurobank estimates Scope 1, 2, and 3 emissions by assuming that historical consumption patterns can predict future trends, allowing
past data to guide current and future emissions estimates. This approach presumes consistency in usage over comparable periods,
making it especially useful for stable operations. In the absence of historical data, Eurobank uses average consumption from the
current year to project future usage, assuming that current performance can provide an accurate forecast. Where feasible, the Group
utilises primary / source data for the relevant calculations, either from its own sources or by acquiring them from its value chain
stakeholders (i.e. suppliers). When those are not available, it employs estimations, assumptions and extrapolations that produce
reasonable outcomes.
These assumptions enable the Eurobank Group to maintain flexibility and accuracy in its emissions estimation, adapting to varying
levels of data availability. By doing so, the Group supports its sustainability goals and ensures compliance with environmental
reporting standards, providing a comprehensive view of its environmental impact.
Where actual consumption data were available for the 2024 reporting year, these data were collected from the relevant entities and
the 2024 emissions figures were updated accordingly.
For the 2025 reporting cycle, the Group recalculated its previously published 2024 total GHG emissions and total energy
consumption, both under the note 2.2.4, to replace the initial disclosures which were based on 10-month activity data and
extrapolated estimates—with full-year actual data now available. This revision was undertaken to improve accuracy and
comparability in accordance with ESRS 2 BP-2 requirements. Following this update, total 2024 GHG emissions (location-based)
increased from 106,386 tCO₂e to 114,261 tCO₂e (+7.4%), and total market-based emissions increased from 89,772 tCO₂e to 97,232
tCO₂e (+8.3%). Total energy consumption for 2024 also increased from 65,649 MWh (originally reported) to 67,592 MWh (+3.0%)
after replacing estimated values with actual consumption data. These differences reflect the use of complete full-year actual data
rather than estimation methodologies and do not indicate changes in underlying operational performance.
Perimeter of Estimation
The emissions estimation process covers the entire Eurobank Group, aligning with the perimeter defined in the Group's Sustainability
Statement. This approach ensures that all operations and activities are considered, providing a comprehensive view of Eurobank's
environmental impact and supporting its commitment to sustainability.
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Contractual instruments
Unit
2025
2024
Contractual instruments used for the purchase of bundled energy with
attributes about energy generation in relation to Scope 2 GHG emissions
MWh
30,906
33,037
In 2025 the Bank continued to purchase green energy from Renewable Energy Sources (RES) with Guarantees of Origin (GOs). More
specifically, 30,906 MWh of purchased electricity was sourced from renewable sources.
Financed emissions
Overview
Financed emissions represent the most material Scope 3 category for Eurobank, accounting for more than 99% of the Group’s total
emissions. These emissions form the basis for Eurobank’s sectoral decarbonisation action plan and its commitment to align its
portfolio with 1.5°C transition pathways and achieve Net Zero by 2050.
Methodology and Calculation Approach
The Group calculates and discloses its financed emissions (category 15) following the PCAF methodology, which is based on a revenue-
based approach, with emission factors estimated for each sector and country through a multiregional input-output analysis
framework, noting that reported emissions from Group’s counterparties have been used where available across Scope 1, 2 and 3.
Where one or more reported scope categories were not disclosed / complete, the Group has incorporated estimated emissions
according to its internal methodology, in line with the PCAF standard.
More specifically, the Group applies a waterfall approach for the calculation of the financed emissions:
●
To the extent possible, published (reported) emissions of the counterparties are used. (Option 1 – Reported emissions)
●
For sector D 35.11 physical activity-based emissions are reported, where published (reported) emissions are not available,
(Option 2 – Physical activity-based emissions)
●
In all other cases the scope 1, 2 and 3 emissions are calculated based on the economic activity data of the counterparty (i.e.,
EUR of revenue) and appropriate emission factors expressed per economic activity (e.g., tCO
2
e/million EUR output of the
corresponding sector) (Option 3 – Economic activity-based emissions.)
Total Financed Emissions
The Group discloses financed emissions for the lending and investment portfolio based on counterparties' scope 1, 2, and 3 emissions,
which total 33.1 million tonnes of CO2 equivalent (MtCO
2
e) for 2025 (2024: 28.5 MtCO
2
e). The increase compared to 2024 (+16%) is
primarily attributable to the growth in the outstanding balance of both lending and investment portfolio (c. € 5,438mn) leading to a
proportional increase in financed emissions. In addition, methodological enhancements contributed to a more risk-aligned and
emissions-sensitive allocation. Increased data availability, including greater use of counterparties published emissions, reduced
reliance on proxies and resulted in more comprehensive Scope 1, 2 and 3 coverage.
It is noted that fluctuations in total financed emissions are expected as companies refine their estimation methods and market
practices and data availability evolve. In terms of financed emissions intensity (tC0
2
e/€mn) the Corporate portfolio remained
practically stable (2025: 786 tC0
2
e/€mn, 2024: 784 tC0
2
e/€mn), while the increase in the Investment portfolio (+62 tC0
2
e /€mn) is
driven by increased availability of published emissions data and the increase in exposures.
Overall, the increase in financed emissions in 2025 is mainly attributable to portfolio growth, methodological refinements and
improved emissions data coverage, and does not indicate a material deterioration in the carbon intensity profile of the underlying
portfolio.
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Τhe table below presents the breakdown of the Group’s total financed emissions between lending and investment activities:
2025
2024
Exposure
(€mn)
Scope 1&2
(ktCO
2
e)
Scope 3
(ktCO
2
e)
Total
emissions
(ktCO
2
e)
Intensity
(tC0
2
e /
€mn)
Exposure
(€mn)
Scope 1&2
(ktCO
2
e)
Scope 3
(ktCO
2
e)
Total
emissions
(ktCO
2
e)
Intensity
(tC0
2
e /
€mn)
Lending
44,996
9,314
16,852
26,167
582
40,938
6,799
16,567
23,367
571
Corporate
32,853
8,977
16,852
25,829
786
29,364
6,440
16,567
23,007
784
Retail
12,143
338
-
338
28
11,574
359
-
359
31
Investments
24,535
3,632
3,302
6,934
283
23,155
2,647
2,470
5,117
221
Total
69,531
12,946
20,154
33,100
476
64,093
9,446
19,037
28,483
444
Scope 3 emissions within the Investment portfolio do not include emissions related to exposures to credit institutions (2025: 2,996
ktCO
2
e). As recognized by PCAF, reporting of Scope 3 emissions by credit institutions may lead to double counting as financial
institutions may account for the other financial institutions’ emissions without taking account the reverse loan/investment.
Most of the Group’s financed emissions come from its corporate portfolio lending, accounting for c.78% of the total, while Scope 3
financed emissions account for c. 61% of the total financed emissions. A breakdown per sector within corporate portfolio lending is
provided below.
Corporate portfolio lending 2025
Exposure
(€mn)
Scope 1&2
(ktCO
2
e)
Scope 3
(ktCO
2
e)
Total
emissions
(ktCO
2
e)
A - Agriculture
234
281
228
509
B- Mining and quarrying
25
5
4
8
C - Manufacturing
4,760
2,026
10,879
12,904
D - Energy
3,807
1,163
576
1,739
E- Water supply, sewerage, waste management and remediation
80
223
33
257
F
– Construction
1,239
65
732
797
G - Wholesale and retail trade
4,683
1,304
3,081
4,385
H
- Transporting and storage
6,169
3,595
515
4,110
I – Accommodation
3,369
113
428
541
L- Real estate activities
3,235
96
19
115
Exposures to other sectors (NACE codes J,K, M – U)
5,251
106
358
464
Total
32,853
8,977
16,852
25,829
Regarding the corporate portfolio, lending to the manufacturing sector has the biggest contribution, c. 50%, followed by wholesale
and retail trade, c17%, and transportation and storage, c. 16%.
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Total GHG Emissions
ESRS Quantitative data / metric
Unit
2025
2024
Total GHG emissions (location-based)
tCO
2
e
33,243,909
28,597,261
Total GHG emissions (market-based)
tCO
2
e
33,231,798
28,580,142
Total net revenue
mn €
3,430
3,341
In 2025, the Group’s GHG emissions amounted to 33.2 mn tCO
2
e with financed emissions contributing >99% and operations-related
(Scope 1,2,3) emissions accounting for less than 1%.
GHG intensity
Unit
2025
2024
GHG intensity per net revenue (location based)
tCO
2
e/ mn €
9,692
8,559
GHG intensity per net revenue (market based)
tCO
2
e/ mn €
9,689
8,554
GHG removals and GHG mitigation projects financed through carbon credits [E1-7]
For operations-related emissions, following the Science-Based Targets initiative guidance, 90% of the baseline year’s emissions will
need to be reduced and the remaining 10% will be removed by purchasing Carbon Credits. Currently there are no plans to include
Carbon Removals across Eurobank’ s value chain (upstream and downstream). As for Carbon Credits, they will only cover the
remaining 10% of emissions, complementing Eurobank’s carbon reductions across its value chain. Carbon Credits will not be used to
show Carbon Reductions across Eurobank’s value chain and they will not impede its progress towards net-zero. Eurobank’s Carbon
Credits are purchased from credible sources that follow the latest quality standards.
2.3
Biodiversity and ecosystems [E4]
2.3.1 Governance
Eurobank acknowledges that it currently does not have a dedicated governance structure in place to address biodiversity conservation
issues comprehensively. However, recognizing the increasing importance of biodiversity in achieving sustainable development and
mitigating environmental risks, Eurobank has integrated biodiversity loss as a priority theme within its existing Sustainability
Governance framework, overseeing it through the Sustainability Management Committee and the Group Sustainability Risk unit. The
Bank acknowledges, however, that guidance in this field is still evolving and is committed to progressively strengthening its expertise,
governance practices and analytical capabilities as more granular approaches become available.
Meanwhile, Eurobank engages regularly with its stakeholders, including environmental organisations, regulators, and clients, to stay
informed about biodiversity issues, thereby maintaining its alignment with best practices.
For more information regarding the Sustainability Governance please refer to: 1.3 Governance, under ESRS 2.
2.3.2 Strategy
Material impacts, risks and opportunities and their interaction with strategy and business model [ESRS 2 SBM-3]
Based on the capability of the financial sector to influence the sustainable use of nature through its business activities, Eurobank is
already taking appropriate steps to integrate biodiversity loss in its operations, by developing a corresponding response strategy and
incorporating relevant provisions in its overall strategy and risk management framework.
Eurobank is currently developing a model for integrating biodiversity considerations into its overall strategy, ensuring that its financing
and investing activities do not have a negative effect on biodiversity and ecosystems and while also promoting activities that
rehabilitate and restore ecosystems. Eurobank recognises that its physical operations have minimal effect on biodiversity and is thus
developing a proportional approach.
22
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The references to Eurobank’s Sustainability Strategy in this section relate to the Strategy currently in force during the 2025 reporting
period. In parallel, the Group is progressing the update of its Group Sustainability Strategy, which will build on the existing framework
and further strengthen the integration of sustainability across its operations and activities.
Action Plan
Eurobank’s strategic action plan around biodiversity will evolve around the following elements:
●
Risk Assessment: Integrate comprehensive transaction assessments to identify and understand biodiversity risks and
dependencies using tools like ENCORE.
●
Sector Analysis: Focus on high and medium-risk sectors, such as agriculture, forestry, water supply, mining, and energy, and
promote measures and financing that mitigates biodiversity impacts.
●
Sustainable Finance: Promote and finance activities and projects that support biodiversity conservation, rehabilitation of
ecosystems and sustainable use of natural resources.
Capacity Building and Sector Analysis
Considering the complexity of assessing the issue of biodiversity as a risk driver in relation to Eurobank’s business practices and own
operations, given the fact that the relevant guidance in this field is currently under development, Eurobank is closely following several
related initiatives and continues to build its skills and capacity, so as to ensure readiness to appropriately address such risks, upon the
availability of more granular guidelines and methodologies in this respect.
To identify business operations impacting biodiversity, the Group conducted a thorough loan portfolio analysis (materiality
assessment) to identify the sectors most vulnerable to biodiversity loss. Utilising the ENCORE tool (Exploring Natural Capital
Opportunities, Risks, and Exposure), the Group analyzed sector-specific dependencies and impacts related to biodiversity loss. The
ENCORE tool facilitates the assessment of dependencies on biodiversity loss by exploring the ways in which economic activities rely
on ecosystem services and natural capital. Based on the results, primary economic activities, such as agriculture and water supply,
are significantly more dependent on ecosystem services than other economic activities, such as transportation. This is mainly because
the production of agricultural products heavily relies on the use of groundwater, surface water, and animal pollination.
For more information regarding the Sustainability Strategy, please refer to: 1.4 Strategy - Company, business model and stakeholder
engagement, under ESRS 2.
2.3.3 Identified impacts, risks and opportunities
Description of processes to identify and assess material impacts, risks and opportunities [ESRS 2 IRO-1]
Eurobank identifies material impacts, risks, and opportunities related to integration of sustainability in risk management through a
comprehensive DMA. This approach integrates industry benchmarks, stakeholder insights, and financial relevance to ensure a robust
evaluation of integration of sustainability in risk management impacts.
During our Double Materiality Assessment, the following risk associated with Biodiversity and ecosystems matters has been identified:
Direct impact drivers of biodiversity loss
Impact
Negative
Potential
Eurobank’s portfolio may negatively affect biodiversity and ecosystems, including impacts
arising from climate change, pollution, and land use.
Risk
Biodiversity loss due to clients’ operations may lead to financial and reputational damage.
2.3.4 Policies, actions and performance
Policies related to biodiversity and ecosystems [MDR-P]
Eurobank has developed a set of policies to guide its actions on biodiversity, ensuring that all business activities align with the Group's
commitment to biodiversity conservation.
Eurobank is committed to engaging with stakeholders by ensuring a high level of
accountability in policy development and implementation. Policies are approved by the appropriate Governance bodies such as the
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Board of Directors or specialized committees, which ensure that there is alignment with the Group's strategic goals and stakeholder
interests. Eurobank main policies that incorporate biodiversity issues are:
●
Environmental Policy Statement: Incorporates biodiversity considerations into environmental risk assessments and
decision-making processes.
●
Sustainable Finance Framework: Guides the Group in aligning its financial activities with sustainability goals, including
biodiversity conservation by defining specific criteria for projects that support biodiversity and excluding activities that might
harm the environment.
●
Sustainable Investment Framework: Guides investment decisions to support long-term environmental and social
sustainability, including biodiversity conservation by developing criteria for investments that promote biodiversity.
For more information regarding the dedicated policies please refer to: 2.2.3 Policies & Actions - Policies related to climate change
mitigation and adaptation [E1-2]
Actions related to biodiversity and ecosystems [MDR-A]
Based on the capability of the financial sector to influence the sustainable use of nature through its business activities, Eurobank is
already taking appropriate steps to integrate biodiversity loss in its operations, by developing a corresponding response strategy and
incorporating relevant provisions in the risk management framework. These actions have been embedded into the Group’s operating
model in order to ensure that the Group has established actions on an ongoing basis:
●
According to the Group’s Exclusion List, activities prohibited by the laws of the host country or international conventions
concerning the protection of biodiversity or cultural heritage resources are excluded from financing.
●
At the same time, the ESG Questionnaire that is used by the Group in the context of the borrowers’ creditworthiness
assessment includes, inter alia, dedicated questions aiming to capture the biodiversity loss risk of the Group’s
counterparties.
●
Furthermore, a qualitative Risk Appetite Statement (RAS) has been introduced in relation to the environmental risk posed
to biodiversity. Based on its exclusion list, the Group shall refrain from financing activities prohibited by host country
legislation or international conventions relating to the protection of biodiversity resources.
●
The Group also enhanced its methodological approach towards addressing biodiversity-linked risks, as part of its Risk
Identification and Materiality Assessment (RIMA) process. Specifically, Eurobank has better articulated the sectors that are
dependent on and therefore may affect biodiversity aspects, as a means of effectively identifying and managing potential
risks.
As per the
Responsible Investment Policy
factors into the investment process. In particular, the sustainability analysis includes the assessment of environmental criteria (e.g.
emissions of greenhouse gases, exposure to fossil fuel and water emissions) at the level of the companies in which the funds and
portfolios invest. The events or conditions that may be responsible for a negative impact on the return of the fund/portfolio include
environmental aspects (e.g. carbon emissions, water pollution, loss of biodiversity or damage to ecosystem). The specific sustainability
factors considered may vary, as they depend on the specific investment strategy followed by each fund/portfolio.
Also, through the Climate -Related & Environmental Risks’ Materiality Assessment has as main objective to outline the general
methodological approach by which the Group assessed the materiality of the sustainability risks, including biodiversity loss, and to
demonstrate the exercise's results.
2.3.5 Metrics & Targets
Biodiversity metrics [MDR-M]
Eurobank is currently in the process of developing and monitoring biodiversity risk indicators through the ENCORE tool which classifies
sectors into five levels: Very Low, Low, Medium, High, and Very High. To enhance its approach, Eurobank initially created a numerical
five-level scale, where 0 represents Very Low, 1 represents Low, 2 represents Medium, 3 represents High, and 4 represents Very High.
For each subsector, the maximum score from each subcategory of ecosystem services presented by the ENCORE tool was used. The
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average of these maximum scores for each subcategory was then calculated, followed by the average per Level 1 NACE sector. The
final scores for each Level 1 NACE sector were categorized as follows:
●
0-1: Minor,
●
1-2: Low,
●
2-3: Medium,
●
3+: High.
Biodiversity targets [MDR-T]
Eurobank is currently in the process of developing specific targets related to biodiversity conservation. This initiative aims to establish
clear, measurable goals that will guide the Group's efforts in mitigating biodiversity risks and enhancing its positive impact on
ecosystems. By setting these targets, Eurobank seeks to ensure accountability and transparency in its biodiversity strategy, aligning
its operations with global sustainability standards and contributing to the preservation of natural resources for future generations.
Meanwhile, Eurobank target setting process towards biodiversity is also enhanced through its Risk Appetite Statement (RAS) to refrain
from financing activities prohibited by host country legislation or international conventions relating to the protection of biodiversity
resources. This commitment is explicitly operationalized through the Credit Policy Manual (CPM), under the “Lending Principles”
chapter, where such activities are defined as “Prohibited Lending Activities”. By embedding the RAS commitment in the CPM,
Eurobank translates a high-level risk appetite into clear, enforceable credit rules that are applied consistently across lending decisions.
This linkage supports effective implementation and oversight, provides a clear basis for controls and auditability, and enables
systematic monitoring of adherence to biodiversity related restrictions within the credit process.
2.4
Integration of sustainability in risk management [Entity-specific]
2.4.1 Governance
The role of the administrative, management and supervisory bodies [ESRS 2 GOV-1]
The Group applies a model of defined roles and responsibilities regarding the management of Sustainability risks across the Three
lines of defense, shaped by the European Central Bank’s Single Supervisory Mechanism (SSM) 13 expectations related to climate-
related and environmental risks and considering all relevant guidelines and regulatory requirements:
●
1st line
The Business Units (CIB and Retail Banking) are responsible for assessing, managing and monitoring risk levels in all risk
categories, including Sustainability risks. The CIB and Retail Banking Sustainability Centers of Excellence are responsible for
undertaking all relevant sustainability and sustainable finance activities. In addition, the role of the Group Sustainability
Unit in the 1st line includes the responsibility for managing and coordinating sustainability strategy related issues, the
development of action plans for the Group's Net Zero portfolio strategies, the facilitation of the Sustainability data
framework development, as well as Sustainability Reporting, Environmental & Energy Reporting (EMAS Report, Greenhouse
Gases Emissions Report per ISO14064) and Sustainability ratings.
●
2nd line
The Group Risk Management (GRM) is independent from the Business Units and is fully responsible for setting the risk
strategy and risk appetite framework, including sustainability risks. Within the GRM, the dedicated Group Sustainability Risk
unit has the overall responsibility for overseeing, monitoring and managing sustainability risks and sustainable financing
activities, in cooperation with the other GRM Units, as well as with Group Compliance.
●
3rd line
The Group Internal Audit (Group IA) independently reviews the adequacy and effectiveness of the internal control
framework in place regarding Sustainability risk management, following a risk-based approach.
For more information, please refer to: 1.3.1 The role of the administrative, management and supervisory bodies ESRS 2 GOV-1].
The GSR has the overall responsibility for overseeing, monitoring and managing sustainability risks. More specifically, the GSR
prepares and maintains the Group’s Sustainability risk management policies, processes and methodologies, in collaboration with the
Group Sustainability Unit and the Business and Risk Units. In addition, it leads the development and implementation of the
Sustainability risk-related framework, policies and processes, in coordination with other units, as well as acts, monitors and reports
the progress of the implementation of the developed Climate Risk action plan and reports to the Board for Sustainability risks matters.
Moreover, the GSR reviews and challenges the involved stakeholders as to setting the Financed Impact Strategy (including Net Zero
targets), as well as monitors the Financed Impact Strategy (including Net Zero) and reports financial targets and KPIs. The GSR also
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leads the 2nd line independent sustainable lending re-assessment process against the Sustainable Finance Framework criteria,
including the characterization of products of the Retail Portfolio as sustainable. Additionally, the Unit reviews and confirms the
outcomes of the ESG Risk Assessment, evaluates their consistency and completeness, and formally challenges the adequacy of the
proposed mitigating actions. Furthermore, the GSR develops and maintains the Climate Risk Stress Testing Framework, as well as the
scenario analysis and stress testing methodologies, and coordinates the performance of sustainability risk scenario analysis and
relevant stress test exercises at Group level.
As of 2024, Eurobank has enhanced its Governance Structure and Committees to support the integration of Sustainability risks:
●
Oversight of sustainability risks at management body level through allocation of responsibilities to Board and management
committees. Specifically, Chairman of the SMC is the General Manager, Group Strategy.
●
A Board Member is responsible for climate -related and environmental risks.
●
Establishment of 2 Committees that supplement the governance arrangements in sustainability risk, i.e. Sustainability
Management Committee and Climate Risk Stress Test Committee.
●
Appointment of Group Senior Sustainability Officer to lead the Group’s sustainability initiatives.
For more information, please refer to:
1.3.1 The role of the administrative, management and supervisory bodies [ESRS 2 GOV-1].
2.4.2 Strategy
Material impacts, risks and opportunities and their interaction with strategy and business model [ESRS 2 SBM-3]
Eurobank’s strategy, climate transition plan (as described in Chapter: 2.2.2) and business model are closely integrated with its
Sustainability Risk Management Framework, which includes robust risk management processes and tools. Eurobank actively evaluates
the impact of climate scenarios on its counterparties, helping to identify climate transition financing opportunities while ensuring
resilience to evolving environmental and regulatory risks. This integration of sustainability into the bank's risk management practices
strengthens its competitive position by enabling proactive engagement with clients on sustainability-related matters. It also aligns
with regulatory expectations (i.e. SSM’s 13 expectations on the management of climate-related and environmental risks) and supports
the identification and mitigation of potential financial losses linked to sustainability risks.
Eurobank’s risk management tools ensure comprehensive assessment and monitoring of sustainability risks across its portfolio. While
the integration of sustainability factors may require clients to provide additional data and meet sustainability requirements, these
measures safeguard Eurobank against potential risks that could affect its market perception and business model. By embedding
sustainability considerations into its risk management processes, Eurobank not only meets regulatory obligations but also enhances
its long-term resilience and sustainability, securing a competitive edge in the marketplace. This dual approach of addressing risks and
leveraging opportunities ensures that Eurobank’s strategy remains aligned with both its business model and its commitment to
sustainable growth.
Sustainability Risk management accounts for regulatory guidelines and expectations, such as ECB and EBA guidelines on Climate-
related environmental risks, as well as the market practices. The Group has developed an implementation roadmap in alignment with
the SSM’s 13 expectations on climate-related and environmental risks. For more information please refer to the
Consolidated Pillar 3
Report - 11.1.3 Risk Management
.
The references to Eurobank’s Sustainability Strategy in this section relate to the Strategy currently in force during the 2025 reporting
period. In parallel, the Group is progressing the update of its Group Sustainability Strategy, which will build on the existing framework
and further strengthen the integration of sustainability across its operations and activities.
2.4.3 Identified impacts, risks and opportunities
Description of processes to identify and assess material impacts, risks and opportunities [ESRS 2 IRO-1]
Eurobank identifies material impacts, risks, and opportunities related to integration of sustainability in risk management through a
comprehensive DMA. This approach integrates industry benchmarks, stakeholder insights, and financial relevance to ensure a robust
evaluation of integration of sustainability in risk management impacts.
Nevertheless, for the identification and assessment of sustainability risk management the Group has developed comprehensive
processes that include RIMA, Risk appetite framework, and ICAAP. For more information, please refer to the
Consolidated Pillar 3
Report - 11.1.3 Risk Management
.
The impacts, risks and opportunities associated with the integration of sustainability in risk management matters are shown in the
table below:
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Integration of sustainability in risk management
Impact
Positive
Actual
Eurobank evaluates the impact of climate scenarios to the resilience of its
counterparties, resulting in the timely identification of climate transition financing
opportunities for its clients.
Negative
Potential
The ESG / climate risk assessment may require additional effort by the clients in order
to provide required ESG data and may result in additional condition to comply with for
financial agreements.
Risk
Failure to adequately address sustainability requirements and/or manage respective
risks could hamper the Group’s market perception and be a driver for other risks, such
as credit risk.
Opportunity
Integrating Sustainability in risk management in response to evolving regulatory
requirements and business needs, improves the Group’s resilience to sustainability-
related risks, safeguarding the Group against potential financial losses, strengthening
its overall risk management framework.
2.4.4
Policies, actions and performance
Policies related to the integration of sustainability in risk management [MDR-P]
Eurobank has incorporated sustainability risk aspects across all pillars of its Risk Management Framework, through the establishment
of comprehensive policies and processes. It is among the Group’s priorities to identify, assess, manage and mitigate relevant risks,
with a view towards ensuring alignment with its business strategy, as well as regulatory and industry developments.
Sustainability risk management in financing activities is overseen by the Board member responsible for climate-related and
environmental risks, the Sustainability Management Committee, and the newly appointed Group Senior Sustainability Officer (GSSO).
Group Risk Management Framework (RMF) and Sustainability Risk Management Policy
The Group Risk Management Framework defines the roles and responsibilities of the Group Risk Management (GRM), which is
independent from the Business Units as a 2nd line, having full responsibility for the establishment of the Group’s Risk Strategy and
Risk Appetite Framework, as well as for monitoring all risks assessed as material through the Risk Identification and Materiality
Assessment (RIMA) process, including climate -related and environmental risks undertaken by the Group. For more information,
please refer to the: E1- Climate change Material impacts, risks and opportunities and their interaction with strategy and business
model [ESRS 2 SBM-3].
In accordance with relevant supervisory expectations and the Group’s enhanced governance operating model for the incorporatio
n
of sustainability risks across the Three lines of defense, new roles and responsibilities regarding sustainability risk management have
been embedded into the Group Risk Management Framework. In addition, Eurobank has developed its Sustainability Risk
Management Policy, which aims at fostering a holistic understanding of the effects of sustainability risks on its business model, as
well as supporting decision-making regarding these matters and providing a robust governance under its Risk Management
Framework.
Collateral Valuation Policy
The Bank acknowledges that collateral valuation should account for climate risk, as it may affect the value of collateral (e.g. increased
flood risks). Recognising the potential impact of climate risk on collateral value, the Bank has incorporated climate-related factors
into its Collateral Valuation Policy and procedures, aiming to mitigate risks associated with properties vulnerable to environmental
hazards, in alignment with the regulatory standards.
Eurobank updated its Collateral Valuation Policy (CVP) to specify accepted collateral types and valuation procedures, while integrating
assessments of climate-related and environmental risks. This involves collecting pertinent information such as Energy Performance
Certificates (EPCs) and incorporating forward-looking estimates of natural hazards. The updated Policy will also consider broader
climate-related and environmental factors, such as waste management and accessibility, to enhance valuation accuracy and risk
management.
Where Energy Performance Certificates (EPCs) or actual energy consumption data are not available for a specific collateral, Eurobank
applies a structured fallback mechanism to ensure valuation records remain complete and usable for risk monitoring. In such cases,
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the Bank estimates energy consumption (kWh/m²) in collaboration with a specialized external provider, using property specific
characteristics (e.g., building type, year of construction, location) rather than generic averages. This model-based estimation primarily
supports coverage of legacy collateral and portfolio level reporting where data gaps may persist.
Credit Policy Manual
Eurobank has established formal credit and loan standards that require the systematic integration of environmental, social and
governance (ESG) risks into all financing decisions. The Group’s Credit Policy Manual (CPM) has been updated to integrate
sustainability-related risks by incorporating climate and environmental factors into credit risk management practices, aligning with
the SSM's expectations. Specifically, the CPM integrates sustainability-related factors into sector-specific credit risk assessment tools
(e.g. Climate Risk Scorecard and ESG questionnaires), which inform credit approval, pricing and client engagement.
Group Exclusion List
Eurobank maintains a list of activities that are excluded from financing, in line with the exclusion lists of the EBRD. For all financing
transactions, the Group ensures that its clients demonstrate an organised and systematic approach to E&S risk management that
complies with applicable local, national and international environmental, health and safety, and labour legislation and standards,
relevant permits, as well as public disclosure requirements.
Know-Your-Customer (KYC) and Anti-Money Laundering/Terrorist Financing (AML/TF) policies and processes
Eurobank has established Know-Your-Customer (KYC) and Anti-Money Laundering/Terrorist Financing (AML/TF) policies and
standards, which are designed to provide safeguards against, inter alia, fraud and cooperation with clients with increased financial
crime risk (i.e. risk of involvement in money laundering and terrorist financing).
Within the scope of customer KYC profiling, Eurobank applies enhanced due diligence measures upon establishing a business
relationship and when carrying out transactions with natural or legal persons/entities who are classified as high-risk as per Eurobank’s
relevant internal processes.
Climate Risk Stress Test Framework
The Framework provides a transparent and repeatable process for designing and executing the climate risk stress test, as well as for
reporting and evaluating stress test outcomes and determining management actions.
For more information, please refer to
Consolidated Pillar 3 Report - 11.1.3 Risk Management
impacts, risks and opportunities and their interaction with strategy and business model [ESRS 2 SBM-3].
Actions related to the integration of sustainability in risk management [MDR-A]
The Group has developed the following processes and tools for the monitoring and management of sustainability risks. These
processes have been embedded into the Group’s operating model and are performed on an ongoing basis in the context of continuous
sustainability risk management.
Risk Identification and Materiality Assessment (RIMA) process
The Risk Identification and Materiality Assessment (RIMA) process sets the appropriate mechanisms to identify, measure and monitor
risks at an early stage, as well as to manage their potential impact on the achievement of the Group’s objectives. Through the RIMA
process, the Group identifies material risks that could potentially have a significant adverse impact on its financials, capital base,
liquidity position or business model, as well as any exposure to possible emerging risks.
As sustainability risks interact with other risks and result in direct distributional impacts and indirect macroeconomic impacts, the
Group understands that careful consideration of the cross-cutting nature thereof is necessary to ensure the optimal implementation
of adaptation activities. As such, the Group considers sustainability risks as drivers of existing risk types, undertaking a holistic and
systemic approach when examining the complex links between sustainability risks and both financial and non-financial risks. Eurobank
has integrated sustainability risk elements into its existing risk management processes, creating additional procedures, policies and
tools so that these risks can be properly identified and measured.
Sustainability
Risk
Data
The Group manages sustainability risk data through dedicated infrastructure operating within the Group’s overarching data
governance framework. Sustainability risk data management is embedded in the Bank’s established data control environment
(including ownership, quality controls and monitoring), ensuring consistency with broader governance standards. In parallel, the Bank
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is developing sustainability specific capabilities to address the distinct characteristics of sustainability data, such as diverse external
sources, evolving methodologies, and increased granularity required for risk measurement and reporting.
Having already performed an assessment of sustainability data availability in its internal systems against regulatory
requirements/expectations, the Group continues to enhance its sustainability risk data aggregation capabilities and IT infrastructure
accordingly, while also using appropriate controls and safeguards to ensure the accuracy and completeness of the compiled
information. The Group seeks to further improve sustainability risk data granularity through allocating detailed roles and
responsibilities as part of the bank-wide data governance framework, for the purposes of sustainability data management and
implementing approaches for addressing data needs (i.e. engaging with external data providers, developing methodological
approaches for estimating required information).
Risk appetite
The Group articulates its risk appetite through a set of qualitative and quantitative statements with respect to, inter alia, solvency,
liquidity, profitability, asset quality and other areas related to material risks. The purpose of these indicators and thresholds is to
facilitate the assessment of whether the Group is operating within its defined risk appetite levels. The outcome of this process is the
Risk Appetite Statements (RAS) document, whereas the principles, process and governance aspects related to the RAS are outlined
in the Risk Appetite Framework (RAF). The RAS are complemented by a set of Business Line Statements (BLS), which constitute
operational metrics (and limits) at the business level where the risks are undertaken [MDR-T 2.5].
Moody’s Risk Analyst (MRA) model
The Group’s MRA Model assesses the CIB borrowers’ credit profile based on qualitative and quantitative criteria. Specifically, the
“Risk of Adverse Events” criterion assesses a client’s vulnerability to adverse developments or business interruptions, fines, litigation
and negative publicity, stemming, among others, from environmental parameters and social issues (e.g. health and safety of
customers).
Climate Risk Scorecard
In line with leading market practices, as well as taking into account supervisory requirements/expectations with regard to establishing
an approach for further assessing clients with higher climate risk exposure, the Group has developed the Climate Risk Scorecard for
considering climate-related and environmental risks.
In this context, an assessment process based on the Climate Risk Scorecard is performed for all new financing transactions, limit
increases and limit renewals (existing and new clients), initially applied to the Group’s Corporate & Investment Banking (CIB) portfolio.
The Climate Risk Scorecard comprises a modular questionnaire which includes targeted climate risk and sustainable financing related
questions, both qualitative and quantitative, capturing the following key dimensions: transition risk, taxonomy aligned activities,
physical risk, sustainable financing, emissions, strategy, climate & environmental incidents, transition -green technology.
In recent years, the banking sector has faced increased regulatory focus on ESG matters. Banks are now required to improve their
credit risk assessment processes to better identify and evaluate climate -related and environmental risks. In response, the Hellenic
Bank Association (HBA) and major Greek banks have launched an initiative to create a unified Interbank ESG Questionnaire for their
clients. This questionnaire aims to standardize the assessment of ESG factors across Greek banks, ensuring compliance with regulatory
expectations and international guidelines (e.g., EBA Guidelines, ECB's climate risk guide, and TCFD recommendations). In Cyprus the
banks have also developed the Interbank ESG Questionnaire, in collaboration with the Association of Cyprus Banks, to standardize
ESG assessments across Cyprus and help customers improve ESG performance through scores, certifications, and personalized action
plans. This process has been adopted by the Group’s entities in Greece and Cyprus as of 2025.
ESG Risk Assessment
Eurobank has developed an ESG Risk Assessment by combining its Climate Risk Scorecard with the Interbank ESG Questionnaire. This
comprehensive approach helps assess and classify the Group's clients based on ESG criteria, in line with regulatory requirements.
Eurobank uses an internal ESG Risk Scoring method, resulting in one of three ESG risk categories: High, Medium, or Low. This
assessment informs credit decisions, by incorporating ESG risks, potential mitigation actions and due diligence considerations. The
framework includes ESG due diligence triggers and escalation mechanisms, with the Bank providing recommendations for appropriate
mitigating actions. Obligors are expected to submit an ESG action plan within 12 months to address identified risks and opportunities.
Eurobank’s ESG Risk Assessment framework determines whether mitigation actions are required based on the borrowers’ overall ESG
score and transaction characteristics such as tenor and exposure. Based on these factors, ESG mitigation actions are mandatory for
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high-risk borrowers, while medium-risk borrowers may also undergo this process. The ESG action plan is based primarily on the
review of the borrower’s responses to the ESG Questionnaire and comprising, where applicable, proposed mitigation actions
identified by the RM with the support of the CIB Sustainability Center of Excellence Unit and the Group Sustainability Risk Unit. The
results of the ESG action plan must be submitted to the relevant approval authorities for their consideration in the decision-making
process.
The overall approach aligns with Eurobank's business strategy, enhances ESG risk awareness, supports sustainable financing, and
ensures compliance with the Group's risk appetite and credit policies. This process has been fully adopted by the Group’s relevant
entities in Greece and Cyprus and is gradually being introduced into other countries. In 2025, the similar processes and tools for the
monitoring and management of sustainability risks incorporated in Bulgaria.
Collateral Insurance Requirements
At loan origination, the Bank requires borrowers to maintain valid insurance coverage for real estate assets pledged as collateral, with
the exception of land plots. Mandatory coverage includes protection against key physical risks, such as fire, flood and earthquake,
applicable to all borrowers. Additional insurance requirements may apply depending on the characteristics and specific circumstances
of the property, including, for example, assets under construction or properties located in environmentally sensitive or protected
areas.
Subsidiaries’ Sustainable Finance Actions
Eurobank’s subsidiaries actively support the Group’s sustainable finance strategy by implementing dedicated frameworks, expanding
green lending, and tracking taxonomy-aligned assets. Their efforts contribute to the Group’s consolidated sustainable finance KPIs
and help accelerate the transition to a sustainable economy.
Bulgaria (Postbank)
Postbank has adopted the Group’s Sustainable Finance Framework and developed a Climate Risk Roadmap to guide its sustainable
finance activities. The bank monitors its Green Asset Ratio and taxonomy-aligned assets, which are included in the Group’s
consolidated KPIs. In 2025, Postbank continued to expand green lending products, such as green mortgages and eco-auto loans, and
integrated climate risk assessment into its credit processes for sectors with high transition risk. Through these efforts, Postbank
strengthens its commitment to responsible banking and the systematic integration of sustainability considerations into its business
model. By aligning its sustainable finance initiatives with the Group’s strategic direction, Postbank supports increased climate risk
awareness, facilitates clients’ transition journeys and ensures consistency with evolving regulatory and market expectations.
Cyprus (Eurobank Limited and insurance subsidiaries)
Following the legal merger, Eurobank Limited is in the process of developing its local Sustainable Finance Framework (SFF) and
Sustainable Investment Framework (SIF). The SFF builds on the Group’s existing framework and incorporates previous initiatives from
both banks, consolidating approaches to ensure consistent identification, classification, and governance of sustainable financing
portfolios—covering wholesale and retail—across Eurobank Limited. Its purpose is to establish a clear and comprehensive
methodology for classifying, monitoring, and reporting sustainable financing activities in alignment with the Group Sustainability
Strategy. The Bank also monitors taxonomy-aligned assets and sustainable finance KPIs, which are consolidated at Group level. In
parallel, the SIFs in alignment with the Group’s Sustainable Investment Framework, will ensure consistent identification, classification,
and governance of Sustainable Bonds portfolio of Eurobank Limited. The Sustainable Investment Framework outlines Eurobank’s
available sustainable investment approaches and strategies, the selection of eligible investments and the monitoring frequency of
the Sustainable Bond portfolio as part of the Bank’s investment portfolio. The Framework specifies the respective criteria that are
utilized in the Bank’s banking book’s investment strategy, along with the selection process of eligible sustainable investments.
The acquired insurance companies (ex-CNP Group) applied specific ESG-related exclusion policies throughout 2025, excluding certain
countries and companies based on an ESG-rating-based prohibited list provided by the previous shareholder. They also avoided
investments in businesses deriving ≥20% of revenue from thermal coal, those deriving >10% from thermal coal, or those involved in
new coal mines or coal-fired power plants. The ex-CNP Group monitored its sustainable investment exposure with the aim of
increasing it in line with Eurobank Limited’s policies. In line with Solvency II requirements, climate risk is included in the ORSA process,
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and ERB CIH companies currently perform a qualitative Climate Risk Assessment, with plans to develop a quantitative assessment
with Eurobank Limited’s support.
Luxembourg (Eurobank Private Bank Luxembourg)
Eurobank Private Bank Luxembourg has in place a Sustainable Finance Framework which is tailored to private banking operations,
integrating Sustainability criteria into lending decisions whenever applicable. In 2025, the subsidiary is able to offer green and
sustainable investment products for private banking clients, further supporting the Group’s sustainable finance objectives.
2.4.5
Metrics & Targets
Sustainability risk management metrics [MDR-M]
Through the processes described above, the Group monitors its performance on sustainability through the metrics and indicators
demonstrating the sustainability risk level of its counterparties.
In addition, key indicator for the Group is the allocation of its portfolio to high climate impact sectors and clients. The respective
distributions for 2025 and 2024 are presented in the table below, based on the definitions of Pillar 3 ESG risks disclosures. No external
body other than internal assurance is provided for the below information.
2025 exposure
2024 exposure
Loan exposures to sectors that highly contribute to climate change
bn €
27.4
24.9
Bond and share exposures to sectors that highly contribute to climate change
bn €
1.6
1.4
Exposures towards the top 20 most carbon intensive counterparties globally in
Group’s trading and banking portfolios
mn €
25
31
The increase in the exposures to sectors that highly contribute to climate change, c. €2.5 bn in 2025, is commensurate with the overall
growth in the outstanding balance of both lending and investment portfolio, c. €5.4 bn in 2025, while their percentage contribution
on the overall Non-Financial Corporations portfolio remained practically stable.
Sustainability risk management targets [MDR -T]
The Group has achieved its key Risk Appetite Statement (RAS) for at least 20% of the annual new CIB disbursements to be classified
as green / environmentally sustainable loans, by applying the methodology and criteria set in the Group’s Sustainable Finance
Framework, which outlines the eligible approaches and activities that can be classified as sustainable, demonstrating the Group’s
commitment towards green transition.
In addition, the Group has demonstrated progress against the following areas which have been set as qualitative targets:
●
Significant progress in the integration of sustainability risks in its Three lines of defense Model
●
Incorporation of climate risk elements in the Remuneration Policy (Please refer to “Integration of sustainability -related
performance in incentive schemes [ESRS 2 GOV-3]” for more information)
●
Deployment of the ESG Questionnaire, which has been developed at interbank level with the coordination of the Hellenic
Bank Association
●
Integration of the ESG Risk Assessment process, a combination of the internal Climate Risk Scorecard and the Interbank ESG
Questionnaire
●
Integration of the SFF Assessment Tool. The Bank has successfully operationalized the Sustainable Finance Framework
Assessment Tool within its systems (Drive+). This tool automates the classification of financing solutions (e.g., Green/Social
Loans) against SFF criteria during loan origination, ensuring structural alignment with sustainability goals
●
Assessment of sustainability risks through Sectoral Analysis and forward-looking Scenario Analysis, as part of the TCFD report
(For more information please refer to: E1 – Climate change: Material impacts, risks and opportunities and their interaction
with strategy and business model [ESRS 2 SBM-3])
●
Alignment of its Risk Appetite with the articulated Sustainability Strategy
●
Incorporation of climate risk aspects in collateral valuation
●
Performance of training sessions for its employees in relation to Climate Risk, ESG Risk Disclosures and ESG Risk Assessment
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●
Further integrate climate risk regulatory requirements into its business strategy and risk management framework, leveraging
on key initiatives:
o
Governance, policies and control framework.
o
Climate risk modelling and data management.
o
Commercial strategies/sector policies.
o
Eurobank S.A. and its subsidiaries aim to implement climate risk and environmental action plans by 2025. These
initiatives are designed to ensure full alignment of policies, actions, and strategies across Eurobank Greece and its
subsidiaries, fostering a cohesive and unified approach to achieving organizational objectives.
2.5
Sustainable financing and investment offerings [Entity-specific]
2.5.1 Governance
The role of the administrative, management and supervisory bodies [ESRS 2 GOV-1]
Aiming to implement the Sustainability Strategy, the Group has appointed a Group Senior Sustainability Officer responsible for the
implementation of the Group’s Sustainability Strategy and engaging the following committees that actively contribute to the
promotion of sustainable financing and investment offerings and their integration into the day-to-day operations of the Group:
●
Sustainability Management Committee (Sustainability ManCo): Acts as the final approval body, inter alia with regards to the
inclusion or substitution of Eligible assets of the Green Bond Portfolio, and to the update of the annual Green Bond Report.
The Committee approves the Sustainability Frameworks (e.g. Sustainable Finance Framework, Green Bond Framework,
Sustainability Policy Framework and Sustainability Investment Framework).
●
Group Asset and Liability Committee (G-ALCO): Within the context of the approved investment framework for corporate/FI
bond portfolio, reviews the relevant portfolio limits annually.
As far as the Group Sustainability Risk (GSR) Unit is concerned, it has the overall responsibility for overseeing, monitoring, and
managing sustainability risks. More specifically, the GSR leads the 2nd line independent sustainable lending re-assessment process
against SFF criteria, including the classification of retail portfolio products as sustainable. Also, GSR is responsible for assessing the
sustainability features of new loans/products according to the SFF criteria.
Regarding the Business Units CIB and Retail Banking, they are primarily involved in executing all sustainable financing activities,
including the implementation of the Financed Impact Strategy. Key responsibilities are classified, inter alia, under the following 3 main
categories:
1.
Sustainability Strategy: Executing and monitoring financed and specific operational sustainable goals and performance
targets in line with the Net Zero Strategy.
2.
Sustainable Financing/Funding and Investments: Identifying sustainable financing opportunities and designing relevant
solutions and sustainable products. Performing the sustainable financing assessment, in line with the Sustainable Finance
Framework. Implementing and monitoring the Sustainable Investment and Green Bond Frameworks.
3.
Sustainability Risk Management: Performing the ESG Risk Assessment and formulating mitigation action plans, where
required.
Dedicated functions, namely the Sustainability Centers of Excellence (CoE), within the Business Units (Corporate & Investment
Banking and Retail Banking) are responsible for assessing, managing and monitoring risk levels in all risk categories, including
Sustainability risks. The Head of CIB Sustainability CoE is responsible for overseeing sustainable financing activities, while two Retail
Banking Sustainability Coordinators (Business and Individual clients respectively) are responsible for organising and supporting
sustainable-related activities.
Also, Group Compliance’s key roles and responsibilities regarding sustainable financing and investment offerings include:
o
Monitoring the regulatory environment and emerging trends around sustainable financing.
o
Monitoring the alignment of the Group’s activities with applicable laws, rules, regulations and standards, including
sustainability-related regulatory aspects.
For more information regarding the Sustainability Governance may refer to: 1.3 Governance, under ESRS 2.
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2.5.2 Strategy
Material impacts, risks and opportunities and their interaction with strategy and business model [SBM-3]
The Group acknowledges that sustainable development is a key driver of long-term prosperity and resilience. Supporting the
transition to a low carbon and inclusive economy through financing advisory and capital-raising solutions is central to the Group’s
business model and is embedded in its Financed Impact Strategy.
Through this strategy, the Group aims to generate measurable
positive environmental and social outcomes by directing capital towards activities that support the green transition and social
investments, while also incentivising clients to improve their sustainability performance. The Group’s sustainable finance approach is
underpinned by dedicated frameworks and tools, including the Sustainable Finance Framework. In parallel, the Group is in the process
of finalising its holistic Transition Plan, aligned with regulatory requirements and international best practices. The Transition Plan sets
out the Group’s strategic objectives, governance arrangements, targets, metrics and implementation actions to manage climate-
related and environmental risks and to support the transition of its lending and investment portfolios a climate and environmentally
resilient and more sustainable economy. It adopts a sector-specific approach, focusing on the most carbon-intensive and climate-
sensitive sectors, and is informed by materiality assessments and climate scenario analysis across short-, medium- and long-term
horizons.
The Group acknowledges that sustainable finance is subject to challenges, including evolving regulatory requirements, data and
methodological limitations, and the risk of perceived greenwashing if products do not fully meet recognised criteria. At the same
time, the transition to a sustainable economy presents significant opportunities to support clients, respond to changing market and
investor expectations, strengthen the Group’s reputation and ensure the long-term resilience of its business model.
Through the combined implementation of its Sustainability Strategy and Transition Plan, the Group seeks to integrate sustainability
into decision-making, actively support the real-economy transition, and create long-term value for stakeholders and society.
The Group is currently advancing the development of its Transition Finance Framework, which will serve as a core tool for facilitating
both client-level and portfolio-level transitions. By providing clear eligibility criteria and guidance for financing transitional activities,
the Framework will strengthen the Group’s ability to support counterparties in decarbonising their operations and align the overall
portfolio with credible transition pathways.
The references to Eurobank’s Sustainability Strategy in this section relate to the Strategy currently in force during the 2025 reporting
period. In parallel, the Group is progressing the update of its Group Sustainability Strategy, which will build on the existing framework
and further strengthen the integration of sustainability across its operations and activities.
2.5.3 Identified impacts, risks and opportunities
Description of processes to identify and assess material impacts, risks and opportunities [ESRS 2 IRO-1]
Eurobank identifies material impacts, risks, and opportunities related to sustainable financing and investment offerings through a
comprehensive DMA. This approach integrates industry benchmarks, stakeholder insights, and financial relevance to ensure a robust
evaluation of sustainable financing and investment offerings impacts.
The impacts, risks and opportunities associated with sustainable financing and investment offerings matters are shown in the table
below:
Sustainable financing and investment offerings
Impact
Positive
Actual
Group provides sustainable finance products and services that promote green and social
investments and incentivize improvement of its clients’ sustainability performance.
Positive
Actual
Increase market awareness and provide services that enable customers to make better
informed decisions on sustainable financing solutions.
Negative
Potential
Engagement with clients on sustainability issues is limited to legal entities.
Risk
Evolving market preferences and regulatory shifts may impact the demand for sustainable
finance, posing risks to Eurobank’s existing product offerings.
Opportunity
Promoting green and social investments in line with requirements to support climate
transition and in response to changing consumer preferences enhances the Group’s brand
reputation, attracting sustainability -conscious investors.
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2.5.4 Policies, actions and performance
Policies on sustainable financing and investment offerings [MDR-P]
The Group has approved and implements as part of the operationalization its Sustainable Finance Framework (SFF), which
encompasses a wide range of sustainable-green lending activities and supports the identification and classification of sustainable-
green financings, covering both Corporate and Retail banking portfolios. Eurobank developed its SFF in accordance with
internationally recognised industry guidelines and principles. In addition, Eurobank also maintains a Green Bond Framework, which
enables the Group to meet its environmental/sustainability commitments and finance projects that will deliver environmental
benefits to the economy and support Eurobank’s business strategy and vision. Furthermore, Eurobank has also developed a
Sustainable Investment Framework, which outlines the available sustainable investment approaches/strategies, the selection of
eligible investments and the monitoring frequency of the sustainable portfolio (the sustainable portfolio is part of Eurobank
’s
investment portfolio). Eurobank is committed to engaging with stakeholders by ensuring a high level of accountability in policy
development and implementation. Policies are approved by the appropriate Governance bodies such as the Board of Directors or
specialized committees, which ensure that there is alignment with the Group's strategic goals and stakeholder interests.
More specifically:
●
Through the SFF Eurobank is able to classify sustainable lending solutions offered to its customers, specifying the applied
classification approach and the activities defined as eligible to access sustainable financing (eligible green and social assets).
The SFF scope encompasses a wide range of sustainable lending products, covering both wholesale and retail banking
portfolios. The SFF also incorporates the assessment process of the EU Taxonomy for which the Group pursues Taxonomy-
alignment of financings on a best effort basis. The purpose of establishing the SFF is to provide a clear and comprehensive
methodology for classifying, monitoring and reporting sustainable financing. The policy applies to all financial transactions,
excluding certain activities deemed incompatible with sustainability goals, such as fossil fuel extraction or high carbon-
intensive projects. It covers the entire value chain, both upstream and downstream. Key stakeholder groups affected include
investors, customers, and communities within operational regions. The Group Senior Sustainability Officer (GSSO) holds the
highest level of accountability for the implementation and oversight of the policy within the organisation. The SFF draws
from guiding frameworks such as the Loan Market Association (LMA) principles for loans – Green Loan Principles,
Sustainability-Linked Loan Principles as well as the EU Taxonomy Climate Delegated Act. For more information please refer
to:
Sustainable Finance Framework
.
●
The Sustainable Investment Framework (SIF) aims to classify investments as sustainable based on criteria observed in
international market practices. Eurobank’s SIF outlines Eurobank’s potential sustainable investment approaches/strategies,
the process for selecting eligible investments, as well as the monitoring frequency regarding the sustainable portfolio. Its
scope includes the own bond investment portfolio, for both direct and indirect investments across all sectors, regions, and
value chains, with exclusions in areas such as high-risk fossil fuels and activities detrimental to biodiversity or human rights.
The policy applies to all stakeholders involved in the investment process. Accountability for its implementation lies with the
organisation's Group Senior Sustainability Officer (GSSO).
●
The Green Bond Framework (GBF) assists Eurobank in meeting its environmental/ sustainability commitments and finance
projects that will deliver environmental benefits to the economy and support its business strategy and vision. The Green
Bond Framework is developed in accordance with global best practices and standards and considers EU Taxonomy eligibility
criteria to classify potential investments as green. The Framework defines the eligible assets and associated criteria, the use
of proceeds, the process for project evaluation and selection, the management of proceeds, as well as the relevant reporting
obligations. Its general objectives include promoting green investments, while ensuring transparency and accountability in
the use of proceeds. The scope of the framework covers both upstream and downstream activities related to eligible
projects, across global geographies, with exclusions for projects involving fossil fuels, or other environmentally harmful
practices. The Sustainability ManCo approves the GBF. Accountability for its implementation lies with the organisation's
GSSO. The Green Bond Framework has obtained a Second Party Opinion (
Green Bond Framework- Second Party Opinion
)
for its alignment with the ICMA Green Bond Principles (GBP) and the EU Green Bond Standard (GBS). )
For more information regarding Policies related to Financial Inclusion please refer to: “3.2.2: Policies related to consumers and end-
users [S4-1]”.
Actions on sustainable financing and investment offerings [MDR-A]
The Group takes key actions to promote sustainable financing:
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Net-Zero Banking Alliance (NZBA)
Key element of the Group’s NZBA participation is the use of sectoral decarbonisation pathways as a reference for setting targets
across selected lending portfolios, with a phased target-setting up to 2050. The promotion of sustainable financing that will enable
client transition is the key enabler towards achieving those targets.
Sustainable Finance Framework
Eurobank’s SFF defines four classification approaches for classifying its financing and investing activities as sustainable:
●
Dedicated-purpose – Green/Social loans:
Project-specific loans or financing instruments whose use of proceeds is 100%
directed towards eligible green / social activities. The SFF defines the eligible activities (for the wholesale and retail
portfolios) along with the applicable eligibility and exclusionary criteria that need to be fulfilled. The eligible areas and
activities include energy efficiency, renewable energy, clean transportation, green buildings, pollution prevention and
control, and circular economy regarding the green activities, and economic inclusion, affordable basic infrastructure, access
to essential services, affordable housing, food security and sustainability regarding the social activities.
●
General-purpose – Company business mix:
Financing to companies that fulfil the eligibility green/social criteria and derive
their revenue from eligible activities. Specifically, companies are eligible under the business mix category when they derive
a minimum predefined percentage of their total revenue from eligible activities.
●
General-purpose – Sustainability-linked loans/facilities:
The second type of general-purpose lending adopted relates to
Sustainability Linked Loans (SLL). The purpose of SLLs is to enable and accelerate the ESG transition of clients. Through SLLs,
Eurobank provides ESG-related incentives to its clients, by offering products (loans, bond loans, etc.) with terms linked to
ambitious and predefined Sustainability Performance Targets (SPTs). The SPTs are specific targets that aim to improve the
ESG performance of the client.
●
Recovery and Resilience Facility-based approach:
Activities approved through the Greek Recovery and Resilience Facility,
contributing to the green pillar.
Sustainable Finance Framework Assessment Tool
Eurobank utilises a web-based SFF Assessment Tool for its CIB portfolio. The tool is integrated within the Group loan origination
system, to underpin the classification and evaluation of sustainable/green financing opportunities in a structured manner, as part of
the loan origination process. The SFF Assessment Tool is delivered through an online platform, a workflow-based application, which
assists the process of assessing the Group’s financing solutions against the criteria defined in the SFF.
Sustainable financing products
●
ESG Deposits
Eurobank was the first Greek bank to offer ESG Deposits to its corporate clientele, and continues to offer this product,
allowing its clients to contribute to sustainable development projects. The amount raised from ESG Deposits is allocated to
financing green and sustainability linked loans, in agreement with Eurobank’s SFF.
●
Residential Energy Upgrade Loans
Eurobank has played a key role in energy-saving initiatives in Greece, particularly through its participation in the Exoikonomo
Programmes since 2011, which support the energy upgrade of private residences. In 2025, the Group continued to solidify
its presence in green energy upgrade loans by participating in “Exoikonomo 2021”, “Exoikonomo 2023”, “Exoikonomo 2025”,
“Exoikonomo Anakainizo gia Neous” & the new “Upgrade Spiti mou development Programme funded by the EU's Recovery
and Resilience Facility and managed by the Hellenic Development Bank. These Programmes offer interest rate subsidies,
state loan guarantees, grants, and other benefits for households in order to make green improvements like energy efficiency
upgrades and smart home automation. For those not eligible for Exoikonomo, Eurobank offers a Green Home Loan – Energy
Efficiency Upgrade (with or without collateral) to finance energy-efficient home improvements, such as installing solar
panels, the replacement of heating and cooling systems, the installation of a solar water heater, the upgrading of insulation,
and, more broadly, the full range of ‘green’ residential needs of individual customers. Through these efforts, Eurobank aims
to help Greece meet its environmental goals by offering accessible green financing solutions for homeowners.
●
Green Mortgage Loans
In 2025, Eurobank introduced a discount incentive to encourage the purchase of properties belonging to higher energy-
efficiency classes, as verified by the Energy Performance Certificate (EPC). This initiative aims to promote more sustainable
choices in the real estate market by rewarding customers who invest in buildings with reduced environmental impact and
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improved energy performance. By linking financial incentives to the EPC rating, Eurobank supports national and European
climate goals, while improving the quality of its collateral stock with more energy efficient properties.
●
Photovoltaic SB Loans
Eurobank offers Photovoltaic SB Loans to small businesses for investing in renewable energy, specifically through the
production and sale of energy from photovoltaic systems. Businesses can choose between a loan or leasing option, with the
loan covering up to 80% of the total investment costs, including infrastructure, equipment purchase and installation, site
setup, and connection expenses.
●
Bridge Financing – Exoikonomo
Eurobank’s Bridge Financing - Exoikonomo programme provides a credit line to suppliers and contractors working on
properties under the Exoikonomo – Aftonomo and Exoikonomo 2021 programmes. This financing helps them pre-finance
their work until they are paid through the government subsidies. Suppliers can receive up to 80% or 100% of the subsidy
amount their customers are eligible for, regardless of whether the customers use Eurobank loans. Our actions to promote
sustainable financing, originally developed for our core operations, are strategically and proportionally adapted and
deployed across subsidiaries in Bulgaria, Cyprus, and Luxembourg. An indicative example is the offering of green lending
such as Green home programmes, Green Car programmes for the purchase of new electric or hybrid cars, eco-auto loans,
etc. While these programs are tailored to address the specific local contexts and regulatory environments, we are working
towards achieving a Group alignment. In addition, the Group is currently advancing the development of its Transition Finance
Framework, which will serve as a core tool for facilitating both client-level and portfolio-level transitions. By providing clear
eligibility criteria and guidance for financing transitional activities, the Framework will strengthen the Group’s ability to
support counterparties in decarbonising their operations and align the overall portfolio with credible transition pathways.
ESG-focused mutual funds criteria
Eurobank Asset Management MFMC, a wholly owned subsidiary of Eurobank, with total AUM as of 31.12.2025: €10.25bn, manages
three UCITS funds and one Discretionary Portfolio Management Strategy which are classified under Article 8 of the SFDR with total
AUM of €241,52mn. The three UCITS funds are: GF Greek Equities Domestic Equity Fund, (LF) Fund of Funds Global Megatrends and
(LF) Fund of Funds Next Gen Focus, while the Discretionary Portfolio Management Strategy is Responsible Investment Themes.
Eurobank Asset Management integrates environmental, social and governance factors into its investment decision-making process,
in line with its
Responsible Investment Policy
integrate ESG considerations into investment strategies. ESG considerations are incorporated in the assessment of investment risks
and opportunities prior to investment decisions and are monitored throughout the investment lifecycle as part of the Eurobank Asset
Management’s investment and risk management processes.
ESG awareness and capacity building
Eurobank is prioritising the development of its employees' capabilities to ensure they can effectively assist clients in their
sustainability efforts and facilitate their transition to green transition. For more information, please refer to section 1.3.1. The role of
the administrative, management and supervisory bodies [ESRS 2 GOV-1].
Dedicated training sessions to Business Units
Apart from the general upskilling programmes, during the past years the Group has conducted dedicated training sessions tailored to
the requirements of specific business units and functions, crucial for delivering the Group’s strategy. These sessions focused on
engaging with clients to enable their green transition efforts and identifying sustainable financing opportunities through publicly
available sources, such as company sustainability disclosures.
The Board of Directors is provided with semi-annual sustainability update sessions to support effective oversight of evolving
regulatory requirements, the Group’s mitigation strategy through key initiatives and actions, and emerging sustainability megatrends.
These sessions also incorporate sectoral benchmarking to evaluate the Group’s positioning and performance relative to peers and
market best practices.
Subsidiaries Sustainability Awareness and Engagement Actions
Eurobank’s subsidiaries actively promote sustainability awareness and engagement by delivering targeted training, fostering internal
communication, and integrating Sustainability topics into daily operations. These efforts help embed a sustainability culture across
the Group and support the achievement of Group-wide ESG objectives.
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Bulgaria (Postbank)
In 2025, Postbank continued to expand staff’s ESG awareness. 3,316 bank employees completed the online course “ESG and the
World” developed by Eurobank Group and more than 500 employees from business lending, Risk, Compliance, and Internal Audit
took an internally developed training course on the management of climate and environmental risks in the banking sector. The Bank
also offered specialized sustainability courses, including those developed in partnership with international organizations such as
EBRD’s Green Gateway and IFC’s STEP training. A sustainability awareness training session on topics including CSRD, DMA, and EU
Taxonomy, among others, developed by Eurobank Group was delivered to Postbank’s Management Board and Supervisory Board.
The bank regularly communicates ESG topics through internal bulletins and staff surveys, ensuring that sustainability remains a key
focus for all employees.
Cyprus (Eurobank Limited and insurance subsidiaries)
Eurobank Limited has implemented comprehensive ESG training programs for staff and management, organizing relevant training
sessions in 2025, to enhance awareness on ESG-related matters. In this respect, the Bank implemented a series of workshops and
trainings to support the integration of ESG considerations into business processes and also to promote ESG awareness and culture.
In addition the Bank, launched a dedicated ESG e-Learning course internally while also a number of staff participated in ESG programs
organised by external associates.
ERB CIH Risk & Sustainability team has received training on various ESG topics and received relevant certification. They also
participated in various seminars, workshops and networking events related to this matter to remain informed and engaged with the
local community’s needs. ExCo has participated in training related to CSRD delivered by the ex-shareholders.
Luxembourg (Eurobank Private Bank Luxembourg)
Eurobank Private Bank continued to align its Sustainability Strategy with the Group. The bank is committed to ongoing staff
engagement on ESG topics and is aligning its communication efforts with Group standards to ensure a consistent approach to
sustainability awareness and engagement across all operations.
2.5.5
Metrics & Targets
Metrics on sustainable financing and investment offerings [MDR-M]
The corporate portfolio of Eurobank in Greece, which represents the Group’s core sustainable financing activity, recorded a strong
performance in 2025. Total sustainable outstanding balances reached €4.11 bn, reflecting a c.37.9% year-on-year increase, in line
with the Bank’s green financing targets, while annual disbursements remained broadly stable at €1.3 bn. The tables below present
the allocation of sustainable exposures and the corresponding disbursed amounts for 2025, alongside comparative data for 2024
where available:
Greece
Corporate Banking
Outstanding
balance as of
31.12.2025
(mn €)
Disbursed amounts
within 2025 (mn €)
Outstanding
balance as of
31.12.2024
(mn €)
Disbursed
amounts
within 2024
(mn €)
Dedicated purpose financings
2,656
807
1,898
537
Renewable energy
1,806
424
1,429
419
Green buildings
305
69
230
75
Energy efficiency
207
29
192
-
Clean transportation
67
30
40
36
Pollution Prevention & Control & Circular Economy
7
-
8
7
Other
265
255
-
-
General purpose financings
1,452
496
1,088
736
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Greece
Corporate Banking
Outstanding
balance as of
31.12.2025
(mn €)
Disbursed amounts
within 2025 (mn €)
Outstanding
balance as of
31.12.2024
(mn €)
Disbursed
amounts
within 2024
(mn €)
Business mix
86
48
80
29
Sustainability-Linked Loans (SLL)
1,366
449
1,008
707
Total sustainable financing
4,108
1,304
2,986
1,273
Total outstanding balances increased by more than €1.1 bn, driven primarily by dedicated purpose financings, which rose from
€1.9 bn to €2.66 bn, supported by higher deployment into renewable energy, green buildings and energy efficiency. Renewable
energy exposures expanded from €1.43 bn to €1.81 bn, while green buildings and energy efficiency rose cumulatively from €422 mn
to €511 mn, reflecting sustained demand for transition-related investments. At the same time, Sustainability-Linked Loans grew
materially from €1.01 bn to €1.37 bn, strengthening the role of general purpose sustainable financing. Although disbursements in
certain categories declined compared to 2024, total annual disbursements remained stable, reflecting a more selective origination
approach and longer-term financing structures rather than reduced activity.
International Subsidiaries
Corporate Banking
Outstanding balance as of
31.12.2025 (mn €)
Disbursed amounts within 2025
(mn €)
Dedicated purpose financings
491
125.5
Renewable energy
184
37
Green buildings
254
85
Energy efficiency
4
1
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International Subsidiaries
Corporate Banking
Outstanding balance as of
31.12.2025 (mn €)
Disbursed amounts within 2025
(mn €)
Clean transportation
30
0.5
Pollution Prevention & Control & Circular Economy
-
-
Other
19
2
General purpose financings
36
28
Business mix
-
-
Sustainability-Linked Loans (SLL)
36
28
Total sustainable financing
527
153.5
Across Eurobank’s international subsidiaries, the sustainable corporate portfolio amounted to €527 mn in outstanding balances in
2025, with €153.5 mn disbursed during the year, reflecting strong origination activity combined with a focused, project-driven
approach. Dedicated purpose financings dominated the portfolio (€491 mn), primarily driven by green buildings (€254 mn) and
renewable energy (€184 mn), while additional exposures related to energy efficiency, clean transportation and other eligible
categories remained more limited. General purpose financings reached €36 mn, supporting broader sustainability-aligned business
needs. Sustainability-Linked Loans totalled €36 mn, with €28 mn disbursed during the year, indicating a growing uptake of
performance-linked sustainable financing structures. Overall, the combined portfolio composition demonstrates a clear emphasis on
high-impact, low-carbon sectors and highlights the potential for future scaling across Eurobank’s international operations.
In Luxembourg, the local subsidiary Eurobank Private Bank Luxembourg, is focused on providing private banking and wealth
management services. While serving a limited market segment, the Bank is currently aligning its activity with the broader Group’s
policy of promoting sustainable lending and investment.
The current contribution of subsidiaries to Sustainable Finance volumes reflects the ongoing implementation of their respective
Sustainable Finance Frameworks. In line with the Group’s strategic direction, these frameworks are being systematically deployed
and are expected to progressively enhance the alignment of subsidiary portfolios with the Group’s financed emissions targets and
long-term decarbonization pathway.
For further information regarding Sustainability-Linked Loans (SLL), please refer to note 20 “Loans and advances to customers” of the
consolidated financial statements.
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23
Greece
Retail Banking
Outstanding
balance as of
31.12.2025
(
mn €)
Disbursed
amounts
within 2025
(
mn €)
Outstanding
balance as of
31.12.2024
(
mn €)
Disbursed
amounts
within 2024
(
mn €)
Green mortgage loans
237
87
105
72
Energy renovation loans
36
18
26
8
Bridge Financing – Exoikonomo
-
-
-
-
Electric vehicle loans
4
2
5
2
Photovoltaic SB loans to small businesses and individuals
35
2
38
12
Net metering
1
0
1
-
Other dedicated purpose sustainable loans to small businesses
18
17
7
5
Total sustainable financing
331
126
182
100
In Greece, the total sustainable financing portfolio expanded materially to €331 million, a 82% increase year-on-year, driven mainly
by an extremely strong performance in green mortgages (+126%), with significant increases also in energy renovation and dedicated
purpose sustainable loans to SBs.
International subsidiaries
Retail Banking
Outstanding balance
as of 31.12.2025 (
mn
€)
Disbursed amounts
within 2025 (
mn €)
Green mortgage loans
695
119
Energy renovation loans
8
2
Electric vehicle loans
29
19
Photovoltaic SB loans to small businesses and individuals
2
1
Other dedicated purpose sustainable loans to small businesses
19
7
Total sustainable financing
753
148
Across Eurobank’s international subsidiaries, the sustainable retail portfolio reached €753 mn in 2025, primarily driven by green
mortgage lending in Cyprus. Outstanding green mortgage balances amounted to €695 mn, forming the core of the portfolio. Total
disbursements during the year reached €148 mn, of which €119 mn were green mortgages. Additional contributions came from
energy renovation and electric vehicle loans, while Bulgaria added €19.5 mn in sustainable SME lending with €7 mn disbursed.
Regarding bond positions, as at 31.12.2025 the Group held €170 mn in Sustainability -Linked Bonds (the corresponding amount for
the Bank was €152 mn; 2024: €226 mn).
23
RBB financings, EBRD-supported facilities, as well as Green Loans and Green Energy products.
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Positions in green / sustainable bonds in the Banking Book
Unit
Outstanding balance as
of 31.12.2025
Outstanding balance as
of 31.12.2024
Positions in Sustainability-Linked Bonds
mn €
170
248
For more information on Sustainability-Linked Bonds, please refer to note 22 “Investment securities” of the consolidated financial
statements.
Targets on sustainable financing and investment offerings [MDR-T]
As part of the Group’s ongoing efforts to align its business strategies with global sustainability goals, the financed impact strategy is
underpinned by clear targets for Eurobank’s sustainable finance and investment offerings. These targets, beyond reflecting the Bank’s
commitment to integrating ESG factors into our financial services, they guide our approach to funding projects that have a positive
impact on both society and the environment. Through transparent and measurable goals, we aim to support the transition to a more
sustainable economy while delivering responsible investment opportunities for Eurobank’s clients. Sustainable financing Targets are
based on the classification approach and/or eligible activities described by the Group’s SFF.
The table below demonstrates Eurobank’s performance against the targets set:
2025 Performance and progress
Portfolio Targets
2 billion in new green disbursements to corporates by 2025 (for 2023-
2025)
> € 3.3 bn as of 2025 - Target achieved
20% of annual new corporate disbursements to be classified as
Green/Environmentally Sustainable
c. 20% - Annual target achieved
20% stock of green exposures by 2027 for the corporate portfolio
c. 19% - on track to achieve target
Mobilise €2.25 billion total green RRF funds in the Greek economy by
2026
c. € 2.1 bn - on track to achieve target
No new investments in fixed income securities (excluding exposures in
sustainability/ green bonds) towards the top 20 most carbon-intensive
corporates worldwide
0 new exposures – Target maintained
€200 million annual disbursements of Sustainability-Linked Loans for the
CIB portfolio.
c. € 449mn in SLL disbursements– Annual target achieved
Sectoral targets
35% of new disbursements in the energy sector to be directed to (RES)
financing
> 49% of sectoral disbursements towards RES – Annual
target achieved
80% of disbursements related to the construction of new buildings to be
allocated to green buildings
100% of disbursements to construction of green buildings
– Annual target achieved
20% of new disbursements related to mortgage loans (excluding “Spiti
mou” (I + II)”) to be allocated with EPC B+ and above.
loans with EPC B+ and above – Annual target achieved
Retail Banking targets
€150 million new Retail green disbursements by 2026
More than €100 million increase in our new green
disbursements towards households and small businesses –
Annual target achieved
Once the Group’s Net-Zero Strategy is finalized for all sectors, each subsidiary will set its own specific targets. This will ensure that
every part of the Group effectively contributes to our overall sustainability objectives, while considering their unique operational
contexts and challenges.
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3
Social information
3.1
Own workforce [S1]
3.1.1
Strategy
Material impacts, risks and opportunities and their interaction with strategy and business model [ESRS 2 SBM-3]
The actual and potential impacts on own workforce which have been identified in the course of the DMA are connected to the Group’s
strategy. The Group has committed to contributing to the achievement of the United Nations Sustainable Development Goals (SDGs)
and the UN 2030 Agenda, as a signatory to the UN Global Compact since 2008, and by actively promoting its fundamental principles
and applying the precautionary approach. In this context key component of the Operational Impact Strategy is the Societal Impact
that focuses on providing a diverse and inclusive environment for its people and clients, while fostering sustainable development and
prosperity for the benefit of society. The Societal impact encompasses several key commitments, such as embedding a diverse and
inclusive environment by 2030 and cultivating a culture of wellbeing by 2026. These key strategic commitments address material IROs
of working conditions, other work-related rights, and ensuring equal treatment and opportunities for all.
The references to Eurobank’s Sustainability Strategy in this section relate to the Strategy currently in force during the 2025 reporting
period. In parallel, the Group is progressing the update of its Group Sustainability Strategy, which will build on the existing framework
and further strengthen the integration of sustainability across its operations and activities.
Scope of assessment:
With regards to material impacts, risks and opportunities, all people in the workforce who could be materially impacted by business
activities are in the scope of disclosures, covering own operations and the value chain.
Types of workforce recognized within its workforce:
●
Employees who are directly employed by the organisation: permanent (with or without probation period), full-time, part-
time employees, as well as other staff members such as trainees, or those who have self-employed status.
●
Non employees who are provided by third party undertakings primarily engaged in employment activities.
Material impacts, risks and opportunities:
All the identified negative impacts related to Eurobank’s own workforce resulting from the DMA have been classified as potential.
Eurobank, through various measures and mechanisms, such as compliance with labor laws and standards, employee surveys, work-
life balance initiatives, diversity training and awareness programmes, ensures that any related impacts with widespread or systemic
effects will not materialise. Through materiality assessment, the magnitude and scope of potential and actual impacts is taken into
consideration and are analyzed further. Identified impacts related to Eurobank’s own workforce could only be linked to individual
incidents of discrimination or unethical behaviour.
Own Workforce and Working conditions
Impact
Positive
Actual
Generates direct, indirect, and induced jobs, provides competitive wages and benefits in
alignment with its remuneration policy, and incorporates Employee Engagement surveys to
quantify employees' opinions on well-being.
Positive
Actual
Supporting employee’s well-being through providing satisfying and high-quality working
conditions, including adequate workspace and respect of privacy.
Risk
Non-compliance with modern workplace expectations (good working conditions, adequate
salaries, workplace safety) can affect motivation and performance, leading to decreased
productivity.
Opportunity
Demonstrating commitment to exemplary working condition expectations, such as offering
adequate salaries, promoting work-life balance, and ensuring workplace safety, can attract and
retain employees.
Equal Treatment and Opportunities for All
Impact
Positive
Actual
Implementing internal management systems and initiatives that improve employees’ ability to
live free from gender/sexual/ethnic/racial discrimination and ageism.
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Vulnerable groups:
Conducting the materiality assessment, the main types of people of own workforce who are or could be negatively affected have
been identified. Some employees may be at greater risk of harm. To gain this insight, the materiality assessment is informed by the
Diversity, Equity, and Inclusion Policy, which identifies as vulnerable groups those that may experience gender or age discrimination,
people with disabilities and LGBTQ individuals. “Equal Treatment and Opportunities for All” related risks and opportunities could
result from impacts and dependencies on those vulnerable group of people within own workforce.
Environmental and financed impact pillars:
The environmental pillar of the Bank’s Operational Impact Strategy is centered around reducing carbon emissions and achieving
operational net zero by 2033. Key drivers in order to achieve this target are energy efficiency plans, transitioning to electromobility,
minimising business travel, transitioning to cloud services as well as becoming a paperless banking network. The Bank’s operational
transition plan is not expected to have material impacts on its employees.
The financed impact pillar of the Bank’s Sustainability Strategy focuses on aligning the portfolio with 1.5oC sectoral transition
pathways (which is also the case for subsidiaries’ portfolios) through the promotion of sustainable financing as well as the
management of sustainability-related risks. Efforts towards those areas will require for employees to gradually focus on promoting
sustainable financing / products and consider client sustainability risks in their day-to-day activities. These aspects might entail
upskilling which is expected to have a positive effect on employees.
Eurobank is a signatory to the UN Global Compact since 2008, and is committed to respecting, actively supporting and promoting the
10 fundamental principles relating to human rights, labour rights, protection of the environment and anti-corruption. Eurobank is
committed to upholding the highest standards of human rights and ethical conduct throughout its operations and supply chain. Based
on its Code of Conduct and Ethics and Human Rights Statement, the Group adheres to upholding the highest standards of human
rights and ethical conduct throughout its operations and supply chain. It is ensured there are no operations at significant risk of
incidents of forced labor, compulsory labor and child labor.
Reference to detailed actions and policies:
Detailed descriptions of policies, actions, and initiatives addressing these impacts, risks, and opportunities are provided in the
following sections of this statement.
Policies related to own workforce [S1-1]
Eurobank has adopted policies to manage its material impacts, risks, and opportunities related to its own workforce and disclose
them in accordance with the minimum reporting requirements laid out in the Minimum Disclosure Requirements with regards to
policies (MDR-P) as defined in ESRS 2.
Eurobank is committed to engaging with stakeholders by ensuring a high level of accountability
in policy development and implementation. Policies are approved by the appropriate Governance bodies such as the Board of
Directors or specialized committees, which ensure that there is alignment with the Group's strategic goals and stakeholder interests.
The Group is committed to opposing all forms of discrimination, inequality, and human rights violations, actively promoting
individuality in line with its Diversity, Equity & Inclusion Policy and Human Rights Statement. It ensures that all policies, procedures,
and human resource management practices are guided by a deep respect for human rights, fostering an environment where diversity
and equity are recognised and celebrated. Through the implementation of inclusive policies, commitments, and mechanisms, t
he
Group reinforces its dedication to human rights within its workforce, in alignment with the UN Guiding Principles on Business and
Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational
Enterprises.
Eurobank prioritises respect to human rights in line with the UN Guiding Principles on Business and Human Rights. The Group avoids
causing or contributing to adverse human rights impacts through its own operations and business relationships.
Human rights
mitigation measures are implemented through the Code of Conduct and Ethics, the Diversity, Equity & Inclusion Policy and the Policy
against Violence and Harassment. These publicly available documents establish processes to identify, prevent and mitigate potential
adverse human rights impacts in the Bank’s operations and business relationships. The Supplier Code of Conduct and Ethics extends
these mitigation requirements to the Bank’s value chain, requiring suppliers to respect fundamental human rights principles, prohibit
child labour, avoid discrimination, implement risk assessment procedures and take corrective measures in cases of non-compliance.
Where adverse impacts are identified, remediation mechanisms are available through established grievance channels, investigation
procedures and disciplinary processes, including corrective actions in line with the Code of Conduct and Ethics and the relevant Group
policies. As a signatory to the UN Global Compact since 2008, Eurobank actively supports the 10 principles related to human rights,
labour rights, environmental protection, and anti-corruption. Eurobank is also signatory to the UNEP FI Principles for Responsible
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Banking, publicly disclosing self-assessment reports as part of its commitment to responsible banking practices. Additionally,
Eurobank adheres to collective bargaining labor agreements in Greece and the other countries in which it operates, and participates
in various organisations promoting sustainable growth and responsible entrepreneurship, including the Steering Committee for
Sustainability, Governance and Green Banking of the Hellenic Bank Association.
Policy / Statement
Key Features / Commitments
Oversight / Accessibility
Diversity, Equity & Inclusion Policy
Opposes discrimination, promotes
individuality, supports vulnerable
groups, zero-tolerance for harassment
Nomination & Corporate Governance
Committee published on Group website
Human Rights Statement
Exclusion of forced/child labour,
equitable compensation, reasonable
working hours, freedom of association
Applies across value chain, published on
Group website
Policy against Violence and Harassment
Zero-tolerance for violence/harassment,
clear reporting channels, confidentiality,
disciplinary action
Committee against Workplace Violence
and Harassment; published on corporate
website
Occupational Health & Safety Policy
ISO 45001:2018 standard, crisis
response, health check-ups, safety
assessments, Safety Coordinators
Annual objectives, regular monitoring
Code of Conduct and Ethics
Daily reference manual, mutual respect,
dignity, professionalism, compliance
monitoring
Distributed to 100% of staff; electronic
confirmation
Labour Agreements
Adherence to banking sector
agreements, fair working conditions
Group-wide application
Human Rights Statement
Eurobank’s Human Rights Statement applies across its value chain, encompassing employees, customers, and suppliers. A key priority
is ensuring all employees are treated with respect and dignity, promoting fairness through the exclusion of forced and child labour,
equitable compensation, reasonable working hours, and upholding freedom of association and data privacy. With customers,
Eurobank fosters a relationship of trust, offering fair and transparent services while encouraging feedback through accessible
complaint procedures.
Forced Labour, Child Labour, and Human Trafficking
Eurobank maintains a strict policy against all forms of forced labour, child labour, and human trafficking. The Bank prohibits these
practices both within its own operations and across its supply chain. This commitment ensures that Eurobank’s business practices
align with ethical standards, promoting human rights and dignity in all aspects of its operations. By upholding these principles,
Eurobank contributes to a fairer and more just workplace environment and ensures that its business relationships adhere to high
ethical and legal standards.
Wellbeing and Health & Safety
The Group is committed to maintaining the highest standards of Occupational Health and Safety, recognising the well-being of
its
employees as a critical asset and driver of growth. In line with national and European legislation, health and safety risks are proactively
assessed and managed, ensuring a safe environment for employees, customers, visitors, and stakeholders. The Group sets clear
annual objectives, regularly monitors performance, and encourages continuous improvement. Through innovative crisis response
plans, regular health check-ups, employee training, and ongoing safety assessments, a culture of safety is promoted. The main goal
is to establish a benchmark in the banking sector for health and safety.
The Group applies all measures required under national and EU legislation to ensure the health and safety of its employees, customers
and associates. At the same time, the Bank applies a Health and Safety Management System (HSMS), as per the ISO 45001:2018
international standard on Occupational Health and Safety. In this context, Eurobank implements a prevention and safety programme
for its employees through various initiatives. Eurobank’s Occupational Health and Safety System covers all its employees and
activities.
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Certain employees are designated as Safety Coordinators and Deputy Safety Coordinators. The responsibilities of the Safety
Coordinator and the Deputy Safety Coordinator include their obligation to immediately notify the competent officers of any work-
related risks and submit regular written reports regarding the current situation at the premises they are responsible for.
Diversity and Inclusion
The Group has committed to fostering a culture of diversity and inclusion and has adopted the “Diversity, Equity & Inclusion in
Eurobank” policy to ensure compliance with human rights standards, mitigate discrimination, and foster a diverse and inclusive
workplace.
The objectives of the Diversity, Equity, and Inclusion (DE&I) policy are focused on creating a diverse, equitable, and inclusive
workplace where all employees have equal opportunities, feel respected, and can thrive. The Group aims to build a representativ e
workforce, free from discrimination, and promote transparent processes that foster talent and clarity. The Group is committed to
strengthening an inclusive culture where individuals feel they belong and are empowered to be their authentic selves. Inclusive
leadership is key, and the leaders are accountable for creating an environment that supports all employees. With a zero-tolerance
policy for harassment and discrimination, a safe, healthy, and flexible work environment that prioritises employee well-being is
ensured. Externally, the Group focuses on creating a positive societal impact through education, employment opportunities, and
social initiatives, while promoting diversity in marketing and communications and ensuring ethical, non-discriminatory banking
services.
The DE&I policy outlines clear and specific commitments to support individuals from groups at particular risk of vulnerability, ensuring
an inclusive, equitable, and supportive environment for all employees. The policy focuses on the following key areas:
●
Gender Diversity – As a major employer of women, we are committed to provide the employment framework, culture,
working arrangements, learning and development, and equal career opportunities to empower female employees to thrive
and excel in senior management roles. The organisation is committed to advancing gender equality through targeted
programmes such as the "Women in Banking - Leadership Acceleration Programme" and through sponsoring initiatives like
"the Boardroom”, aiming to prepare women for Board -level and senior leadership positions, working towards gender
diversity and representation in the highest levels of leadership.
●
Parents and Families – The organisation recognises the diverse needs of families, offering an extensive range of benefits to
support parents, regardless of gender, age, or marital status.
●
Age Diversity – The policy promotes the strengths of different generations in the workforce, ensuring that knowledge, skills,
and experience are transferred effectively.
●
People with Disabilities – The organisation is committed to creating an inclusive workplace that values all employees,
offering equal opportunities for advancement, learning, and fair compensation.
●
LGBTQ+ – The policy ensures a safe, respectful, and inclusive environment for LGBTQ+ employees, with protections against
discrimination and harassment.
The policy applies to Eurobank S.A., its subsidiaries (international and in Greece), shareholders, Board members, directors,
representatives, employees, as well as to all interactions with customers, visitors, agents, contractors, suppliers, investors, external
service providers, business associates and the communities in which it operates.
The Nomination & Corporate Governance Committee is responsible for monitoring and assessing the effectiveness of the DE&I Policy.
The policy is readily accessible to all potentially affected stakeholders, as well as to those responsible for its implementation, through
the Groups' official website.
Eurobank prioritises mutual respect, integrity , and professionalism, ensuring that all employees treat the Group, its clients, and
colleagues with respect and dignity. The Group values diversity and fosters an inclusive environment that welcomes individuals
regardless of age, gender, ethnicity, religion, disability, or other personal characteristics. Eurobank is committed to equal employment
opportunities, meritocracy, and fair treatment for all staff. It upholds the principles of understanding and cooperation, encouraging
diverse opinions and supporting a culture free from discrimination, harassment, or intimidation. The Group has a zero-tolerance
policy for such behaviors and provides clear channels for reporting any concerns, including through managers, HR, compliance, or a
dedicated hotline. Staff are encouraged to speak up if they suspect any unethical conduct or regulatory issues.
Code of Conduct and Workplace Culture
The Group’s commitment to diversity and inclusion aligns with its values and is reflected in its Code of Conduct and Ethics. The Code
applies to every staff member, irrespective of segment, level or job description, as a daily reference manual. All senior management
have the duty to communicate the values of Eurobank and inspire all employees under their responsibility. The Code is distributed to
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100% of the staff members, including the Board Members, as well as any individuals who offer advisory services or are employed
based on fixed- term or project employment agreements. With reference to the Code of Conduct and Ethics, staff members confirm
having read and accepted the Code through an electronic platform. Group Compliance and the relevant auditing bodies of Eurobank
are responsible for monitoring and implementing the Code of Conduct and Ethics.
Respect for human dignity is at the core of Eurobank’s workplace culture, and the Group adopts a strict zero-tolerance stance against
violence, harassment, and sexual harassment. Any employee who experiences or witnesses such incidents is encouraged to report
them promptly through available communication channels. All reported incidents are treated with the utmost seriousness,
confidentiality, and respect, with a thorough investigation and disciplinary action if necessary. Eurobank strives to maintain a safe
and respectful environment where all associates are protected from any form of harassment or violence.
Policy Against Violence and Harassment
The
Policy against Violence and Harassment
applies to a wide range of individuals associated with Eurobank. It includes all members
of the Group's staff, regardless of the type of employment contract they hold, whether permanent, temporary, fixed term, or open-
ended. Additionally, it covers individuals working under project contracts, independent service agreements, or salaried mandates.
The policy also extends to employees contracted by third-party service providers who work on behalf of Eurobank, as well as those
participating in training programmes, such as interns, apprentices, and volunteers. It applies to members of Eurobank's staff even if
their work contract has expired, and it also covers candidates seeking employment with the Group. To ensure transparency and
accessibility, the policy is readily available to all staff, candidates, and other stakeholders through the corporate website.
The Committee against Workplace Violence and Harassment is entrusted with the oversight and implementation of this policy,
ensuring that its provisions are effectively carried out across the organisation.
Processes for engaging with own workforce and workers’ representatives about impacts [S1-2]
In alignment with the Sustainability Policy Framework, Eurobank engages with its employees. More specifically, it prioritises employee
upskilling and reskilling, maintains professionalism, and enforces anti-discrimination policies to foster an inclusive workplace. The
Group offers comprehensive benefits for employees regardless of gender, age, or marital status. Regular meetings, breakfast sessions,
and events facilitate dialogue between management and staff representatives. Enhanced communication channels like HR4U and the
Connected portal ensure responsiveness to employee inquiries. The Group promotes work-life balance, social and environmental
awareness, and volunteering and implements an ESG upskilling plan and awareness initiatives for employees to support sustainability
efforts:
●
“Connected”
access to strategic, business, HR and technology updates, while promoting Group-wide initiatives and fostering engagement.
In 2025, the platform recorded 8,637 unique users, with an average dwell time on content 34 seconds.
●
Leadership communications
management and employees, Eurobank organized a series of live meetings involving the Management team and employees
from all divisions. These sessions included three Senior Management meetings. Employees were given the opportunity to
submit questions -either anonymously or by name addressing strategic decisions, business initiatives, or HR-related topics,
thereby fostering an open and transparent dialogue with Top Management. Additionally, to strengthen direct
communication with the regional network, Retail Management conducted 8 onsite visits, while Top Management held 5
roadshows in key regional markets across Greece.
●
Support at work, HR4U
and schedules all necessary actions to better serve them. In 2025, HR4U handled over 22,547 requests. Requests cover a
broad range of topics relating to benefits and schemes, as well as to emergencies, such as blood or platelet requests for
employees and/or their family members.
Employee Perspectives and Stakeholder Engagement
The perspectives of employees inform the Group’s decisions and activities aimed at managing the actual and potential impacts on
them. Employees participate in stakeholder engagement as part of the annual Double Materiality Assessment (DMA), which enables
the understanding of their concerns and priorities. The material topics identified through this engagement are then taken into account
and inform the Group’s policies, actions, and targets. This ensures that the issues that matter most to employees are addressed in
the decision-making processes. Engagement occurs directly with employees, through the completion of questionnaires on potential
material impacts, risks, and opportunities. The Sustainability Management Committee is responsible for overseeing the DMA process
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and approving the proposed contents of the sustainability-related reports that derive from the results of the DMA. The effectiveness
of engagement is measured by the participation rate.
Eurobank’s approach to sustainability is to foster strong relationships of trust, cooperation and mutual benefit with all stakeholders
affected by its activities, directly or indirectly. The Group promotes two -way communication and develops ongoing dialogue with
stakeholders, to actively meet the expectations, concerns and issues raised by all its stakeholders. The Double Materiality Assessment
is conducted on an annual basis and reviewed and approved by the Sustainability Management Committee, in accordance with ESRS
standards.
Channels and Methods of Engagement
Eurobank ensures that the workforce’s insights actively shape its decisions and guide its activities aimed at managing both the actual
and potential impacts. Engagement occurs directly with employees as well as with their representatives. Eurobank fosters ongoing
dialogue with its own employees through the following channels:
●
Sustainable dialogue with employee representatives at company and industry level
●
Staff-management communication via regular meetings, breakfast with the Management, and events
●
Communication through the HR4U contact center
●
Connected, the Bank’s internal portal
●
Axiopoio and Senior Performance Management, employee performance assessment systems both focusing on development
and feedback
●
Upskilling and reskilling of employees
●
Social and environmental issues awareness campaigns (TeamUp Employee Volunteering Team)
●
myPROSPERITY wellbeing programme
●
360-degree informative and awareness internal communication campaigns
The TeamUp volunteer programme encourages employees and their families to participate in corporate voluntarism activity. In 2025,
TeamUp focused on raising awareness about climate change, environmental risks and social issues. More than 1,700 employees
participated in the programme in 2025, contributing over 4,520 hours of volunteer services.
Employee Engagement Initiatives
Improving employee engagement is a crucial goal for Eurobank, seeking to enhance productivity, foster a positive work environment,
and retain top talent. The Group has extended its efforts to engage its workforce through various initiatives and communication
campaigns. These initiatives leverage all available communication channels, including Viber messages, screensavers, emails, videos,
intranet, and more. By prioritising employee engagement with 360-degree communication initiatives, Eurobank demonstrates its
commitment to cultivating a supportive and motivating work environment, conducive to individual and organisational success.
At Eurobank, listening to our people is a strategic priority. As part of our commitment to fostering a high-engagement culture, we
conduct the WeSay Employee Engagement Survey every 18 months, inviting all employees in Greece and Cyprus to share their views
on engagement, satisfaction and wellbeing. The survey is based on globally recognised employee engagement benchmarking models
and serves as the Group’s primary employee engagement measurement tool.
The core focus of the survey is employee engagement, with key dimensions including psychological safety, wellbeing, leadership trust,
enablement, pay and benefits, collaboration, innovation, transformation readiness, ESG awareness and wellbeing support. The survey
also captures employee loyalty through the eNPS (employee Net Promoter Score) framework and collects insights on purpose,
happiness and workplace stress.
In the most recent survey cycle (WeSay 2025, completed in Q1), the survey achieved a strong 82% participation rate, ensuring broad
workforce coverage.62% of employees reported high levels of engagement, reflecting a positive and improving trend compared to
the previous survey cycle. Eurobank has established an annual KPI target of a 2% improvement in employee engagement yoy, which
was successfully achieved in 2025, demonstrating measurable progress and accountability in enhancing employee experience.
Survey results are analysed by business unit and demographic group to identify priority areas and define targeted actions. Findings
from the 2025 survey led to initiatives in areas such as:
●
Compensation and benefits communication
●
Process optimisation
●
Culture alignment and team collaboration
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●
Wellbeing and learning
Through the systematic monitoring of engagement indicators and the implementation of targeted actions, Eurobank ensures
continuous improvement in employee engagement and wellbeing, aligned with the Group’s strategy and sustainability commitments.
Management and Oversight of Engagement
To communicate its strategy and foster two -way dialogue between the management team and employees, Eurobank held meetings
with the Management, with employees from all divisions participating, as well as two Senior Management meetings. To foster an
open line of communication with the regional network, four onsite visits from Retail Management and five Top Management
roadshows took place in regional markets across Greece.
The People Advisory Committee holds the operational responsibility to ensure review and evaluation of all major employee
engagement initiatives, including employee surveys and communication.
Processes to remediate negative impacts and channels for own workforce to raise concerns [S1-3]
Grievance Mechanisms and Reporting Channels
In case of negative impacts on employees, Eurobank ensures, through grievance mechanisms and its Illegal or Unethical Conduct
Policy, that the appropriate remediation actions are taken. Eurobank encourages all stakeholders, including employees, to report
instances of potential or actual human rights impacts, unethical conduct, or violations such as discrimination, harassment, or
intimidation. Clear channels for reporting are established, including branches, the website, phone, email, and in-person
communication. Employees are expected to uphold a safe, respectful, and inclusive work environment, and are encouraged to speak
up about concerns regarding ethical, legal, or regulatory issues. Eurobank’s Policy of Reporting Illegal or Unethical Conduct ensures
that staff and third parties can report misconduct without fear of retaliation, fostering trust and protection.
Eurobank’s whistleblowing mechanism allows staff and third parties to report illegal or unethical conduct through designated internal
or external channels, including email (ethicshotline@eurobank.gr), phone (+30 214 4058990, 24/7), or by post to the Report Receiving
and Monitoring Officer (RRMO). All reports are investigated, and appropriate disciplinary actions are taken when the case is
confirmed.
Handling and Oversight of Reports
The responsible officer for the receiving and monitoring of reports (RRMO) is tasked with providing clear guidance on how to submit
a report, receiving and confirming receipt of the report within seven working days, and performing an initial assessment. The RRMO
is also responsible for designating the appropriate unit or person to handle the report, ensuring the confidentiality of the reporting
person’s identity and any third parties mentioned. Additionally, the officer monitors the progress of the investigation, maintains
regular contact with the reporting person, and ensures that feedback is provided within a reasonable period, not exceeding three
months from the receipt confirmation. The officer also plans and coordinates relevant training efforts to support the process.
The Board of Directors is responsible for ensuring the existence of a robust framework for reporting illegal or unethical conduct,
promoting continuous improvement of the Policy, committing to, promoting and practicing a speak-up/listen-up culture and ensuring
the appointment of the RRMO.
Investigation and Remediation Process
The Group encourages its workforce to document incidents of harassment, including actions taken to address them and prior requests
for assistance. The Group Human Resources, Group Compliance, and Group Internal Audit work together to examine grievances or
complaints, ensuring a prompt, thorough, and impartial investigation while maintaining confidentiality and protecting personal data.
If the investigation confirms a violation of the Group’s Policy against Workplace Violence and Harassment, the responsible Committee
determines appropriate disciplinary measures, taking suitable and proportionate action to prevent recurrence of such incidents.
The Group’s Policy for Reporting Illegal or Unethical Conduct provides protection against reprisal and ensures confidentiality for those
who report concerns. Staff are encouraged to raise issues of concern and speak up when they suspect potential wrongdoing or are
faced with conduct or situations that may raise ethical, legal or regulatory concerns.
The Group’s Policy against Violence and Harassment is supported by a Committee against Workplace Violence and Harassment, which
oversees the implementation of the policy and ensures that all reported incidents are treated with seriousness, confidentiality, and
respect, with thorough investigation and disciplinary action if necessary.
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Protection Against Retaliation
According to the Policy for Reporting Illegal or Unethical Conduct, Eurobank provides protection against reprisal and keeps
confidential the identity of those who have submitted information they know and consider to be accurate and true. Additionally,
there are policies in place to prevent any form of retaliation against individuals, including workers' representatives, utilising these
channels. For further reference, applicable information has been disclosed in accordance with ESRS G1-1 Business conduct policies
and corporate culture.
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 [S1-4]
Eurobank has formulated action plans to effectively manage the material impacts, risks and opportunities relating to its workforce,
which are consistent with ESRS 2 MDR-A. The following outlines a summarized description of the action plans and allocated resources.
Learning, Certification, Professional Development and Performance Management
Eurobank has implemented the following initiatives, aimed at delivering positive impacts to its own workforce:
●
Certifications:
The Bank consistently provides a range of learning solutions to facilitate employees achieve certification/re-certification of
their professional competence in providing investment advice, insurance mediation, mortgage credit and small business
banking. Over 1,280 new certifications were recorded in 2025, while more than 3,200 were re-certified in Greece.
●
Learning and Development:
In 2025, Eurobank delivered 529,852 total learning hours, including activities delivered to temporary employees and
contractors. The average number of learning hours per employee was 37.6. The Bank invested more than €3.2 million in
learning initiatives, ensuring employee upskilling, building leadership capabilities and strengthening expertise through an
extensive range of certifications and professional qualifications.
●
Leadership Capability Framework:
An update of the Leadership Capability Model was carried out in 2025. The updated model reflects emerging leadership
trends, future-fit capabilities, and the evolving demands of executive roles. Our new leadership framework is aligned with
global best practices and designed to support long-term organizational agility and sustainable success.
●
Performance Management:
Eurobank continued to implement the Group Performance Management framework, focusing on continuous feedback and
development. For Senior Executives, 360° Feedback is also used to support leadership growth. The framework is
implemented in accordance with the Group’s Performance Management Policy, which applies uniformly across all Eurobank
entities, promoting consistency and transparency. In 2025, a Bank-wide initiative named Compass Talks-Performance
Power-up was launched, addressed to all Eurobank managers in Greece. The initiative’s goal was to touch base with
managers and support them in improving performance management by transforming challenges into opportunities,
navigating the way Eurobank defines it, as well as learning how to handle low performing individuals.
●
Embedding Ethics and Responsibility in Banking, with a focus on Consumer Protection:
Commitment to transparent operations is a cornerstone of the Eurobank’s corporate culture. Compliance with the
regulatory framework and the obligations arising from consumer protection are key pillars for strengthening the Group’s
credibility and sustainability.
In 2025, a dedicated digital learning on Consumer Protection, specifically tailored for selected front-line and support roles,
was launched to enhance their knowledge regarding:
-
the Eurobank's obligations when providing products and services to consumers,
-
consumer rights and requirements of the regulatory framework,
-
the proper management of pre-contractual and contractual material,
-
unfair commercial practices and respective prevention methods,
-
the importance of responsible communication with consumers.
Through the programme’s practical examples and case studies, 725 employees had the opportunity to develop skills that
ensure the delivery of responsible and compliant customer service, within 2025. Moreover, the initiative will have been
completed by all the relevant roles with Q1 2026.
●
Cultivating Future-Ready Leaders and Managers
o
Leadership development
– A significant leadership shift is underway at Eurobank, anchored in the launch of the
Leadership Development Programme, jointly designed with INSEAD and introduced in Q4 2024. The programme
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created a distinctive space for the first cohort of senior leaders to challenge assumptions, engage in deep self-reflection,
exchange diverse perspectives, embrace innovation, and strengthen a shared commitment to creating meaningful
value—for Eurobank’s clients, people, and society. Delivered through 50+ hours of immersive learning and real-world
exposure over a five-month period—including a field trip to Paris—the programme enabled leaders to gain first-hand
insights into emerging trends and innovation ecosystems. At the same time, it strengthened their capability to navigate
complexity, drive strategic change, and lead with purpose. Building on this momentum, Eurobank continues to
strengthen its strategic leadership capabilities with the launch of a second cohort, featuring enhanced content and
expanding the programme’s reach to a total of 59 senior leaders.
o
Management Skills development
–
Ιn 2025, Eurobank launched a new management skills framework, marked by the
introduction of ManagersDay - an initiative designed to introduce this new development framework to all managers,
reinforcing a shared strategic vision across the organization. Managers from across Greece gained a clear understanding
of their contribution to the Bank’s strategic progress, as well as the collective value created through their daily
collaboration, reinforcing a culture of engagement and responsible leadership. In order to support managers towards
this shift, new learning journeys were introduced for all new and experienced middle managers at Eurobank, aimed at
strengthening core managerial skills and enhancing effectiveness. These journeys combine digital learning modules,
interactive workshops, and virtual masterclasses, with a strong focus on building strategic leadership capabilities,
covering skills such as innovative thinking, stakeholder management, empowering and inclusive leadership, and the
ability to connect and enable teams.
Delivering more than 20,000 learning hours for 1,150 Senior leaders and managers in 2025, the abovementioned
initiatives were attended by 82.3% of this community in Greece and accounted for more than 19% of the total
workforce in the country.
●
Generative AI capability
o
For senior leadership
Eurobank implemented a targeted executive learning initiative on Generative Artificial Intelligence, developed in
collaboration with London Business School. The two-day masterclass enhanced GenAI fluency among senior leadership
by establishing a shared understanding of the technology, its applications, value creation potential, ethical
considerations and transformative role in banking. The programme equipped leaders to drive innovation and
responsibly integrate GenAI into operations, supporting the delivery of smarter, faster and more personalised services,
while upholding high ethical standards. More than 105 senior leaders participated in this programme during 2025. This
initiative reinforces Eurobank’s commitment to continuous skills development towards digital transformation and
innovation.
o
For all employees in Greece
Aiming to provide essential knowledge on Generative AI, along with practical, applicable ideas that can be utilized in
daily work, Eurobank introduced a special digital learning programme, addressed to individuals taking their first steps
in
Generative AI, regardless of role, that does not require technical knowledge to follow.
The programme includes
selected content from the Udemy Business digital learning library and covers fundamental
concepts, practical
workplace applications, AI interaction techniques (prompting), ethical considerations, and
responsible use, along with
a set of optional selected online courses for deeper exploration of more advanced concepts,
practical examples for
everyday tasks, and advanced prompting. Furthermore, the programme offers a curated set of
articles on Gen AI
applications within the banking industry, designed to reinforce organizational readiness for effective
AI adoption.
o
Sales training programme
In 2025, Eurobank launched a new learning initiative focused on sales methodology, based on Behavioral Economics,
designed to transform employees into trusted advisors through an interactive workshop. Participants from the Retail
Branch Network gain a clear understanding of the competitive landscape and develop a structured and applicable sales
strategy, while managers deepen their role as sales coaches, enhancing their ability to support and guide their teams
effectively. Participants reported the value of the programme toward their role challenges, practicality of tools for
implementation and performance uplift.
Talent Acquisition, Career Development, Talent Management, and Succession Planning
Eurobank implements structured and inclusive initiatives to attract talent from a broad range of professional backgrounds, skills and
career stages, supporting equal access to employment opportunities and long-term workforce sustainability. The Group focuses on
strengthening its talent pipeline by engaging individuals with different experiences and expertise, including technology skills through
the TechYourFuture Talent Programme, international professional experience through the Brain Regain initiative, and early-career
talent through systematic engagement with universities and career forums. In parallel, the “Empower the Network” programme
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combines internal career development with selective external recruitment, ensuring a balanced and merit-based approach to talent
acquisition.
Across the entire employee lifecycle, from recruitment and learning to performance evaluation, promotions and career development,
Eurobank applies objective, transparent and merit-based criteria, ensuring equal opportunities, consistent decision-making and
freedom from bias. Through these principles and initiatives, the Group enhances organisational capability, supports knowledge
transfer and builds a resilient workforce aligned with its strategic and business priorities.
●
Career Forums & Academia Engagement:
Eurobank continues to demonstrate its strong commitment to supporting the new generation and strengthening its position
as an employer of choice, through active participation in leading career forums and employability initiatives across Greece.
The Group took part in major national career events, including the Panorama of Entrepreneurship & Career Development,
Career Days by Kariera.gr, and Talent Days by CollegeLink, engaging directly with young professionals and emerging talent.
In addition, Eurobank participated in a wide range of career events hosted by top academic institutions, such as the Athens
University of Economics and Business, the University of Piraeus, the University of Macedonia, the Technical University of
Crete, and other universities across the country, reinforcing its commitment to nurturing youth employability and fostering
industry-academia collaboration. Strengthening the events’ international dimension, Eurobank also welcomed a delegation
from the Technical University of Munich to its headquarters, offering the opportunity to engage with executives, exchange
perspectives on the future of financial services, and gain a deeper understanding of Eurobank’s strategic priorities and
innovation agenda.
●
Other Career Events:
For the 10th consecutive year, Eurobank, in collaboration with the Panorama of Entrepreneurship & Career Development,
successfully hosted the Eurobank Business Day on-site career event. In 2025, the event welcomed 60 students and recent
graduates from leading academic institutions, offering them the opportunity to interact directly with senior Eurobank
executives and high-performing employees, explore real business challenges, and gain a deeper understanding of the Bank’s
strategy and operations. This year’s Eurobank Business Day centered on Innovation, Technology and AI, showcasing the
Group’s commitment to digital transformation and future-focused skills. Through interactive workshops, career corners and
panel discussions, participants were introduced to emerging technological trends, the impact of AI on banking, and the
evolving skillsets shaping the future of work.
●
Brain Regain / Strategic Talent Attraction Initiatives:
The Brain Regain initiative includes dedicated Career Days organised by the Greek Public Employment Service (DYPA) and
the Ministry of Labour & Social Security, in collaboration with the Ministry of Foreign Affairs. These events aim to connect
high-skilled Greek professionals living abroad with employment opportunities in Greece and to support their repatriation
and reintegration into the local labour market. In alignment with this national effort, Eurobank strengthened its strategic
focus on attracting experienced Greek talent working overseas. Throughout 2025, the Bank conducted targeted outreach in
major global talent hubs—including London, Stuttgart and New York —enabling direct engagement with professionals
interested in returning to Greece and contributing to the country’s economic and innovation landscape.
Through dedicated networking events, market insights sessions and individual meetings, Eurobank showcased its career
opportunities, innovative initiatives and strong employee value proposition, positioning itself as an employer of choice for
repatriating talent. As a result of these efforts, Eurobank was recognised nationally for achieving the highest number of hires
from abroad within the Greek market, reinforcing its leading role in supporting the return of high-calibre expertise to Greece.
This strategic commitment continues to strengthen Eurobank’s internal capabilities, enhance knowledge transfer and
contribute to the broader national objective of reversing talent migration and supporting sustainable economic
development.
●
TechYourFuture Talent Programme 2025:
In 2025, Eurobank continued to strengthen its commitment to developing next-generation technology talent through the
TechYourFuture programme, a strategic initiative designed to attract, cultivate, and upskill young professionals with high
potential. This year, the programme brings together 14 participants in total, including 7 new joiners from Greece, 4 from
Bulgaria, and 3 employees from Cyprus who are part of the Bank’s existing staff. All participants join Eurobank as full-time
employees and embark on a dual journey that blends professional experience with structured learning. From their first day,
they are enrolled in a two-year technology development academy, during which they split their time equally between
working and learning, dedicating 50% of their schedule to practical, on-the-job experience and the remaining 50% to focused
training.
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The curriculum combines certified learning pathways, hands-on project exposure, and mentoring from experienced
technology leaders. Delivered in collaboration with Microsoft, the programme ensures access to industry-leading resources
and deep expertise in emerging technologies. TechYourFuture continues to serve as a key driver in building Eurobank’s
internal technological capabilities and preparing future talent for critical roles within the Bank’s digital transformation
strategy.
Development Plans and Improvement Plans:
Career development holds significant importance within the Group. Employees work with their managers to create tailored
Development Plans that align with their professional growth and career aspirations. Alternatively, an Improvement Plan can be
crafted to outline a strategic path for enhancing performance and addressing areas requiring development. Both plans are designed
to cultivate employee competencies and behaviours through targeted training and development initiatives, aligning their skillsets
with their current roles or potential future positions.
●
Talent Management Programme:
Eurobank implements a structured, bank-wide Talent Management Programme focused on identifying, developing, and
strategically leveraging a strong internal talent pipeline to support business priorities. In 2025, the talent pools across all
Business Units reviewed to ensure a strong and current pipeline of high-potential employees. This enhanced approach
includes a talent segmentation model with a focus on mobility and structured career discussions, enabling tailored
development offerings such as job swaps and rotations, mentoring, and job shadowing to support the next career steps of
career-oriented talents.
●
Prosper Class of 2025:
As part of developing the Bank’s Future Leaders identified through the Talent Management process, Eurobank continued
the PROSPER programme in collaboration with ALBA Graduate Business School — a specialised leadership development
experience designed to strengthen strategic thinking and modern leadership capabilities. The programme offers a
comprehensive learning journey that includes external perspectives, interactive sessions, cross-functional networking,
practical guidance and dialogue with experienced academic faculty, encouraging innovation, critical thinking and forward-
looking decision-making. In 2025, 32 high-potential employees participated in and successfully completed the PROSPER Class
of 2025, reinforcing Eurobank’s commitment to cultivating the next generation of leaders.
●
Employee Mobility & Internal Career Marketplace:
In 2025, Eurobank continued to enhance internal mobility through the Career Marketplace intranet platform, which
supports employees in exploring available job opportunities and understanding potential career paths within the
organisation. The platform also provides practical guidance, tips and best practices to help employees navigate the internal
recruitment and mobility process effectively.
During 2025, 355 job openings were posted on the Career Marketplace, with 48% of positions in Greece filled internally,
reinforcing Eurobank’s commitment to developing and promoting talent from within and strengthening career growth
opportunities across the Group.
●
Succession Planning:
The Group’s C-Level Succession Planning framework is assessed annually, following a structured and comprehensive process,
according to the guidelines of the Group’s Nomination and Corporate Governance Committee as well as its Board of
Directors. The Bank has a C-level Succession Planning Policy in place to ensure executive bench strength for the C-level roles
is aligned with the Group strategy, purpose and leadership culture, aiming to achieve business continuity and growth. C-
level Succession Planning focuses on mobility of successors, while female representation is of outmost importance. In 2025,
female successor representation increased to 30% at C-Level. Eurobank also introduced targeted career discussions with
high potential internal successors, with the discussion focusing on progress and goals in their current role, career aspirations
and development areas. In 2025, the Bank completed the first review of C-1 Succession Planning, complementing the
existing C-level succession framework. Notably, 38% of the total C-1 successor pool were women, demonstrating the strong
potential for further enhancement and support of the Bank’s female senior talent pipeline. Key radar talented resources
were identified and will be actively managed through the Group Talent Management programme.
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Wellbeing, Work-Life Balance, and Inclusion
●
Wellbeing and Work-Life Balance:
In 2025, Eurobank further embedded wellbeing into its people strategy, recognising it as a key enabler of employee
engagement resilience and sustainable performance. The Bank adopts a holistic and preventive approach to wellbeing,
combining structured programmes, accessible support mechanisms and continuous assessment of employee needs. The
myPROSPERITY framework remains the central wellbeing platform, supporting employees across all stages of their personal
and professional lives through four interconnected pillars:
o
For my body
o
For my soul
o
For my community
o
For my future
The Bank collaborates with external partners to further strengthen employees’ financial literacy and informed decision-
making.
Wellbeing initiatives are designed to ensure equal access, flexibility and confidentiality, enabling employees to manage their
wellbeing according to their individual needs and life circumstances As part of this initiative, employees eagerly participated
in 9 online myPROSPERITY Talks and live events delivered during working hours, delving into contemporary topics.
Additionally, the employees had access to articles and podcasts, via internal channels, that not only inspired and informed
them, but also equipped them with new skills, empowering them to fortify their emotional resilience.
●
For my future – Financial Wellbeing
Financial wellbeing is an integral part of Eurobank’s holistic wellbeing approach. Under the myPROSPERITY – For my future
pillar, the Bank supports employees in strengthening their financial confidence through targeted initiatives and digital tools.
In this context, Eurobank expanded its collaboration with Plum, a leading European fintech platform, offering employees
free access to a personalised digital money management solution. Through automated saving, budgeting and investment
tools powered by artificial intelligence, employees are supported in managing their personal finances in a simple and
informed way.
●
For my body – Nutrition & Healthy Habits
Promoting healthy nutrition is a key component of physical wellbeing. Under the myPROSPERITY – For my body pillar,
Eurobank introduced initiatives that support balanced dietary habits and informed everyday choices. Employees at the
Eurobank Campus in Nea Ionia have access to free individual nutrition counselling, including body composition analysis and
personalised dietary plans, provided by a certified clinical dietitian. In parallel, the Bank launched a collaboration with
Meallion, offering employees access to healthy, balanced meals at a preferential corporate rate, supporting healthy choices
while also promoting sustainability through responsible sourcing and recyclable packaging.
Digital & Preventive Wellbeing Tools
To complement in-person support, Eurobank provides digital wellbeing solutions that promote autonomy and accessibility:
●
The Coach Platform
wellbeing, available to all employees free of charge
●
Parental and Family Leave:
Eurobank offers extra maternity/childbirth leave (with flexible hours or accrued leave), paid parental leave (19+2 weeks,
over 2 weeks above the legal minimum, with 1,152 total paid weeks granted in 2025), unpaid parental leave, paid leave for
single parents, adoption, disabled children and medical caregiving, and leave for school-related child activities.
●
Flexible Work Arrangements:
Hybrid work up to 3 days/week from home – 81% of middle/back -office staff opted in via formal agreement. Flexible
start/end time within a 2-hour range. Time-out reminders to support on-time clock-out (regulatory compliance).
●
Disability Inclusion:
1 hour less per day for employees with >50% disability.
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●
Diversity and Inclusion Initiatives:
As part of its commitment to Diversity and Inclusion, the Group introduced the 3rd Season of Women in Banking (WiB) in
December 2024, following the highly successful and award-winning previous two seasons. WiB is a programme aimed at
empowering women within Eurobank to advance to higher leadership roles, drive transformative change within the
organisation, and advocate for an inclusive and equitable work environment. Designed by and addressed to talented women,
this programme integrates mentoring with learning through interactive workshops, virtual masterclasses, gaming and
various engaging activities. In 2025, the Bank successfully completed the third season of the Women in Banking (WiB)
programme, following the strong momentum of the previous cycles. The collaboration among participants from all three
seasons, together with the involvement of all mentors and mentees, has fostered a vibrant and growing WiB Community
within Eurobank.
All three (3) seasons of WiB concluded with resounding success, encompassing 2,200 hours of educational programmes and
over 980 hours of mentoring sessions. The collaboration among participants from all cycles, comprising of 188 mentors and
mentees, culminated in the formation of a vibrant and influential community within Eurobank. This community aims to
foster social connections, expand professional networks within the Group, and enhance professional growth through
knowledge and idea exchange. The WiB Community has already undertaken several initiatives with the objective of
maintaining its active presence and generating a positive impact on its members, other female colleagues within Eurobank
and the broader organisation.
WiB not only serves as a cornerstone for women’s empowerment but also plays a pivotal role in championing diversity and
inclusion, cultivating a workplace founded on acceptance and mutual respect. With a forward-looking approach and
unwavering dedication, the WiB community is spearheading endeavors to empower women and foster a more inclusive
leadership landscape.
So far, out of the 188 WiB community members, a significant number has grown to become new managers as well as a
senior managers, increasing the percentage of women in senior leadership positions, a key goal of the Women in Banking
initiative. It should be noted that most WiB participants already were managers. Promotions and remuneration rewards
were also plentiful within the WiB community, showcasing how impactful and empowering the programme is to
performance, not just mindset.
The abovementioned initiatives are the ones in place within the wider spectrum, related to the employees of the Greek
entities. There are more initiatives implanted on a local level, based on the specific characteristics and needs of its entity.
●
Women’s Empowerment Principles (WEPs):
In 2024, Eurobank signed the Women’s Empowerment Principles (WEPs) which provide essential guidance for businesses
striving to promote gender equality and empower women within the workplace, marketplace, and broader community.
Established by UN Women and the UN Global Compact, these principles are informed by international labour and human
rights standards, recognising that businesses play a critical role in advancing gender equality and women's empowerment.
Eurobank's commitment to these principles transcends mere rhetoric; it is integrated into its Code of Conduct and reflects
the organisation's core values. With a steadfast emphasis on empowering women and enhancing their leadership
opportunities within the Group, Eurobank's dedication to the WEPs represents a meaningful step towards this goal. Women
empowerment workshops (gender pay gap) further reinforce this commitment. By adopting the Women’s Empowerment
Principles, the Group reaffirms its unwavering commitment to fostering a sustainable and inclusive future for its
organisation, its employees, and the wider community in which it operates.
●
Connected Intranet and Internal Communication
Eurobank’s internal corporate intranet serves as a vital resource for employees, keeping them informed on all strategic,
business, HR and technology-related matters. It is a digital platform that promotes the Group’s actions and initiatives,
providing employees with immediate access to important information. In 2025, the content of the intranet was maintained
and updated, resulting in 8,637 users visiting Connected, and on average dwell time on content 34 second, users spent
several minutes (06:50) per sess ion on the intranet.
Work-Life Balance and Mental Health
To mitigate and remediate negative impacts on its workforce stemming from Group operations, Eurobank has planned and
implemented the following actions:
●
Eurobank provides Mental Health Employee Assistance Helpline for all its employees, from Monday to Sunday, including
holidays, from 15:00 to 23:00. The Helpline operates completely confidentially and without any financial burden. The
dedicated advisers from HELLAS EAP guide and support Eurobank’s employees on a variety of relevant topics, such as stress
management at work, emotional resilience, family tensions or addiction issues.
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●
Additional leave on top of the statutory one, such as childbirth leave (pregnancy and post-partum) and maternity leave, with
the option of reduced working hours or accrued leave.
●
Leave for a child’s educational-related school activities.
●
Paid parental leave, minimum 2 weeks more than the legal requirements, unpaid parental leave, paid leave for single-parent
families, paid leave to adopt a child, paid parental leave for parents with disabled children, paid family/care leave for medical
reasons.
●
1 working hour less per day to employees with certified disability equal to or more than 50%.
●
Measures to help employees keep their schedule within their working hours and promote their work-life balance, i.e. by
sending out emails as reminders to clock out on time, in compliance with regulatory requirements.
●
Hybrid Work Model up to 3 days from home: 81% of middle or back-office employees have opted for Hybrid Work Model
via contractual agreement in accordance with Eurobank's Hybrid Work Policy.
●
The opportunity to the majority of employees to choose their working hours from a range of options, typically within a 2-
hour span, in order to better accommodate their needs.
●
Eurobank tracks and encourages full use of annual leave entitlements.
Learning Initiatives Regarding Violence and Harassment in the Workplace
Eurobank continually strives to promote a safe and respectful work environment. Therefore, a digital learning programme was
implemented during 2023 for all Group employees in Greece, aiming to equip people with the necessary knowledge and skills to
identify, prevent and properly respond to instances of violence and harassment. In addition, separate virtual workshops were
addressed to team managers, to provide them with practical knowledge to prevent such behaviours, while amplifying the effort
towards nurturing an environment of mutual respect and dignity, where no one tolerates harassment in any form. Since then,
Eurobank constantly continues to offer the digital learning programme as mandatory for all new hires and the virtual workshop for
all the newly-appointed team managers .
Diversity, Equity and Inclusion
Discriminations based on nationality, gender, parental status, colour, religion, health, sexual orientation, etc. are not in tune with the
Group’s principles and values. The Group has adopted a zero-tolerance approach, which applies to all staff and prohibits all forms of
discrimination, whether direct or indirect. It is also reflected in contractual documents adopted when entering into relationships with
third parties. To this end, it has introduced a Diversity, Equity and Inclusion Policy and Workplace Violence and Harassment Policy.
Employee Engagement and Feedback
As analyzed further in section “Processes for engaging with own workforce and workers’ representatives about impacts [S1-2]”,
Eurobank has implemented the initiative “WeSay 2025 survey” in order to monitor employee satisfaction and provide opportunities
for feedback that will help identify negative impacts, enabling proactive intervention.
Eurobank conducts the WeSay Employee Engagement survey every 18 months, inviting all employees in Greece and Cyprus to share
views on engagement, satisfaction and wellbeing. The WeSay 2025 survey, completed in Q1, recorded an 82% participation rate.
Findings have led to actions that are currently being implemented in areas such as compensation and benefits, learning, process
optimisation, culture alignment and team collaboration, and wellbeing initiatives.
Additional Actions to Address and Mitigate Material Risks
To address and mitigate material risks stemming from impacts and dependencies on the workforce, the following actions have been
initiated:
●
Comprehensive training programmes have been implemented to enhance skill development and reduce skill gaps.
●
Professional growth opportunities have been launched to foster career progression and retain top talent.
●
Well-being initiatives have been rolled, including mental health support, flexible working arrangements, and wellness
programmes.
●
An inclusive workplace has been created by establishing diversity and inclusion policies and promoting a culture of respect
and belonging.
●
In addition, Eurobank ensures its practices do not harm employees by enforcing GDPR compliance—personal data is
processed lawfully, used only for legitimate HR purposes, and access is restricted to authorized staff. For more information
please refer to: Data security and customer privacy.
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Subsidiaries’ Own Workforce & Equal Treatment actions
In addition to Group-level policies, Eurobank’s subsidiaries in Bulgaria, Cyprus, and Luxembourg implement targeted actions to ensure
fair working conditions, equal opportunities, and a respectful, inclusive workplace. The following sub-sections summarize each
subsidiary’s key measures and achievements in these areas.
Bulgaria (Postbank)
Postbank has established a comprehensive framework to support its workforce and promote equal treatment. The bank enforces a
strict zero-tolerance policy against discrimination, harassment, and human rights violations, embedding Diversity, Equity & Inclusion
(DE&I) and Workplace Violence and Harassment Policies into its governance and daily operations. In 2025, women represented 78%
of the total headcount, and there were zero incidents of discrimination or harassment reported. Postbank supports women’s
advancement through mentoring programmes for female leadership and initiatives for mothers returning from maternity leave. The
bank also provides leadership development, targeted induction training, and access to international learning opportunities. In 2025,
Postbank officially inaugurated its internal Postbank University. It includes the brand-new Future Skills Academy, which is a
comprehensive human development programme aimed at building the skills needed to thrive in an increasingly technological world
where people have a key role to play. The bank launched Digital Pulse - a joint initiative of the Digital Transformation Area and Human
Resources aimed at enhancing the digital culture in the bank and building knowledge and skills in artificial intelligence, data
management and digital tools for more efficient work, innovation and process optimization. As part of its commitment to continuous
improvement of the work environment and organizational culture, in November and December 2025, the bank carried out a full-
scope employee engagement survey. The survey gave employees the opportunity to freely express their views on various topics
related to their experience in the Bank, achieving 82% participation rate. The preliminary results indicate 70% employee engagement.
Postbank’s commitment to employee wellbeing, professional and career development, and equal treatment was recognized with the
Top Employer award for the third consecutive year and multiple distinctions for best employer, diversity and inclusion.
Cyprus (Eurobank Limited and insurance subsidiaries)
Eurobank Limited has advanced its workforce and equal treatment agenda by embedding diversity and inclusion into their core
policies and practices. Eurobank Limited maintains , amongst others, a Code of Conduct and Ethics, a Policy for Reporting Illegal or
Unethical Conduct or Violations of European Union and National Law (Whistleblowing), a Personal Grievance Committee, and a Code
for Dealing with Violence and Harassment in the Workplace to ensure a safe and respectful work environment. Diversity principles
and gender equality provisions are incorporated into succession planning, recruitment, and remuneration. Ex Hellenic Bank
employees are empowered to donate unused leave days to colleagues facing hardships. Ex Eurobank Cyprus Women’s Empowerment
Committee organized special networking initiatives. In 2025, women made up 67% of Eurobank Limited employees. Eurobank Limited
achieved a 100% completion rate for employee performance evaluations and regularly monitor gender pay equity, with targets set
for gender diversity at senior level.
Ex-CNP Group provides various benefits to support employees’ well-being and promote a respective and inclusive workplace. For
example, maternity and paternity leave is extended beyond labour law provisions, whistleblowing policy and tools help prevent and
respond to incidents of harassment and discrimination at the workplace, while benefits such as attractive provident fund and
discounts for insurance policies of employees’ family members support their financial wellbeing. In 2025, women made up 70% of ex-
CNP Group workforce with 38% of women in managerial roles.
Luxembourg (Eurobank Private Bank Luxembourg)
Eurobank Private Bank Luxembourg upholds high standards for workforce management and equal treatment. The bank is committed
to gender equity, family support, age diversity, disability inclusion, and LGBTQ+ inclusion. A zero-tolerance policy for discrimination,
mobbing, bullying, harassment, or victimization is strictly enforced, and there were zero fines or penalties regarding discrimination
or harassment in 2025. Employees are supported in pursuing academic and professional development, and the bank provides
teleworking, health and life insurance, and ethics training.
3.1.2
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
[S1-5]
Eurobank has set measurable time-bound outcome-oriented targets to advance its commitments towards its employees to fostering
a diverse and inclusive internal environment by 2030 and cultivating a culture of wellbeing by 2026.
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Key Workforce-Related Targets
The main related targets:
●
Improve gender diversity for Top and Senior Management
●
Monitor, disclose and improve Gender Pay Equity Gap
●
Increase participation in mental health training courses
●
Investigate, specify and quantify the significant aspects for employees’ wellbeing
●
Measure wellbeing score through people engagement survey
Alignment with DEI Policy and Material Topics
These targets support and align with the core principles of the Diversity, Equity and Inclusion (DE&I) policy, emphasising diversity,
equity, inclusion and well-being across the organisation. The focus on maintaining gender balance in the workforce aligns with the
DE&I policy’s goal of advancing gender equity. The commitment to inclusive management as part of Manage Forward and other
Leadership Development programmes and initiatives that focus on leadership training for all Eurobank managers, supports the
development of an inclusive working environment. Eurobank’s Generations Diversity strategy further reflects the company's
commitment to fostering an equitable and inclusive environment that recognises the value of diverse perspectives across all age
groups. Monitoring and improving the Gender Pay Equity Gap ties directly to the DE&I policy's equity objectives, ensuring that
compensation is fair and transparent. Additionally, the targets focused on workforce well-being, including achieving an increase in
the wellbeing score and increase the participation of employees in mental health training, underscore the organisation's dedication
to the holistic well-being of its employees.
Progress and Achievements in 2025
Indicative achievements against targets for 2025 are as follows:
●
Training on unconscious bias for managers as part of a four-hour virtual training programme on workplace violence and
harassment.
●
Generation Diversity Strategy principles and conclusions have been integrated into the Bank’s Renewal Strategy.
●
Continuation of the “myProsperity” initiative (including inspirational talks by external experts), as part of the Group’s
Wellbeing Framework.
●
Implementation of the Culture Shift initiative, promoting new ways of collaboration in the workplace, new Manager’s
Competencies and a new Leadership Capability Framework.
●
Training programmes in place to promote diversity and inclusion, as well as anti-harassment principles, addressed to all
employees.
●
Completion of wellbeing initiatives to promote mental health.
●
Launch of 2025 People Engagement Survey, including a wellbeing and life-work-balance section.
●
A Group-wide project has been initiated to monitor and improve the gender pay gap, with the aim of strengthening
transparency and supporting equal pay practices across the Group.
Governance, Monitoring, and Continuous Improvement
The Sustainability Strategy defines the Group’s sustainability priorities and objectives. The Operational Impact Strategy is deployed
through milestones and KPIs that support the annual and the long-term interim targets set across multiple project streams, spanning
over the next decade. It is developed and deployed along 3 pillars and corresponding corporate objectives, supported by a governance
structure of project streams (one per each commitment) and the supervisory ESG/OIS Committee. Progress is regularly reviewed at
the Sustainability Management Committee. Links are established with Transformation streams as well as corresponding ISO
management system standards, to ensure substantiation and certification of activities, validate target setting and measured
performance, and systematically monitor progress through internal reviews and external assurance. The Group plans to revisit and
update its Sustainability Strategy on a regular basis, in line with best market practices and regulatory requirements. The targets’
progress will be monitored throughout the year to ensure that they are met with a final evaluation at the end of the period they are
set.
Equal Treatment and Opportunities for All, and Own Workforce and Working Conditions, have been identified as material topics
during the stakeholder engagement process. The commitment to fostering a diverse and inclusive internal environment, alongside
cultivating a culture of wellbeing are informed by the impacts, risks and opportunities that are directly linked to these topics.
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Characteristics of employees [S1-6]
In 2025, the Group’s total number of employees amounted to 12,773, remaining broadly stable compared to 12,833 employees in
2024. Permanent employees continued to represent the vast majority of the workforce, reaching 12,631 employees (2024: 12,785).
Female employees accounted for approximately 65% of total headcount, maintaining the Group’s consistent gender representation
across the organisation.
Total in Headcount
Employees as of 31.12.2025
Employees as of 31.12.2024
Male
Female
Total
Male
Female
Total
Total number of permanent employees
4,401
8,230
12,631
4,396
8,389
12,785
Total number of temporary employees
34
108
142
14
34
48
Total of non-guaranteed hours employees
0
0
0
0
0
0
Total number of employees (sum)
4,435
8,338
12,773
4,410
8,423
12,833
The following tables present the distribution of employees across the Group’s countries of operation — Greece, Bulgaria, Cyprus and
Luxembourg. In 2025, Greece represented around 47% of the Group’s headcount, with a stable gender mix. Bulgaria accounted for
approximately 29%, Cyprus for 23%, and Luxembourg for around 1% of total employees. Changes across countries largely reflect
normal workforce movements and temporary employment fluctuations, particularly in Bulgaria and Cyprus, where a small increase
in temporary employees was recorded to support operational needs.
Overall, the Group’s workforce composition remained consistent with the previous year, reflecting a stable organisational structure
aligned with the Group’s operational requirements and strategic priorities.
Greece
Employees as of 31.12.2025
Employees as of 31.12.2024
Male
Female
Total
Male
Female
Total
Total number of permanent employees
2,548
3,494
6,042
2,559
3,499
6,058
Total number of temporary employees
0
0
0
0
0
0
Total of non-guaranteed hours employees
0
0
0
0
0
0
Total number of employees (sum)
2,548
3,494
6,042
2,559
3,499
6,058
Bulgaria
Employees as of 31.12.2025
Employees as of 31.12.2024
Male
Female
Total
Male
Female
Total
Total number of permanent employees
786
2,800
3,586
784
3,075
3,859
Total number of temporary employees
13
79
92
0
0
0
Total of non-guaranteed hours employees
0
0
0
0
0
0
Total number of employees (sum)
799
2,879
3,678
784
3,075
3,859
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Cyprus
Employees as of 31.12.2025
Employees as of 31.12.2024
Male
Female
Total
Male
Female
Total
Total number of permanent employees
986
1,875
2,861
973
1,753
2,726
Total number of temporary employees
17
27
44
11
31
42
Total of non-guaranteed hours employees
0
0
0
0
0
0
Total number of employees (sum)
1,003
1,902
2,905
984
1,784
2,768
Luxembourg
Employees as of 31.12.2025
Employees as of 31.12.2024
Male
Female
Total
Male
Female
Total
Total number of permanent employees
81
61
142
72
52
124
Total number of temporary employees
4
2
6
3
3
6
Total of non-guaranteed hours employees
0
0
0
0
0
0
Total number of employees (sum)
85
63
148
75
55
130
A total of 1,406 employees left the Group during the reporting period, resulting in an overall employee turnover rate of 11.0%,
compared to 10.2% in 2024. The tables below present the turnover distribution and ratio for 2025, illustrating that turnover increased
slightly year-on-year, driven by normal workforce mobility across the Group’s geographies. The voluntary turnover rate from VES
programmes was 3.1%.
Group
Employees as of 31.12.2025
Employees as of 31.12.2024
Unit
Male
Female
Total
Male
Female
Total
Total number of employees
who have left during the
reporting period
Headcount
473
933
1,406
451
854
1,305
Total number of employees
Headcount
4,435
8,338
12,773
4,410
8,423
12,833
Rate of employee turnover
%
10.7
11.2
11.0
10.2
10.1
10.2
As in the previous year, all employee-related data have been reported in headcount, ensuring consistency and comparability across
the Group. Information is collected from all subsidiaries and consolidated by Group Human Resources, enabling a comprehensive and
unified overview of workforce developments for the 2025 reporting period.
Collective bargaining coverage and social dialogue [S1-8]
Eurobank follows a policy of direct communication with its employees as well as through labour unions. The union with the largest
membership is officially recognised as the representative body for employees in labour negotiations with management. Over 92% of
Group’s employees are covered by collective bargaining agreements at the enterprise, sectoral, and national levels. Management
actively collaborates with the unions, supporting scheduled meetings and fostering open dialogue to monitor developments within
the work environment.
Collective bargaining agreements address various issues such as health and safety, remuneration, working hours/ work time flexibility,
training, career development, equal opportunities, absenteeism/leave/illness, and insurance issues. In line with Eurobank’s internal
policies, employees' participation in trade union activities is a constitutional right, exercised within the framework of existing laws.
Legal trade union activity does not affect employees’ employment status and development in any way, either positively or negatively.
Employees can monitor and get informed about their trade union rights, as well as the activities of associations, through various
communication channels of their Union and the Greek Federation of Eurobank Employee Unions – OTOE e.g. websites, emails, notices,
labour rights guides, codification of collective agreements).
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Collective bargaining coverage
Group
Unit
2025
2024
Number of employees covered by collective bargaining agreements
Headcount
11,854
12,114
Total Number of employees
Headcount
12,773
12,833
Total Employees covered by collective bargaining agreements ratio
%
92.8
94.4
Six labour unions are active at Eurobank Greece. They represent 79,08% of the Bank’s Headcount. The standard working hours for
bank employees, as defined by the Sectoral Collective Labor Agreement, are 37 hours per week. Employees who work beyond this
limit are compensated for overtime in accordance with applicable legislation. Based on the Bank’s internal organisation, the trade
union activity of the employees is their constitutional right and is exercised within the context of the existing legislation. Any
involvement of the Bank in said trade union activity is not permissible, unless, and to the extent, permitted by current legislation.
Eurobank is one of the four banks that represent sector workforce majority, participating in the banking industry collective bargaining
agreements with the Greek Federation of Bank Employee Unions – OTOE.
In addition, regarding the Group’s operations in Cyprus, the Employers’ Association of Cyprus Banks which covers all the banks
members of the Association of Cyprus Banks who have a Collective Agreement with the same Trade Union, is responsible for industrial
relation issues and/or discussions for the renewal of the Collective Agreement. Specifically, ex Hellenic Bank engages with Trade
Unions representing its staff members as part of its ongoing stakeholder engagement activities and negotiates for the settlement of
disputes arising from collective agreement negotiations.
Social dialogue
Group
Unit
2025
2024
Number of employees working in establishments with workers' representatives
Headcount
7,166
6,971
Total Number of employees
Headcount
12,773
12,833
Total Employees working in establishments with workers' representatives ratio
%
56.10
54.32
In 2025, the share of employees working in establishments with workers’ representatives increased by 1.8% (from 54.3% to 56.1%),
reflecting a broader reach of formal employee representation across the Group.
Coverage rate
2025
Collective Bargaining Agreement for Employees –
European Economic Area (EEA)
(for countries with >50 employees representing
>10% of total employees)
Social dialogue – Workplace representation (EEA only)
(for countries with >50 employees representing >10%
of total employees)
0–19%
Bulgaria (0%)
20–39%
40–59%
Luxembourg (54.05%)
60–79%
Greece (78.67%)
Cyprus (78.49%)
80–100%
Cyprus (81.48%)
Greece (94.82%)
Bulgaria (100%)
Luxembourg (89.86%)
Diversity Metrics [S1 -9]
The Group is committed to fostering equal opportunities for all employees, ensuring fair access to senior management roles, equitable
salary structures, and merit-based evaluations and rewards. Eurobank prioritises performance and potential when making decisions
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related to professional development, promotions, and career advancement. This involvement underscores the company’s focus on
integrating Diversity, Equity, and Inclusion (DEI) principles, as well as broader sustainability values, throughout its operations.
In 2025, the Bank launched several initiatives promoting diversity and inclusion, benefiting employees and the broader ecosystem.
Women In Banking (WiB) – As part of its commitment to diversity and inclusion, in 2024, Eurobank launched the 3rd Season of its WiB
programme, building on the success of the previous seasons. The programme empowers women to advance to leadership roles, drive
change and promote an inclusive work environment. It combines mentoring, learning and interactive activities to support talent
development. This programme aimed at empowering women within Eurobank to advance to higher leadership roles through
mentoring, interactive workshops, virtual masterclasses, gaming and various engaging activities. The 3
rd
with 70 new mentees building up to a community of 188 women. The 4
th
Eurobank supports every phase of the family life cycle, providing a broad range of benefits and initiatives to empower its employees
and all modern forms of families. It supports parents, irrespective of gender, age or marital status, and is proud of the exceptional
range of benefits that its staff enjoy, providing an excellent framework, within which each staff member may pursue growth,
irrespective of their personal or family situation.
The following table presents the gender distribution in number and percentage at top management level. Top management level
contains the grade levels of Executives and Senior Management within the Group:
Employees in top management ratio
Group
Unit
2025
2024
Male
Female
Male
Female
Number of employees at top management level by gender
Headcount
298
148
306
149
Percentage of employees at top management level by gender
%
66.8
33.2
67.3
32.7
Distribution of employees by age group: under 30 years old, 30-50 years old, over 50 years old:
Total number of employees by age
Group
Unit
2025
2024
under 30
years old
30-50
years old
over 50
years old
under 30
years old
30-50
years old
over 50
years old
Number of employees during the
reporting period
Headcount
960
8,012
3,801
1,030
8,648
3,155
Percentage of employees per age
group
%
7.5
62.7
29.8
8,0
67.4
24.6
Adequate Wages [S1-10]
All of the Group’s employees receive adequate wages in compliance with the statutory labour laws and salary practices in place,
applicable standard collective and workplace agreements, as applicable to each country of operation.
Training and skills development metrics [S1-13]
Performance Management
In 2025, Eurobank continued to implement Group Performance Management, designed to establish a transparent, consistent and
effective framework for enhancing employee performance, and aligning with Eurobank’s strategic objectives and values. This
framework translates the Group’s strategy into practice by setting clear and measurable business objectives (“what”) for employees
and promoting a cohesive organisational culture, by focusing on the development of the Group’s organisational capabilities and
qualitative competencies (“how”) across all levels. Performance Management is integrated into SAP Success Factors for enhanced
accessibility. Performance Management in Eurobank prioritises development and emphasise continuous feedback, while for
Executive Board members and Key Function Holders, the 360 Feedback methodology is applied.
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The percentage of number of employees that participated in performance reviews during 2025 regarding performance year 2024
was 90% for the male employees and 95% for female employees. In the following table the percentage of employees that participated
in regular performance and career development reviews is presented, broken down by gender.
2025 (Performance year 2024)
Group
Unit
Male
Female
Total
Total number of performance reviews executed
Number
3,980
7,922
11,902
Total number of performance reviews agreed by the management
Number
3,980
7,922
11,902
Total number of employees that participated in regular performance and career
development reviews
Headcount
3,980
7,922
11,902
Total number of eligible employees who have been assessed for the reporting year
Headcount
4,011
7,971
11,982
Total Number of employees
Headcount
4,443
8,346
12,789
2024 (Performance year 2023)
Group
Unit
Male
Female
Total
Total number of performance reviews executed
Number
4,080
8,089
12,169
Total number of performance reviews agreed by the management
Number
4,081
8,092
12,173
Total number of employees that participated in regular performance and career
development reviews
Headcount
4,080
8,089
12,169
Total number of eligible employees who have been assessed for the reporting year
Headcount
4,095
8,120
12,215
Total Number of employees
Headcount
4,410
8,423
12,833
Learning
Eurobank prioritises learning and development as a fundamental aspect of its operations and overall strategy. Providing equal learning
opportunities for all employees—regardless of role, contract type (permanent, temporary, external associates, managers or
employees)—is essential for enabling skill development and driving sustainable business outcomes. This inclusive approach ensures
that every team member has the resources to grow and contribute to the organisation’s long-term success. In 2025, Eurobank has
consistently upheld its commitment to developing diverse talent, fostering a culture of ongoing learning, and equipping its workforce
with the critical skills needed to drive the organisation's vision for Eurobank 2030.
Learning in numbers (2025):
●
529,852 learning hours Group-wide, including activities delivered to temporary employees and contractors
●
32 average number of learning hours per male employee
●
41 average number of learning hours per female employee
●
38 average number of learning hours regarding the Group’s employees
●
4.7 Learning days on average per employee Group-wide
24
The learning days metric for 2025 refers to all the countries Eurobank operates in and is calculated as the equivalent of 8 learning hours per day.
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Average number of learning hours per employee and by gender is presented below.
Training hours per employee and by gender as of year-end
Group
Unit
2025
2024
Male
Female
Total
Male
Female
Total
Training hours offered to and
completed by employees
Hours
141,983
338,726
480,709
209,168
379,301
588,469
Total Number of employees
Headcount
4,435
8,338
12,773
4,410
8,423
12,833
Average number of training hours
Training hours
32
41
38
47
45
46
Equal Learning Opportunities and Digital Platforms
Eurobank centers on equal learning opportunities for all employees, fostering continuous development through tailored workshops
and digital platforms, including Udemy, Microsoft LxP, and Intuition. Partnerships with distinguished digital learning platforms offer
thousands of courses on cutting-edge technologies and in-demand business skills. SAP SuccessFactors, the Human Experience
Management (HXM) cloud platform, enables the workforce in Greece and Cyprus to access a diverse range of learning content at any
time, across all smart devices. In 2025, 76.7% of total learning activity in Eurobank-Greece was delivered online or through virtual live
sessions.
Annual Learning Initiatives and Consumer Protection
The Bank implements a series of learning initiatives annually, such as MiFID, Know-Your-Customer (KYC), Mortgage Credit Directive
(MCD), fair lending and ethical sales practices, recognition of financial fraud and scams targeting consumers for all customer-facing
employees, aimed at strengthening consumer protection and ensuring the delivery of responsible and compliant customer service.
In addition, during 2025 a dedicated digital learning course was introduced to further strengthen knowledge and awareness on
consumer protection, specifically tailored for selected front-line and support roles across relevant Units.
Inclusion, Accessibility, and Investment in Learning
Moreover, Eurobank continued the delivery of a dedicated workshop, jointly hosted with the Me Alla Matia NPO, providing people
with the opportunity to familiarise themselves with best practices when accompanying a visually/hearing-impaired client or serving
an autistic customer, and to elevate the quality of service to these clients, thereby fostering inclusion and accessibility. Additionally,
a digital guide was designed to help employees in selected Units become familiar with, and appropriately apply information and
recommendations in order to serve people with disabilities equitably. The guide provides guidance tailored to different types of
disabilities and service channels—whether it involves an in-branch visit, a phone call, a video interaction, or the use of our digital
services. In 2025, Eurobank invested more than €3.2 million in learning initiatives, ensuring employee upskilling, building leadership
capabilities and strengthening expertise through an extensive range of certifications and professional qualifications.
Health and safety metrics [S1-14]
The Group adheres to all national and EU regulations to safeguard the health and safety of its employees, customers, and partners.
Additionally, Eurobank has implemented a Health and Safety Management System in accordance with the ISO 45001:2018 standard
for Occupational Health and Safety. As part of this, Eurobank runs a comprehensive prevention and safety programme, featuring a
range of initiatives designed to protect its workforce. The scope of Eurobank’s Occupational Health and Safety System encompasses
all employees and operations across the Bank.
Eurobank follows national and EU health and safety regulations, implementing an ISO 45001:2018 certified Health and Safety
Management System. It runs a comprehensive prevention and safety programme to protect all employees and operations. All network
branches, 8 central buildings and the Nea Ionia Complex are certified under ISO 45001:2018. Certification currently covers 5,380
employees (89%), with a goal to extend to all Bank sites. 100% of Group’s employees are covered by the Health and Safety
Management System.
Health and safety templates present the following information:
●
the percentage of people in the Group’s workforce who are covered by the health and safety management system based on
legal requirements and/or recognised standards or guidelines
●
the number and rate of recordable work-related accidents
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●
the number of fatalities as a result of work-related injuries and work-related ill health of the Group’s employees (and other
workers working on the sites)
o
Own workforce covered by the health and safety management system ratio
Group
Unit
as of year-end
2025
as of year-end
2024
Number of employees in own workforce who are covered by the health
and safety management system
Headcount
12,773
12,833
Total number of employees in the own workforce
Headcount
12,773
12,833
Percentage of employees covered by health and safety management
system
%
100
100
Work-related injuries and work-related ill health for 2024 and 2025
Group
Unit
Own workforce -
Employees
Other workers working on
undertaking's site
Number of fatalities as a result of work-related injuries
and work-related ill health
Number
0
0
Recordable work-related accidents ratio
Group
Unit
as of year-end
2025
as of year-end
2024
Number of recordable work-related accidents
Number
10
21
Number of total hours worked
Hours
24,411,660
23,143,850
Rate of recordable work-related accidents
Rate
0.41
0.91
All of the Group’s employees are covered by the undertaking’s health and safety management system. Regarding the number of
fatalities as a result of work-related injuries and work-related ill health, the number of cases was 0 for both the own workforce of the
Group and the other workers working on its sites.
In 2024, the Group recorded 21 recordable work-related accidents, corresponding to a recordable accident rate of 0.91, based on
23,143,850 total hours worked. In 2025, the number of recordable work-related accidents decreased significantly to 10 cases, while
total hours worked increased to 24,411,660 hours, resulting in a recordable accident rate of 0.41. This represents a substantial
improvement in health and safety performance year-on-year.
Occupational Risk Assessment Studies are conducted for all buildings. The latest updates are carried out by a specialist company. The
studies are regularly updated and revised after renovations, refurbishments or changes to premises. Safety Coordinators and Deputy
Safety Coordinators are assigned at all premises. They are responsible for reporting work-related risks and submitting regular written
reports. Safety Engineers conduct risk assessments, investigate work incidents and propose corrective actions. Employees are entitled
to report any health or safety risk to the Health and Safety Unit, Onsite Safety Engineer, or Workplace Physician. Any work-related
incident is reported immediately through an incident report. Safety Engineers prepare follow-up reports with corrective actions, if
needed. Health and Safety processes are audited by internal inspections as part of the Bank’s OHS system, government bodies (e.g.
SEPE), Safety Engineers and Workplace Physicians. In response to recommendations, the Bank takes corrective action and implements
updated system processes, where required.
Remuneration metrics (pay gap and total remuneration) [S1-16]
The gender pay gap is defined as the difference between the average pay levels of female and male employees, expressed as a
percentage of the average pay level of male employees. In line with ESRS requirements, the Group reports both mean (average) and
median gender pay gaps on a raw, unadjusted basis, without accounting for role, level, function, or responsibility.
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Remuneration metrics
Group
Mean/ Average
GPG
Median GPG
2025
33.8%
23.4%
2024
36.0%
24.0%
In 2025, the mean gender pay gap decreased to 33.8%, and the median gap recorded a slight decrease to 23.4%.
The Annual Total Remuneration Ratio is defined as the ratio between the total annual remuneration of the highest-paid employee
(i.e. Group CEO) and the median remuneration of all employees of the Group.
Annual Total Remuneration Ratio
Year
Ratio
2025
x60.3
2024
x60.0
It should be noted that the annual total remuneration ratio increased marginally from 60 to 60.3 in 2025.
The Group’s remuneration principles and governance framework (detailed in Section 1.3.3 Integration of sustainability -related
performance in incentive schemes [GOV-3]) along with continuous monitoring of market trends and remuneration best practices at
both local and international markets, provide the foundation for internal fairness.
The consolidated gender pay gap is primarily influenced by the structural composition of the workforce and the Group’s international
operating model, which varies across entities in size, functional scope, capability mix and applicable pay market dynamics.
Consequently, local environments and market benchmarks contribute to the Group’s gender pay gap, reflecting variations inherent
to the structure of a multi-country organisation.
In addition, gender representation patterns also vary significantly by country, with men and women unevenly distributed across
organisational levels, particularly at senior leadership positions and lower-grade roles, which further shapes consolidated pay gap
outcomes. Taking into account that the CSRD metric is an unadjusted measure, the gender pay gap is calculated without factoring in
any parameters, such as role, level etc. that relate to equal work. The results primarily reflect workforce structural imbalance in
gender representation and should not be considered as evidence of pay unfairness.
In addition, the divergence observed between the mean/average and median metric is driven by a relatively small number of high-
remuneration outliers, primarily male incumbents in senior Group roles. This skews mean/average pay figures while the median is
less affected and depicts a more balanced pay structure.
Considering the above, the findings suggest that the primary driver of the gender pay gap within the Group is workforce composition
and gender representation across entities and organisational levels, as opposed to unequal pay practices or differences in
remuneration policy. The data points to a structural seniority pipeline and progression challenges, rather than pay equity issues per
se. The Group has already identified the importance of reinforcing the continuous focus on female talent development and more
balanced gender representation in senior management level.
As a next step in its commitment to strengthening pay equity, the Bank has initiated a comprehensive assessment process to monitor
the gender pay equitability and broader pay fairness across its operations in Greece and its international subsidiaries. Using equal
work analysis alongside CSRD reporting will provide a more accurate and actionable understanding of pay equity practices across the
Group. The assessment following EU Pay Transparency Directive's approach will allow to isolate genuine pay differences and take
appropriate actions. These insights will lead to a fairer interpretation of CSRD analysis, while supporting targeted evidence-based
interventions rather than broad or misdirected adjustments.
Gender Pay Gap by Pay Quartile (2024–2025)
2024 Results
Quartile
Average GPG
Median GPG
1st Quartile
6.0%
12.0%
2nd Quartile
0.0%
0.0%
3rd Quartile
2.0%
2.0%
4th Quartile
22.0%
8.0%
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2025 Results
Quartile
Average GPG
Median GPG
1st Quartile
7.6%
9.4%
2nd Quartile
0.2%
0.6%
3rd Quartile
1.6%
2.9%
4th Quartile
22.1%
8.5%
The comparative results indicate that the Group’s gender pay gap continues to be primarily structural in nature, rather than the result
of unequal pay for equal work.
Alongside the ESRS required gender pay gap metrics calculated on total remuneration, the Group has prepared a supplementary
analysis based solely on fixed annual compensation (base salary) which provides an additional perspective on pay outcomes that
excludes remuneration elements that are not uniformly applicable across all employees and may vary depending on eligibility or
performance.
When focusing on base salary, the gender pay gap narrows: In 2025, the base salary gender pay gap amounted to 27.6%
(average/mean) and 21.5% (median), compared with 33.8% (average/mean) and 23.4% (median) when calculated on total
remuneration.
This supplementary view provides insights on deviation in base pay component that is related to steady factors like level and type of
role without the distortion of variable component that may be related to specific yearly outcomes.
The 2025 results indicate that gender representation in senior roles is the primary factor influencing gender pay gap outcomes. The
metrics of the two reporting periods demonstrate that progress in reducing the gender pay gap is dependent on long-term changes
in leadership representation rather than short-term remuneration adjustments.
The Group remains committed to strengthening talent pipelines and promoting leadership diversity by embedding gender balance
into workforce planning, particularly in senior and high-impact roles, supported by regular pay equity reviews. Eurobank fosters a
culture of meritocracy rooted in Diversity, Equity and Inclusion (DE&I), ensuring these principles are integrated into daily practices,
governance frameworks and organizational commitments, while providing equal opportunities, inclusive working arrangements, and
development pathways to empower women to advance into senior management. In this context, the Group Gender Diversity
Guideline for Top and Senior Management as approved by the Board on January 2026, establishes clear scope, direction, processes
and accountability mechanisms to enhance female representation and ensure a sustainable, gender-inclusive leadership pipeline,
reflecting the Bank’s belief that diverse leadership strengthens performance, innovation and trust.
Furthermore, the Group, as part of its commitment to diversity and inclusion, completed the 3
rd
in 2025, following the highly successful and award-winning previous two seasons. WiB is a programme aimed at empowering women
in Eurobank to advance to higher leadership roles, drive transformative change within the organisation, and advocate for an inclusive
and equitable work environment. WiB not only serves as a cornerstone for women’s empowerment but also plays a pivotal role
in
championing diversity and inclusion, cultivating a workplace founded on acceptance and mutual respect. With a forward-looking
approach and unwavering dedication, the WiB community is spearheading endeavors to empower women and foster a more inclusive
leadership landscape.
The abovementioned initiative is related to the employees of the Greek entities. There are more initiatives implemented on a local
level, based on the specific characteristics and needs of each entity.
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Incidents, complaints and severe human right [S1-17]
Eurobank complies with frameworks such as UN Guiding Principles on Business and Human Rights and UN Global Compact.
Information regarding the incidents, and complaints that occurred during the 2025 reporting year are illustrated below:
Incidents, complaints and severe human rights impacts
Group
Unit
as of year-end
2025
as of year-end
2024
Total number of incidents of discrimination, including harassment, reported
in the reporting period
Number
5
10
Number of complaints filed through channels for people in the organisation's
own workforce to raise concerns (including grievance mechanisms)
Number
6
17
Total amount of fines, penalties, and compensation for damages as a result
of the incidents and complaints disclosed
Monetary
Terms
0
0
Number of severe human rights incidents
Number
0
0
An indication of how many of severe human rights incidents are cases 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.
Number
0
0
Total amount of fines, penalties, and compensation for damages as a result
of the incidents disclosed
Monetary
Terms
0
0
Regarding the number of complaints filled through official channels, most of the cases relate to staff complaints received in writing
by HR. Those complaints related to matters such as performance appraisal, training, staff transfer and organisational structure. All
cases were investigated as per the respective policies of the Group. As a result, the Group had no amount in fines and penalties as
result of the incidents and complaints disclosed, as well as zero number of cases related to severe human rights incidents.
Eurobank applies a zero -tolerance approach, which applies to all staff and prohibits all forms of discrimination, whether direct or
indirect. It is also reflected in contractual documents adopted when entering into relationships with third parties. Eurobank ensures
equal opportunities for all employees, fair access to senior management positions, equal salary criteria and merit-based evaluations.
Professional development, promotions and advancement are based on performance and potential. Its commitment to diversity and
inclusion aligns with its values and is reflected in its Code of Conduct. Diversity and inclusion are sponsored at the highest levels within
the Company and initiatives are applicable – but not limited – to its practices and policies on all aspects of employee life cycle.
The Human Resources related grievance reporting process is covered by the Disciplinary Council and the Workplace Violence and
Harassment Policy. Discriminations based on nationality, gender, parental status, colour, religion, health, sexual orientation, etc. are
not in tune with its principles and values.
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3.2
Consumers and end-users [S4]
3.2.1
Strategy
Material impacts, risks and opportunities and their interaction with strategy and business model [ESRS 2 SBM-3]
As identified through the Double Materiality Assessment (DMA), Eurobank has actual impacts and an opportunity on consumers and
end-users primarily related to accessibility and the provision of accurate, transparent information on financial products. These
impacts are connected to Eurobank’s strategy and business model, which integrates sustainability considerations across all
operations.
Eurobank has committed to contributing to the achievement of the United Nations Sustainable Development Goals (SDGs) and the
UN 2030 Agenda, as a signatory to the UN Global Compact since 2008, actively promoting its fundamental principles and applying the
precautionary approach. In this context, key component of Eurobank’s Operational Impact Strategy is the Societal impact that include
boosting accessibility and inclusion for customers by 2025 and the Governance and Business impact that includes promoting external
ESG awareness by 2025. These strategic commitments address material IROs of responsible banking towards customers.
Eurobank considers Social Inclusion a key component of its strategy and business model, structured around three pillars:
●
Financial Inclusion:
follows: promoting equal access to financial services for underserved communities and vulnerable population groups, such
as people living in remote areas, while offering financing products that specifically relate to infrastructure and supported
services, aiming to assist businesses grow and become updated, and boosting their competitiveness. Social impact financing
is a key focus area, relating to activities such as education, upskilling, healthcare,social cohesion, and gender equality.
●
Accessibility:
to all customers and end-users. This includes continuous investment in banking services friendly towards people with
disabilities, as well as training and awareness for all accessible banking issues.
●
Approachability:
through Eurobank’s digital channels. It reflects the availability and coverage of informational, monetary, non-monetary
servicing transactions, and product applications in digital environments, ensuring that customers can independently manage
their financial needs remotely. It is driven by Eurobank’s human-centric culture, responsible marketing and communication,
and the design of products and services tailored to individual customer needs. Approachability is supported by systematic
market research and the use of Customer Re lationship Management tools.
Through responsible marketing and communication driven by its human-centric culture, Eurobank designs products and services
tailored to individual customer needs. To optimize marketing messages, the Group carries out systematic market research on each
customer category, focusing on both quantitative and qualitative features that highlight trends and expectations. Using Customer
Relationship Management tools, it is able to propose or offer individual customers the product or service that truly meets their needs.
The Group recognizes that social risk management is essential for a sustainable business model and has taken actions to adjust its
business model, strategy, and financial planning to address risks arising from social matters. A key strategy to manage these risks is
the promotion of financial inclusion. Eurobank views Social Inclusion as a strategic business opportunity to increase positive impacts
and reduce negative impacts, continuously identifying innovative channels for service delivery and designing value-adding solutions
tailored to customer needs.
Through the materiality assessment, the magnitude and scope of potential and actual impacts are considered and analyzed further.
Identified impacts related to consumers and/or end-users could be linked only to individual incidents of restricted access to
information.
Regarding governance-related information, please refer to Section 1.3 Governance.
As part of the materiality assessment, key impacts on customers have been identified, as presented in the following table:
Information-related Impacts for Consumers and/or End-users
Impact
Positive
Actual
Provides clients access to accurate, relevant, and high-quality secured information,
fostering transparency and promoting responsible banking.
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Social inclusion for Consumers and/or End-users
Impact
Positive
Actual
Provides specific products and services, including microfinance, that promote a
discrimination free environment, equal opportunities, inclusion and diversity.
Opportunity
Contributing to financial inclusion aligns with social impact goals, positively impacting
brand reputation and offering financing to underserved populations, such as students and
geographically isolated communities.
Conducting the materiality assessment, the main types of customers who are or could be negatively affected have been identified.
Some customers may be at greater risk of harm. To gain this insight, the materiality assessment is informed by the Diversity, Equity,
and Inclusion Policy, which identifies as vulnerable groups elderly people and people with disabilities. The elderly are more susceptible
to data exploitation or cybersecurity threats due to digital literacy gaps. For both vulnerable groups digital platforms that do not
adhere to accessibility standards (such as WCAG) could create significant barriers in usage and overall service.
The references to Eurobank’s Sustainability Strategy in this section relate to the Strategy currently in force during the 2025 reporting
period. In parallel, the Group is progressing the update of its Group Sustainability Strategy, which will build on the existing framework
and further strengthen the integration of sustainability across its operations and activities.
3.2.2
Policies, actions and performance
Policies related to consumers and end-users [S4-1]
Eurobank has adopted policies related to its consumers and end-users, to manage material impacts, risks, and opportunities related
to its consumers and end-users, in line with the Minimum Disclosure Requirements (MDR-P) as defined in ESRS 2. The Group ensures
that all policies are developed and implemented with a high level of accountability, approved by the appropriate governance bodies
such as the Board of Directors or specialized committees, and aligned with the Group’s strategic goals and stakeholder interests.
Eurobank prioritises respect for human rights, adheres to the UN Guiding Principles on Business and Human Rights, and as a signatory
to the UN Global Compact since 2008, actively supports the 10 principles related to human rights, labour rights, environmental
protection, and anti-corruption.
The following policies set out Eurobank’s approach to protecting and serving its consumers and end-users. These policies are designed
to ensure transparency, ethical conduct, accessibility, and inclusion, and reflect the Group’s commitment to responsible banking and
respect for human rights:
●
Code of Conduct & Ethics:
Focuses on transparency, client protection, and ethical behaviour. Ensures clients receive clear, accurate, and
comprehensive information about products and services, and provides tailored protection for investment-related
transactions. Requires continuous staff training and certification, and mandates compliance approval for potential conflicts
of interest.
●
Complaints Management Policy:
The Complaints Management Policy fully complies with the provisions of the Bank of Greece (Executive Committee Act
157/2019) and is certified under the ISO 9001 and ISO 10002 standards, reaffirming Eurobank’s commitment to fair,
transparent, and effective complaint handling and resolution processes through standardised procedures and tailored
responses. The Policy aims to enhance customer satisfaction, continuously improve the quality of services provided, and
ensure the equitable and efficient resolution of every complaint.
●
Sustainability Policy Framework:
Outlines Eurobank’s commitment to supporting customers in their transition to a more sustainable future, including
decarbonization goals and investments with positive environmental and social impacts. The framework also addresses
climate change, social needs, and prudent governance.
●
Sustainable Finance Framework:
Defines the financing approaches, activities, and criteria for classifying financings as sustainable. For the social pillar, eligible
activities include employment generation, microfinance, SME financing, and equitable access to assets, services, and
resources for vulnerable groups.
●
Human Rights Commitment:
Eurobank prioritises respect for human rights in line with the UN Guiding Principles on Business and Human Rights and as a
signatory of the UN Global Compact since 2008. The Group avoids causing or contributing to adverse human rights impacts
through its operations and business relationships.
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●
Certifications:
Eurobank has attained ISO 37002 (Whistleblowing Management System), ISO 37001 (Anti-bribery Management System),
and ISO 9001 (Financial Crime Prevention Services Certification) and ISO 37301 (Compliance Managements Systems
Certification, obtained within 2025).
Processes for engaging with consumers and end-users about impacts [S4-2]
Eurobank considers strengthening customer relationships and fostering collaboration as key strategic objectives. Engagement with
consumers and end-users is achieved through a comprehensive approach that combines responsible information, high-quality
customer service, and a broad range of accessible products and services.
The Group maintains a robust network of retail branches and digital channels, including ATMs, APS, e-Banking, the Eurobank Mobile
App, vBanking, and Digital Onboarding. Expert relationship managers are available both in-branch and through digital channels, while
special purpose branches and dedicated Corporate Service Centers address specific client needs. Private Banking clients are served
through a specialized network. Eurobank ensures 24/7 accessibility for retail, private, and corporate customers via EuroPhone Banking
and the EuroPhone International Banking Line for non-resident clients. Collaboration with Hellenic Post (ELTA) further extends
banking access to remote areas. Publicly available information is provided through the Group’s websites, and communication is
enhanced through video calls, click2chat, and automated appointment systems.
The Group also leverages automated customer journeys and online sales processes, enabling clients to access services without
physical presence. Customer engagement is further supported by regular economic reports, market research programmes,
satisfaction and NPS surveys, and customer interviews based on Design Thinking Methodology. Social media, direct digital campaigns,
webinars, newsletters, and the Digital Academy for Business are used to maintain ongoing dialogue and inform clients about relevant
topics.
Eurobank’s approach to inclusivity is reflected in initiatives for people with disabilities, focus group discussions to identify ESG
expectations, and tailored communication for Private and Personal Banking clients. Informative events and reports are also provided
for investment clients.
Responsible marketing and communication:
As part of its engagement strategy, Eurobank ensures marketing practices are responsible and customer-centric. Driven by its human-
centric culture, Eurobank designs products and services tailored to the individual needs of its customers. To optimize marketing
messages, the Bank conducts systematic market research on each customer category, focusing on both quantitative and qualitative
features to understand trends and expectations. Using Customer Relationship Management tools, Eurobank offers products and
services that meet individual customer needs.
Customers receive direct and prompt information on new products and services through customized communication tools. Marketing
campaigns are tailored to specific customer groups, considering their stage (e.g., new customer or one who has filed a complaint) and
following specific procedures for each stage. Communication aims not only to promote products and services but also to reward
customer relationships, optimize customer journeys, and collect feedback.
In 2025, Eurobank conducted over 500 targeted marketing campaigns across all communication channels and organized more than
170 online, physical, or hybrid events to maintain close contact with customers. All campaigns were subject to prior authorization
and compliance checks, ensuring adherence to national and EU legislation and voluntary codes. No incidents of non-compliance with
regulations or voluntary codes concerning product and service information, labeling, or marketing communications were identified,
and no fines or sanctions were imposed on the Bank.
The Bank complies with national and EU legislation and voluntary codes for communication, marketing, and commercials. Control
mechanisms and safeguards ensure compliance with the regulatory framework. For targeted customer communication (via email,
text messages, e-Banking messages, Viber, phone calls, etc.), Eurobank fully complies with the GDPR and other relevant legislation.
To ensure compliant advertising, Eurobank keeps staff of all relevant divisions up to date on fair marketing practices. In May 2025, a
dedicated training workshop took place in cooperation with the Communication Control Council to inform, educate, and advise
representatives from Eurobank’s Marketing and Digital Sales and Presence teams regarding clear and effective advertising while
safeguarding consumers.
Eurobank has developed procedures and mechanisms to promote and provide information about its products and services
transparently and honestly. Each marketing campaign is well-organized, transparent, and subject to prior authorization by competent
Bank units.
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The approach to take action in relation to specific material negative impacts on consumers and/or end-users is characterised by
proactively identifying and addressing risks associated with product design, marketing, and sales, with a focus on monitoring and
mitigating potential negative outcomes.
his includes ensuring that advertising and promotional campaigns are subject to prior
authorization by the Legal Services Unit for all promotional content while especially for the content concerning investment products
and services is additionally subject to approval by Group Compliance.
The above approach aims to prevent misleading or harmful
messaging, as well as taking steps to monitor and mitigate data privacy risks. Eurobank continuously seeks to improve the
transparency and fairness of product design and marketing strategies to safeguard the interests of consumers. Processes to provide
remedy in the event of material negative impacts are available and effective in their implementation and outcomes. These processes
include actively seeking customer feedback through customized communication tools and ensuring that customers receive direct and
prompt information about any new deals or changes to the products and services they choose.
Responsible information:
Complementing responsible marketing, Eurobank prioritizes honest and transparent communication through its Responsible
Information framework. The Bank provides customized information to each customer, ensuring clarity about its products and services.
To achieve this, Eurobank:
●
Has established customer support departments and both traditional and online service networks.
●
Has created simple procedures and brochures to inform customers about its products and services.
●
Adheres to the regulatory framework and the Banking Code of Conduct, with control mechanisms to ensure compliance.
Customers can refer to the General Terms of Banking Transactions and Terms of Payment Services before engaging in transactions.
Detailed information about personal data processing, bank charges, and deposit protection is available through various channels,
including branches, the corporate website, e-Banking, and v-Banking.
Before taking out a loan, customers receive a pre-contractual information sheet and personalized details about the loan adapted to
the needs and financial capabilities of each client. After signing a loan agreement, they are kept updated through regular statements.
Similar information is provided for investment products by qualified Bank officers.
Eurobank has policies and procedures in place for the oversight and governance of products/services throughout their life cycle,
ensuring they meet customer needs and comply with regulatory requirements.
For all types of products and services offered by the Bank (including investment, credit, deposit, bancassurance and payment
products), customers receive clear, accurate and appropriate pre contractual and ongoing information on the key characteristics,
costs and relevant risks, in full conformity with the applicable regulatory requirements, enabling informed decision making
throughout the customer relationship.
Borrowers facing repayment difficulties may find information for debt settlement solutions (through the website link “expression of
interest for debt settlement”) for inclusion in the Arrears Resolution Process, pursuant to the Code of Conduct for Loans under Law
4224/2013, on the Bank’s website (www.eurobank.gr).
Customers can obtain additional information about their transactions through Bank branches, the website, e-Banking, or EuroPhone
Banking. Eurobank's primary goal is to provide continuous, prompt, and accurate information to its customers.
Customer Feedback and Continuous Improvement
Additionally, Eurobank systematically collects and analyses customer feedback through satisfaction and Net Promoter Score (NPS)
surveys at multiple touchpoints (branches, e-Banking, Mobile App, v-Banking, ATMs, EuroPhone Banking), as well as customer
interviews using Design Thinking Methodology, market research projects, and focus group discussions. In 2025, over 150,000
customer evaluations and 64,000 comments were analysed to improve our design of new services. Follow-up communication is
conducted on a sample of resolved cases to gauge satisfaction and collect feedback.
Processes to remediate negative impacts and channels for consumers and end-users to raise concerns [S4-3]
Eurobank has established comprehensive policies and mechanisms that enable customers to raise concerns and ensure the prompt
and appropriate remediation for any negative impacts.
For Eurobank, the relationship and cooperation with its clients constitutes a primary strategic objective. In pursuit of honest,
transparent and effective communication, specific processes have been developed to provide clear and accurate information
regarding the Bank’s products and services. Through the implementation of the Customer Complaints Policy and ISO 9001 and ISO
10002 certified processes, Eurobank manages customer complaints with professionalism and empathy, supported by a centralized
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complaint-management framework. Performance is measured through relevant qualitative indicators, with results reviewed monthly
at the Executive Board level and quarterly by the Audit Committee.
To further strengthen its customer relationships, Eurobank has launched Customer Excellence, designed to enhance customer service
through all points of contact and designed relationships of trust.
Eurobank addresses customer complaints in a spirit of cooperation, understanding and mutual respect, always in pursuit of an
appropriate, fair and mutually acceptable solution. All complaints are managed with impartiality and with a genuine commitment to
equitable resolution. Eurobank has harmonized its Complaints Management Policy with the Bank of Greece's Executive Committee
Act No. 157/2019 and revised it in accordance with ISO 9001 and ISO 10002 standards thereby further enhancing the efficiency and
consistency of the complaint management process. The policy aims to strengthen the effectiveness and responsiveness of Eurobank’s
complaint resolution framework. Customers are also informed that, should they remain dissatisfied
with the proposed resolution,
they have the right to refer the case to the
Hellenic Financial Ombudsman. Performance in terms of these actions is continuously
monitored through qualitative and quantitative indicators established by the Bank. Relevant statistics are extracted and reflected in
detailed reports used to keep Eurobank’s Management updated. Eurobank’s commitment to customer service and its sincere
dedication to client satisfaction are evident throughout every stage of the complaint management process. Customers are
consistently informed of the progress of their case. Additionally, post resolution communication is maintained, to a sample of cases,
to determine whether the customer was satisfied with the outcome, as well as to receive their comments and feedback.
All information and insights derived from complaint analysis are systematically evaluated to identify root causes of dissatisfaction and
to propose measures that enhance service quality and prevent the recurrence of similar issues.
Eurobank closely monitors the effectiveness of its remediation actions through a range of client complaints performance indicators,
which are:
Customer complaint performance
2025
2024
Customer satisfaction rate
49%
50.6%
Complaints resolved within 2 business days
50%
50%
Annual new complaints: annual decrease
5.3%
15.3%
Client cases received
10,248
10,825
Client cases resolved
10,136
10,522
Overall resolution rate
98.9%
97.2%
Additionally, Eurobank makes the most of customer experience data (Voice of Customer) from all available sources, internal and
external, such as complaints, surveys etc., constantly adding new sources by initiating new NPS surveys at various touchpoints
(branches, e-Banking, Eurobank Mobile App, v-Banking, ATMs, EuroPhone Banking) and for major products. These are analyzed and
evaluated to identify areas that call for improvement and to take corrective and preventive measures, so that Eurobank services fully
meet its customers’ wishes and expectations. Moreover, to better monitor results, certain qualitative indicators have been identified
and are regularly monitored.
The effectiveness of these actions and initiatives is further supported by the Retail Customer Excellence Committee, which is
consisted of senior Bank executives and is tasked with making decisions that will produce the desired outcomes for quality and
customer service issues.
In 2025:
●
Over 150,000 customer evaluations on banking experience were collected through regular measurements.
●
Over 64,000 comments were analysed, which helped improve existing services and/or design new ones.
●
Over 1,400 customers were personally contacted to be informed about the actions Eurobank initiated about their
comments.
As a result, of all the above Eurobank’s Relationship NPS (R-NPS) for Primary Bank customers reached record high figure in H2 2025
with an increase of 1,6 points vs H2 2024.
The responsible officer for the receiving and monitoring of reports (RRMO) is tasked with providing clear guidance on how to submit
a report, receiving and confirming receipt of the report within seven working days, and performing an initial assessment. They are
also responsible for designating the appropriate unit or person to handle the report, ensuring the confidentiality of the reporting
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person’s identity and any third parties mentioned. Additionally, the officer monitors the progress of the investigation, maintains
regular contact with the reporting person, and ensures that feedback is provided within a reasonable period, not exceeding three
months from the receipt confirmation. The officer also plans and coordinates relevant training efforts to support the process.
According to the Policy for Reporting Illegal or Unethical Conduct, Eurobank provides protection against reprisal and keeps
confidential the identity of those who have submitted information they know and consider to be accurate and true. Additionally,
there are policies in place to prevent any form of retaliation against individuals, including customers, utilising these channels. For
further reference, applicable information has been disclosed in accordance with ESRS G1-1 Business conduct policies and corporate
culture.
Eurobank also prioritises cybersecurity, personal data, and the resilience of its ICT systems against evolving cyber threats.
Cybersecurity strategy follows a comprehensive Predict, Prevent, Detect, and Respond framework. Customers may contact the Data
Protection Officer regarding any matter regarding the processing of their personal data. Additionally, for the exercise of their rights,
customers may submit a written request to Retail Business Planning and Customer Excellence Retail Banking Unit. Eurobank shall use
its best endeavors to address such requests within thirty (30) days of receipt
Taking action on material impacts on consumers and end-users, and approaches to managing material risks, pursuing material
opportunities related to consumers and end-users, and effectiveness of those actions [S4-4]
Eurobank implements a comprehensive set of actions to address and prevent potential negative impacts on consumers and end-
users. These actions are strategically structured around the pillars of Accessibility, Financial Inclusion, and Approachability, and are
continuously adapted across the Group’s operations and subsidiaries to align with Eurobank’s overarching sustainability objectives.
Accessibility
The combination of physical Branches, ATM’s, EuroPhone Banking, v-Banking, e-Banking and the Eurobank Mobile App, contribute
significantly to customers having access to services. Eurobank also offers clients the option to be served in English at branches and
through EuroPhone Banking, while English is also available as an option at ATMs. The Group’s new “Going from physical to phygital”
approach, an innovative mentality that combines physical service with technology, introduces a new perspective in the Bank
’s
relationship with its customers. Furthermore, the Retail International Customers One-Stop Hub offers a comprehensive range of
products and services to non-resident customers, for their banking and investment needs in Greece. As it is referenced in more detail
at section 3.4 Fostering Innovation, Eurobank Group Digital Banking leverages its expertise to provide innovative, data driven financial
products and services. Placing customers at the centre, it delivers simple, personalized products and ensures easy access to them.
Bringing technology closer to everyone, it acts as a digital and phygital key enabler and Eurobank’s main digital culture ambassador.
Accessibility for People with Disabilities
Eurobank makes continuous efforts to eliminate all barriers, ensuring a welcoming experience for all customers, including individuals
with disabilities. Its approach aligns with the requirements of Law 4994/2022 and the European Accessibility Act (EAA).
In both design and implementation, the Bank follows internationally recognized standards such as EN 301 549:2021 and WCAG 2.1
Level AA, with a strategic goal of full compliance with WCAG 2.2 Level AA. It also adheres to standards related to the physical
environment, including EN 17210:2021, in conjunction with the New Building Regulation of the Ministry of Environment and Energy.
Eurobank is the first Greek bank to have published an Accessibility Statement by June 27, 2025, in accordance with the requirements
of Law 4994/2022.
Also, Eurobank is the first Greek bank to integrate the Digital Disability Card into its systems, ensuring that all customers with
disabilities receive immediate service and benefits.
As of January 1, 2025, customers holding a Digital Disability Card automatically receive priority service without needing to disclose
their disability upon entering the branch. It is sufficient that they have registered their Digital Disability Card. They simply use their
debit or credit card at the Nemo Q automated priority system and receive a ticket for faster service.
Additionally, by registering their Digital Disability Card, customers gain access to enhanced benefits on the Bank’s products and
services:
●
A preferential interest rate of 1.85% on the “Apotamievo Tora” savings account, for amounts up to €5,000, valid for one
year (the current standard rate is 0.15%).
●
Free access to the Eurobank My Blue Advantage benefits package for both 2025 and 2026.
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●
Double €pistrofi (cashback) rewards for two years on purchases at selected supermarkets using a Eurobank debit or credit
card that participates in the rewards programme.
Branches
96 Branches are accessible to individuals who use wheelchairs, and 7 are equipped with detachable ramps to facilitate access.
All branches provide priority service to holders of a digital disability card, and this service can also be accessed via a QR code provided
by the branch manager. Signage indicating priority service is present in all branches, including signage in Braille to assist visually
impaired customers.
In addition, all branches can provide documents in Braille upon request, with a one-week turnaround time for preparation. The
presence of guide dogs is fully welcomed at all service points without exception.
Finally, 13 new generation branches have been mapped to document the conditions inside them, including identifying any areas that
can be used by individuals on the autism spectrum as spaces to decompress if needed. Additionally, Sensory Maps and Sensory
Accessibility Guides, specifically designed for individuals on the autism spectrum, have been added to the Eurobank.gr website and
to the Bank’s interactive tables. These resources enable customers and their companions to be aware of the conditions they will
encounter when visiting these branches.
ATMs
Eurobank has developed extensive initiatives to improve the accessibility of its ATMs. All ATMs support voice guidance for basic
transactions such as cash withdrawals, balance inquiries, and PIN changes. The Technical Project Unit has conducted height
measurements for ATMs located in branches where customer access is from the exterior of the branch, ensuring that the screen and
keypad height ranges between 90 and 120 centimeters, in compliance with the guidelines of the “Designing for All” standard.
Current Accessibility Status
●
1,237 ATMs with voice guidance
●
144 are fully accessible for users with mobility impairments and support voice guidance
Training Actions for Accessibility
As part of its strategy for equitable service and enhanced accessibility, Eurobank has implemented a series of training initiatives and
awareness programmes for its staff on issues related to serving customers with disabilities. These initiatives are aimed at employees
across all units who interact directly or indirectly with the public and focus on:
●
Understanding the current legal framework, as shaped by national and European legislation, with an emphasis on the right
of individuals with disabilities to equal access to services,
●
Recognizing the different types of disabilities and the specific needs that arise in each case, as well as the service options
available per channel and type of disability offered by the Bank,
●
Establishing a framework of actions that promote empathy, accessibility, and inclusion, both in the Bank’s physical and digital
environments.
In total, in 2025, more than 4,200 employees were trained through in-person and online seminars on inclusive customer service,
tailored to different types of disabilities (e.g., mobility, visual, hearing, intellectual, mental). In parallel, experiential training sessions
were conducted for 233 front-line employees, focusing on hands-on understanding and familiarization with the daily obstacles faced
by individuals with disabilities. Additionally, 69 Bank employees attended specialized training on the legal framework governing the
accessibility of banking products and services.
Furthermore, experienced advisors from the v-Banking platform have completed four cycles of study in sign language through the
Hellenic Sign Language School of the Federation of the Deaf of Greece, aiming to better serve individuals with hearing impairments.
v-Banking
With customer service being a key priority, Eurobank is also particularly aware of the need to make its services accessible to people
with disabilities and takes all the appropriate measures.
Specialized banking personnel in the innovative v-Banking service are trained
in sign language to provide equal access to information on the Bank’s products and services for deaf and hard-of-hearing customers.
Support for Neurodiversity and Language Accessibility
In addition, Eurobank is creating conditions for seamless banking services for individuals on the autism spectrum. In collaboration
with Happy Act, the Group is mapping the environments of future branches to identify conditions and areas that can serve as sensory
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relief spaces. Additionally, sensory maps and social stories are being developed and are available on interaction tables and the
website, allowing customers and their companions to understand the conditions they will encounter at the branch in advance.
Accessibility Initiatives Across Subsidiaries
Eurobank’s actions make its services, assets, resources and opportunities accessible to all consumers, are strategically adapted and
deployed across subsidiaries in Bulgaria, Cyprus, and Luxembourg. Example of relative initiatives are ATM/Branch accessibility for
people with disabilities, responsible individual in each branch to assist people with disabilities, etc. While these programmes are
tailored to address the specific local contexts and regulatory environments, they remain aligned with Eurobank’s overarching
sustainability objectives.
Partnerships and Alternative Channels
In 2025, Eurobank received three awards at the Diversity, Equity & Inclusion Awards 2025 organised by the Diversity Charter and Bite
Awards 2025. The Eurobank was recognised for its features and services aimed at improving the experience of people with disabilities,
achieving high scores in the categories of "Bank Strategy" and "Innovation/Creativity".
●
Diversity, Equity & Inclusion Awards 2025 by Diversity Charter:
o
Gold Award in "Physical Abilities”
o
Bronze Award in "Mental Health / Neurodiversity”
●
BITE Awards
o
Gold Award in “Competitive Advantage through ICT for the nomination: Banking without Barriers: Our Commitment to
Accessibility”
Financial Inclusion
Supporting small businesses and social finance
Eurobank promotes financing products that specifically relate to infrastructure and supported services, aiming to assist businesses
grow and become updated, boost their competitiveness, and improve the quality of the products and services they offer. These
processes have been embedded into the Group’s operating model and are performed on an ongoing basis in the context of continuous
financial inclusion:
●
Financing under InvestEU RRF _GR under the Member State compartment of the InvestEU programme for Greece, funded
by the Recovery and Resilience Facility (RRF) and in line with the Recovery and Resilience Plan for Greece which targets
actions in three areas:
1.
Strengthening Competitiveness "RRF GR SME Competitiveness" –Retail Business Banking (RBB) only
2.
Developing Innovation & Digitalization "RRF GR Innovation & Digitalization" active at RBB (Not yet available for
Commercial Banking Network - CBN)
3.
Sustainability "RRF GR Sustainability" active at RBB (Not yet available for CBN) with the Guarantee of the European
Investment Fund (EIF). The funding available under the new (sub)programmes is targeted at SMEs, to cover their
working capital needs and/or to implement investment projects, aimed at improving their competitiveness including
research & innovation, sustainability, digitalisation and digital upgrading of their operations.
●
Financing under SME Competitiveness which benefits from support from the European Union under the InvestEU Fund. (RBB
only). Through InvestEU SME Competitiveness Guarantee Programme, with the guarantee of the European Investment Fund
(EIF), eligible enterprises can access liquidity with reduced collateral requirements and favourable pricing conditions to cover
their working capital needs and/or to implement investment projects aimed at improving their competitiveness.
●
EIB Funding (FIs 88311/2017, 89424/2018, 90866/2019) (Re-employment of funds for CBN).
Standard facility of EIB Loan for SMEs and MidCaps, which focuses (for at least 1/3) on the financing of Final Beneficiaries which
promote youth employment, in the context of the EIB’s Jobs for Youth Initiative.
SMEs and Midcaps that are financed for “Jobs for Youth” have an additional 20bps transfer of financial advantage.
●
Criteria for Jobs for Youth Initiative:
o
In the last 6 months it has employed at least one young person (5 for MidCaps), or in the coming 6 months it plans to
employ at least one young person (5 for MidCaps), calculated from the signature date of the On-lending Agreement; it
commits to keep the young people in employment for at least 1 year
o
In the last 6 months it has provided a vocational training or internship position to at least one young person (5 for
MidCaps), or in the coming 6 months it plans to provide a vocational training or internship position to at least one young
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person (5 for MidCaps), calculated from the signature date of the On-lending Agreement. The training/internship has a
duration of at least 3 months and is formalised by an active cooperation agreement with a technical school, university
or public employment agency and/or is confirmed by a letter signed by one of these institutions and/or is part of the
Final Beneficiary’s own formalised vocational training or internship programme, and/or
o
In the last 6 months it has participated in a youth entrepreneurship programme of a Non-Governmental Organisation
or educational institution or plans to participate in such programme in the coming 6 months.
HDB Programmes
Co-Financed Programmes
●
TEPIX III (Co-financing rate 40%-60% HDB/ERB)
The Fund improves the access to finance for all small and medium-sized enterprises (SMEs) and aims to support and develop
their business activity, so as to cover a wide range of their financing needs. Furthermore, the programme aims to enhance
the productivity of the enterprises, by improving their processes for products & services and to improve their
competitiveness.
●
Micro Agri (Co-financing rate 50%-50% HDB/ERB).
The Fund aims to provide micro loans for investment purposes, covering investments in the agricultural sector, as well as in
investments related to the processing of agricultural products with a final product that is also agricultural. Working Capital
may be granted subject to and for the purposes of investment.
●
Business Growth Fund (Co-financing rate HDB/ERB 40%-60%).
Green Loans Programme
The Fund aims to support SMEs to meet their investment purposes in implementing Green Transition projects that facilitate
reducing emissions, protect the environment and reduce energy consumption costs.
●
Digital Loans Programme
The Fund aims to support SMEs to meet their investment purposes, which are submitted via a business plan, in order to
digitize and digital upgrade their operations, so as to increase productivity, achieve business growth and create new jobs.
●
Spiti mou I & II Programme
The Spiti mou I & II Programmes offer a co-financed loan for the purchase of a first residence to individuals who meet specific
age and income criteria.
Guarantee Programmes
●
TEPIX III
This Fund was designed by the HDB to support SMEs by offering them not only the necessary liquidity and capital for
investments but also the ability to reduce their financing costs. The zero guarantee fee, grace period, and interest subsidy
make financing more accessible, while revolving credit facility provides the flexibility that SMEs need to respond to the
constantly changing market needs. Additionally, the investment and special purpose working capital loans enable SMEs to
implement their strategic investments, expand, and enhance their competitiveness.
●
Tameio Eggyodosias TMEDE
The Fund aims to enhance the liquidity of SMEs of the construction and engineering sectors that wish to undertake or have
undertaken the execution of projects and/or studies of public interest, regardless of the stage of execution of the project or
study, through the provision of guarantees to the cooperative Credit Institutions providing Working Capital Loans, with a
regular maturity, with a disbursement. (RBB only). Active programme in 1st semester of 2024, expected to be reactivated
again
o
Tameio Eggyodosias Kainotomias finance innovative SMEs, for the implementation of investment projects, with the
aim
of research and innovation, through the creation and implementation of a new or significantly improved product or a
process, a new marketing method or a new organisational method in business practices, workplace organisation. (RBB
only). Active programme in 1st semester of 2024, expected to be reactivated again.
●
DeLFI GF
It applies to existing and newly established Very Small, Small, and Medium-sized Enterprises (SMEs) that have been classified
under a support scheme through the new Development Law 4887/2022. (RBB & CBN)
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Education
Education is key pillar to Eurobank’s Corporate Social Responsibility programme, including a variety of actions for supporting students
of all levels and enabling them to connect with the job market and pursue a better future. Apart from the Bank’s participation in
‘Marietta Giannakou’, together with the other 3 systemic banks under the coordination of the Hellenic Banks Association and with
the total amount of €100M for the renovation of 430 schools, Eurobank also engaged in the following actions:
●
Eurobank funded the full-time MSc in Digital Transformation at the Athens University of Economics and Business for Group
employees and other graduates selected on the basis of academic excellence. Beneficiaries paid very low tuition fees, while
job placement was guaranteed for the top 10 performers. Additional initiatives included professional support through
mprostagiatinpaideia.gr, a platform connecting university students with the job market through job placements, internships,
training, and mentoring.
●
The Moving Education Forward initiative—one of Greece’s longest-standing CSR programmes— on the completion of its 23
rd
year and the recognition of 939 outstanding students in the national examinations, also supported the operation of
mprostagiatinpaideia.gr, a professional platform connecting university students with the job market through job
placements, internships, training, and mentoring.
●
The Bank collaborated with the Bodossaki Foundation to fund the establishment of 6 STEM laboratories in public schools in
the Evros Prefecture, Lesvos, and Ikaria, offering students in small schools in remote areas the opportunity to engage in
hands-on learning in physics, chemistry, and biology. It also continued its major sponsorship of CTY Greece, along with its
participation in the extracurricular programme of Anatolia College for young students from Pomak villages, who, under the
guidance of experienced educators, learn English through a wide range of educational and creative workshops.
●
Eurobank has been a major sponsor of the Center for Talented Youth (CTY) Greece since its inception, offering 10
scholarships per year to students to attend innovative summer programmes.
The Demographic Challenge
●
Eurobank continued the implementation of its strategic initiative addressing Greece’s demographic problem, recognizing its
significant social and economic implications. The initiative supports young families and aims to elevate demographic
considerations in the public policy dialogue.
●
In 2025, Eurobank intensified its support in remote eastern regions of Greece, including Evros, the North Aegean, and the
Dodecanese, where local populations face multiple challenges and have limited access to infrastructure and services.
Through Moving Family Forward and partner NGOs, 69 births have been supported since the beginning of the initiative
through free assisted reproduction services for less privileged couples and essential supplies have been provided to new
parents.
●
Eurobank also announced a new action targeting citizens from Evros aimed at starting or expanding newly established
businesses in the area. To this end, the Bank collaborated with AFI Microfinance to provide financial support to individuals
from Evros who do not have access to bank lending, while also offering education and consulting services for business
planning as a prerequisite for financing. By the end of 2025, 64 individuals and/or newly established companies had received
funding, leading to successful cases across diverse sectors, ranging from medical services and engineering to farming,
commerce, and the circular economy.
●
Spiti mou I & II – Affordable housing loans: In 2025, Eurobank actively supported the “Spiti Mou” loan scheme through
participation in the new Spiti mou II Programme. This government-backed initiative facilitates access to affordable home
ownership for younger age individuals and families. Through the provision of low-interest and state co-funded loans (fully
subsidized under certain demographic conditions), the programme contributes to improving living conditions, strengthening
social cohesion, and supporting demographic sustainability. Eurobank’s participation reflects its broader commitment to
inclusive financing and responsible banking, ensuring that more households can secure quality housing while maintaining
long-term financial stability.
To
further enhance transparency and support the Bank’s Sustainability Strategy commitments toward accessibility, inclusion and
improved customer outcomes, Eurobank presents below a detailed breakdown of total disbursements and average loan amounts
across age categories. This additional analysis provides clearer insight into the demographic reach of the “Spiti Mou” programmes
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and demonstrates the Bank’s continued contribution to equitable access to essential financial services within its retail lending
portfolio.
Spiti mou I Total Disbursements & Average Ticket
Age Bands
Applications
%
Loan Amount (€)
%
Average Amount
(€)
<30
361
18.88
33,446,584
17.90
92,650
30–40
1,540
80.54
152,282,246
81.50
98,885
40–50
11
0.58
1,122,750
0.60
102,068
Grand Total
1,912
100.00
186,851,579
100
97.726
Spiti mou II Total Disbursements & Average Ticket
Age Bands
Applications
%
Loan Amount (€)
%
Average Amount
(€)
<30
341
16.89
35,191,932
16.01
103,202
30–40
941
46.61
103,862,068
47.24
110,374
40–50
731
36.21
80,346,770
36.54
109,914
50–60
6
0.30
459,800
0.21
76,633
Grand Total
2,019
100.00
219,860,570
100.00
108,896
Social Resilience
●
From an extensive set of initiatives supporting the State and civil society, particular emphasis in 2025 was placed on
sponsorships and donations in the fields of health and accessibility.
●
More specifically, the Bank provided financial support to Laiko Hospital for the staffing of the liver transplant clinic, whose
innovative operation benefits a significant number of patients each year. It also financed the purchase of modern
gastroscopy equipment for Konstantopouleio Hospital, as well as the renovation of the Diabetology Clinic at the Salamis
Naval Base.
Culture
●
In 2025, Eurobank engaged in a number of cultural projects and/or sponsorships with a view to making art and culture more
accessible to all citizens. Apart from contributing to the study and implementation of renovating the historic Old Parliament
building, which houses the National Historical Museum of Greece, the Bank continued to support the Benaki Museum as
sponsor of its entire exhibition programme, sponsored the exhibition “Cycladic Blues” by Marlene Dumas at the Museum of
Cycladic Art, one of the most distinctive and radical figures in international contemporary art, and supported the exhibition
of Nikolas Kontaxis at the Basil & Elise Goulandris Museum, an acclaimed visual artist who explores and embraces his
neurodiversity through creation, color, and art. Eurobank also financed the Sacred Music Festival of the Greek National
Opera, a series of interfaith and unifying performances held in both open-air and indoor venues across Athens, as well as
the Syros Classical Music Festival, which brings together outstanding artists from the international music scene for both local
audiences and visitors to the island.
●
Revolving savings culture: Eurobank collaborates with the University of Piraeus and the the Hellenic Financial Literacy
Institute to provide educators of young children with knowledge and content for explaining the concept of savings and best
practices in managing personal finances. Eurobank also promotes CSR initiatives supporting youth education, including
awareness campaigns and programmes for financial literacy.
●
Eurobank offers student loans for undergraduate and postgraduate studies, covering tuition fees and related educational
expenses. These loans feature favorable interest rates compared to standard personal loans, flexible repayment terms, and
options for parents to act as guarantors.
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Approachability
Eurobank ensures that its products, services and information are approachable, transparent and digitally accessible through its online
channels, fostering trust and enabling consumers and end-users to independently access information, perform monetary and non-
monetary transactions, as well as to raise concerns and receive timely responses. Through continuous enhancement of its digital
environments, Eurobank expands the availability and coverage of its services, empowering customers to efficiently manage their
financial needs anytime and anywhere. The Customer Excellence initiative delivers outstanding service at all customer touchpoints
and fosters trust-based relationships. Eurobank provides customized information to every customer, ensuring transparent
communication about products and services
Nationwide Physical and Digital Presence
Focusing on customer service, Eurobank aims to make its services, assets, resources and opportunities accessible to all. To this end,
through its branch network (266 branches), the Hellenic Post Office network (420branches) and the self -service banking terminal
network (1,774 service points), Eurobank aims to maintain its presence in remote and inaccessible areas, serving populations having
difficulty to physically access services, as well as people with disabilities. Through the Hellenic Post branches, Eurobank is present in
238 Municipal Communities with a population of less than 5,000 people, many of whom have difficulty accessing services, especially
on remote islands (e.g. Agathonisi, Anafi, Karpathos, Nisyros, Tilos, Halki, Folegandros, Amorgos, etc.). Additionally, in 182 areas with
a population less than 5,000 people, access to services is provided via off-site ATMs (e.g. Agios Efstratios, Alonissos, Symi, etc.). In
2025, the network of deposit-enabled ATMs expanded by 103 units, of which 46 represent newly established OffSite locations. 57%
of the ATM fleet has already deposit capability. Additionally, in 2025, the cash withdrawal functionality was activated across APS
terminals.
Eurobank Mobile App
The Eurobank Mobile App is designed, developed and regularly optimised to comply with Web Content Accessibility Guidelines
(WCAG) 2.1, Level AA, and the European Standard for ICT accessibility (EN 301 549). Additional WCAG 2.2 criteria specific to mobile
applications are also taken into consideration to create better mobile experiences for all. Our teams collaborate to enable disabled
users to carry out basic banking transactions on the app, such as payments, fund transfers, card top-up and IRIS Payments, keep track
of their finances, and manage their cards.
e-Banking
Eurobank’s digital banking platform is an established customer service channel of the Bank. It is developed and optimised with a
commitment to meet Web Content Accessibility Guidelines (WCAG) 2.1, Level AA, and the European Standard for ICT accessibility (EN
301 549). It allows users with disabilities to customise the interface to their requirements, e.g. enlarge text and change colours, and
also to navigate it using assistive technologies, e.g. screen readers. This enables them to interact with core digital functionalities and
perform banking tasks, such as view their balance, carry out transactions, and manage their finances. To continue providing inclusive
access to core banking services, our teams carry out accessibility audits with specialised partners and usability tests including users
with disabilities. Their findings drive remediation with the objective to enhance digital accessibility and create an equitable banking
experience for all.
Enhanced Customer Service Channels and Innovations
In 2025, over 980.100 appointments were scheduled throughout the year. The online appointment booking option (through
eurobank.gr and e/m banking) became available towards the end of July 2023. Τhe appointments through digital channels during the
whole year 2025 was 27% of the total bookings. Branch appointment booking was made available through Digital Channels providing
customers with real-time information on service availability, appointment details, and offers 24-hours/day as well as SMS reminders,
significantly enhancing customer convenience. It has been established that customers must be able to secure an available
appointment within three (3) days.
As part of our ongoing efforts to enhance the customer experience and improve operational efficiency, we have leveraged the “Digital
Document Certification” functionality provided by the Greek government, integrating it into an innovative application within the
Bank’s systems. This application enables the remote completion of tasks and sales with speed, security, and ease, both for the
customer and the employee—eliminating the need for physical presence at the branch.
Specifically, the tool offers the following benefits:
•
A simple, fast, and automated workflow for securely sending and receiving documents to and from the customer.
•
Automated validation checks of digitally signed documents through the gov.gr platform.
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•
Historical tracking and traceability of all actions and data.
•
Time savings for front-line staff and a streamlined service experience for customers.
•
Decongestion of physical branches, enhancing flexibility and effectiveness in daily banking operations.
Optimizing Relationship Manager Time Allocation
Eurobank implemented two key changes to increase the time relationship managers allocate to each client. The Eurobank call centre
answers incoming calls to all branches, allowing for faster and more efficient service. Branch staff between 10:00 and 13:00 focus on
advisory services, and customers can carry out monetary transactions exclusively with the use of self-service transaction terminals.
This has been implemented in 264 out of 266 branches. During the summer season, selected branches will extend Meta Teller
operating hours to deliver exceptional service to RBB customers. Specifically, service hours are extended by one hour, from 08:00 to
10:00 and from 12:00 to 14:00.
As part of the Group’s advisory approach and its commitment to enhancing services, the Mobility initiative empowers our officers to
deliver banking solutions beyond branch premises. During on-site visits, they provide customers with comprehensive support across
a defined range of banking services and products (end to end).
Nationwide Access through Strategic Partnerships
Eurobank has a cooperation agreement with Hellenic Post (ELTA) that allows Eurobank’s customers to enjoy core banking services
through the Hellenic Post branch network. With more than 400 branches and 100 ATMs across Greece, the Hellenic Post branch
network provides extensive nationwide service, both in urban and in remote areas, where banking presence is limited or non-existent.
Alternative Communication and Sales Channels
In addition. Eurobank’s Telemarketing is an alternative channel which promotes products and services to existing Group customers.
The promotions and targeted customers are selected in collaboration with 3 segments (IB, PB, SB). Telemarketing offers direct,
personal and 2-way communication. The sales are completed over the phone, digitally or at the customer’s place of choice. The main
promotional products are Loans, credit & debit cards and light bancassurance products. Information is provided directly over the
telephone or through referral to the branch network.
Eurobank’s approach to approachability is further supported by its recognition for innovative customer service and inclusion practices
at the National Customer Service Awards and DEI Bite Awards.
Complaint Management and Remediation
Eurobank’s complaint management is harmonized with the Bank of Greece's Executive Committee Act No. 157/2019 and is certified
under ISO 9001 and ISO 10002. All complaints are managed with impartiality and a sincere willingness to reach a fair solution.
Customers are regularly updated on the progress of their case, and if not satisfied with the proposed solution, they are advised of
their right to contact the Hellenic Financial Ombudsman.
Communication is maintained with a sample of customers even after their case has been resolved, to determine satisfaction with the
outcome and to receive further feedback. This information is used to identify reasons for dissatisfaction and to recommend
improvements in service provision and prevention of future issues.
Monitoring and Continuous Improvement
Eurobank tracks the effectiveness of its actions through quantitative and qualitative indicators, including:
●
Client complaints performance indicators (customer satisfaction rate, complaints resolved within 2 business days, annual
new complaints, client cases received/resolved, overall resolution rate).
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Customer satisfaction surveys and Net Promoter Score (NPS) metrics.
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Customer privacy and information protection indicators are also regularly monitored.
Eurobank achieved a 5.3% annual decrease in new complaints for 2025. Furthermore, it is worth noting that Eurobank achieved a
48% cumulative reduction in complaints over the past four years. Additionally, 50% of complaints were resolved within two business
days, demonstrating the effectiveness of the Bank’s ISO-certified complaint management process.
The Retail Customer Excellence Committee, composed of senior Group executives, is responsible for making decisions to ensure
quality and customer service outcomes, and also oversees privacy and information protection KPIs that concerns customer’s
experience.
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The process regarding identifying what action is needed and what response to a particular actual or potential negative impact on
consumers and/or end-users is characterised by ESG Risk Assessment. Eurobank continues to strengthen its capacity to identify and
manage social risk stemming from client operations.
Processes to provide remedy in the event of material negative impacts are available and effective in their implementation and
outcomes. These processes include actively seeking customer feedback through customized communication tools and ensuring that
customers receive direct and prompt information about any new deals or changes to the products and services they choose.
All advertising and promotional campaigns are subject to prior authorization by relevant Group units, with content reviewed for
compliance.
Severe human rights issues and incidents connected to consumers and/or end-users have not been reported. In 2025, no incidents of
non-compliance with regulations and voluntary codes concerning product and service information, and labelling or marketing
communications were identified and, as a result, no fines or sanctions were imposed on the Group.
Resources allocated to the management of material impacts engage internal functions such as Risk Management, Compliance, IT
Security, and Customer Experience departments, which take actions like enhancing threat intelligence and cybersecurity measures,
conducting staff training and awareness programmes, ensuring compliance with international standards, and monitoring customer
satisfaction.
At this stage, Eurobank has not set quantitative targets for these actions, as the initiatives under S4 -4 are implemented as ongoing
and adaptive processes rather than fixed, time-bound objectives.
Subsidiaries’ Information-related Impacts for Consumers and/or End-users actions
In addition to Group-level policies on transparency and customer communication, Eurobank’s subsidiaries in Bulgaria, Cyprus, and
Luxembourg implement targeted actions to ensure clear, accessible, and responsible information for consumers and end-users. The
following sub-sections summarize each subsidiary’s key measures and achievements in this area.
Bulgaria (Postbank)
Postbank ensures inclusive access to its products and services through a multi-channel service model, including an extensive branch
network, dedicated business centers, digital banking platforms, ATMs and Express Banking Digital Zones, as well as a 24/7 customer
service line. Accessibility and transparency for customers and end users form an integral part of the Bank’s social responsibility and
sustainability approach.
In preparation for the application of the European Accessibility Act (Directive (EU) 2019/882), as transposed into the Bulgarian
Accessibility Requirements for Products and Services Act, the Bank has established a structured Accessibility Act implementat ion
Programme covering its core banking digital services and customer-facing channels. A comprehensive accessibility assessment has
been performed across websites, mobile applications, self-service terminals, digital banking zones, electronic communications (e-
mails and PDFs), and social media content, in line with the requirements of the applicable legislation and the WCAG 2.1 accessibility
standards (Levels A and AA). Based on the assessment results the Bank has outlined a multi year roadmap focused on gradual
enhancement of accessibility standards across all key areas. New products, services and digital assets progressively integrate relevant
accessibility requirements as these standards become embedded into internal processes and development practices.
Postbank is committed to continuously improving the accessibility of its digital channels for individuals with specific needs, including
enhancements that address visual, hearing and other functional impairments. Transparency is further reinforced through clear and
accessible information on product features, fees, commissions, and contractual terms.
In addition, Postbank has been advancing initiatives that support equal access to financial services, including sign language training
for front office teams and financial literacy educational programmes for younger audiences, in line with the Bank’s social sustainability
objectives.
Cyprus (Eurobank Limited and insurance subsidiaries)
responsible banking and transparency.
The Customer Contact Center is ISO 18295-1 certified, ensuring high-quality and accessible customer support. The Customer Contact
Centre staff have been appropriately trained to provide service with clarity, simplicity, brevity and consistency.
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A formal, centralized customer complaints procedure operates in accordance with regulatory requirements. Complaints are analysed
and investigated to identify root causes and propose holistic solutions, while customer service KPIs are regularly reviewed. Continuous
staff training supports service quality and customer-centric delivery. Complaint handling procedures are publicly available and
regularly reviewed by management.
Furthermore, in line with the Accessibility of Products and Services Law of 2024, which transposes the European Accessibility Act, the
Bank is in the process of establishing a structured accessibility framework covering its products, services, digital channels, customer
communications, and physical service points. Eurobank Limited has issued a Declaration of Conformity confirming its commitment to
providing accessible products, services, and customer channels in accordance with applicable national legislation transposing the
European Accessibility Act. Accessibility is recognised as a core principle of equal treatment and customer-centric service delivery and
is integrated across both digital and physical customer touchpoints.
The Bank ensures the accessibility of its digital resources by following internationally recognized standards such as EN 301549:2021
and the Web Content Accessibility Guidelines (WCAG) 2.1 level AA. The Bank’s goal is to fully comply with the WCAG 2.2 level AA
Standard.
Digital banking solutions have been expanded for greater accessibility, including online banking, mobile banking, digital wallets, and
open banking. The digital channels include basic functions that are already partially accessible (e.g. keyboard navigation) while
Eurobank Limited is working intensively to improve the user navigation experience in these functions.
For the accessibility of the physical infrastructure, Eurobank Limited follows standards and general guidelines issued from time to
time by the competent authorities and/or through the Association of Cyprus Banks. Accessibility enhancements are continuously
implemented to support users with visual, hearing, mobility, or other impairments.
The branches constitute the main physical customer service channel and maintain an important role in the provision of an accessible
environment. Specifically,
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All branches offer priority service to all customers who fall within the scope of protection of the local law and priority service
signage is present in all stores, including Braille.
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All branches have parking slots for the disabled.
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Guide dogs are unconditionally accepted at all service points.
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The majority of branches are accessible to people using wheelchairs.
The ATMs are highly accessible to people with mobility problems. Furthermore, some devices have functional features such as
embossed keys, headphone ports and clearly worded visual messages with high contrast.
In parallel, the Bank takes measures to improve accessibility across physical service points, including branches and ATMs, and ensures
that customer information, contractual documentation, and product disclosures are made available in clear and accessible formats,
including alternative formats upon request. Accessibility considerations are embedded into the Bank’s design, development, and
operational processes and are supported by internal assessments, staff training, and ongoing monitoring.
With regards to the insurance subsidiaries, ERB Cyprus Insurance Holdings Limited aims to deliver high-quality, client-focused services.
Trained intermediaries provide clear and transparent product information, while customer service teams and regional representatives
offer timely support and manage claims. The ex-CNP mobile app enhances customer experience by allowing clients to view policies,
payments and claim status, upload documents and download statements. A Complaints Management Policy sets out the company’s
approach and responsibilities for handling client complaints.
Luxembourg (Eurobank Private Bank Luxembourg)
Eurobank Private Bank Luxembourg ensures that information for consumers and end-users is clear, accessible, and compliant with
regulatory standards. The bank maintains multiple communication channels and provides regular training to staff on customer service
and information security. Complaint management processes are in place to address client concerns promptly, and the bank is
committed to ongoing improvements in customer communication