ANNUAL REPORT
For the period from 1 January to 31 December 2025
(In accordance with Law 3556/2007)
Athens, February 26, 2026
1 | ANNUAL FINANCIAL REPORT
Contents
Statements by the Members of the Board of Directors .............................................................................................................. 5
Board of Directors’ Report as at 31.12.2025 ............................................................................................................................... 6
Explanatory Report of the Board of Directors of Alpha Bank S.A. for the year 2025 ........................................................ 36
Sustainability Statement FY 2025 ..................................................................................................................................... 41
Corporate Governance Statement ................................................................................................................................. 158
INDEPENDENT AUDITOR’S LIMITED ASSURANCE REPORT ......................................................................................................... 236
INDEPENDENT AUDITOR’S REPORT .......................................................................................................................................... 240
Financial Statements for the Group and the Bank as at 31.12.2025 ........................................................................................ 250
Income Statement .................................................................................................................................................................. 251
Statement of Comprehensive Income .................................................................................................................................... 252
Balance Sheet ......................................................................................................................................................................... 253
Statement of Changes in Equity .............................................................................................................................................. 254
Statement of Cash Flows ........................................................................................................................................................ 257
Notes to the Financial Statements .......................................................................................................................................... 258
GENERAL INFORMATION ............................................................................................................................................................... 258
1. Accounting policies applied ........................................................................................................................................... 261
1.1 Basis of presentation ................................................................................................................................................................ 261
1.2 Material accounting policies ..................................................................................................................................................... 263
1.3 Significant accounting judgments and key sources of estimation uncertainty......................................................................... 280
Reverse merger ............................................................................................................................................................................... 284
2. Restatement of financial statements ............................................................................................................................ 286
INCOME STATEMENT ..................................................................................................................................................................... 293
3. Net interest income ....................................................................................................................................................... 293
4. Net fee and commission income ................................................................................................................................... 294
5. Dividend income ............................................................................................................................................................ 295
6. Gains less losses on derecognition of financial assets measured at amortised cost..................................................... 296
7. Gains less losses on financial transactions .................................................................................................................... 296
8. Other Income ................................................................................................................................................................ 297
9. Net income from investment property management ................................................................................................... 297
10. Staff costs ...................................................................................................................................................................... 297
11. General Administrative expenses .................................................................................................................................. 299
12. Impairment losses and provisions to cover credit risk .................................................................................................. 299
13. Expenses relating to credit risk management ............................................................................................................... 300
14. Impairment losses on fixed assets and equity investments .......................................................................................... 300
15. Gains/(Losses) on disposal of fixed assets and equity investments .............................................................................. 301
16. Provisions ...................................................................................................................................................................... 301
17. Transformation costs ..................................................................................................................................................... 301
18. Income tax ..................................................................................................................................................................... 301
19. Earnings/(losses) per share ........................................................................................................................................... 303
ASSETS ....................................................................................................................................................................................... 306
20. Cash and balances with Central Banks .......................................................................................................................... 306
21. Due from financial institutions ...................................................................................................................................... 306
22. Trading securities .......................................................................................................................................................... 306
23. Derivative financial instruments (assets and liabilities) ................................................................................................ 307
24. Loans and advances to customers ................................................................................................................................. 314
25. Investment securities .................................................................................................................................................... 316
26. Investments in subsidiaries, associates and joint ventures ........................................................................................... 318
27. Investment property ..................................................................................................................................................... 323
28. Property plant and equipment ...................................................................................................................................... 324
29. Goodwill and other intangible assets ............................................................................................................................ 325
30. Deferred tax assets and liabilities .................................................................................................................................. 325
31. Other assets ................................................................................................................................................................... 327
LIABILITIES ...................................................................................................................................................................................... 329
32. Due to Banks.................................................................................................................................................................. 329
33. Due to customers .......................................................................................................................................................... 329
34. Debt securities in issue and other borrowed funds ...................................................................................................... 329
35. Liabilities for current income tax ................................................................................................................................... 332
2 | ANNUAL FINANCIAL REPORT
36. Employee defined benefit obligations .......................................................................................................................... 332
37. Other Liabilities ............................................................................................................................................................. 334
38. Provisions ...................................................................................................................................................................... 335
EQUITY ....................................................................................................................................................................................... 336
39. Share Capital.................................................................................................................................................................. 336
40. Share premium .............................................................................................................................................................. 338
41. Merger reserve .............................................................................................................................................................. 338
42. Other Equity Instruments .............................................................................................................................................. 338
43. Reserves ........................................................................................................................................................................ 338
44. Retained Earnings .......................................................................................................................................................... 340
ADDITIONAL INFORMATION .......................................................................................................................................................... 341
45. Contingent liabilities and commitments ....................................................................................................................... 341
46. Group Consolidated Companies .................................................................................................................................... 343
47. Disclosures Law  4261/5.5.2014 .................................................................................................................................... 352
48. Segment Reporting ........................................................................................................................................................ 353
49. Risk Management .......................................................................................................................................................... 356
49.1 Credit Risk ...................................................................................................................................................................... 356
49.2 Market Risk .................................................................................................................................................................... 413
49.3 Liquidity risk .................................................................................................................................................................. 420
49.4 Fair value of financial assets and liabilities .................................................................................................................... 426
49.5 Transfers of financial assets .......................................................................................................................................... 435
49.6 Offsetting financial assets - liabilities ............................................................................................................................ 436
50. Capital Adequacy ........................................................................................................................................................... 439
51. Related party transactions ............................................................................................................................................ 441
52. Auditor’s fees ................................................................................................................................................................ 444
53. Disclosure of Law 4151/2013 ........................................................................................................................................ 444
54. Assets held for sale ........................................................................................................................................................ 445
55. Corporate events relating to the Group structure ........................................................................................................ 447
56. Acquisition of companies .............................................................................................................................................. 448
57. Discontinued Operations ............................................................................................................................................... 451
58. Insurance Contract Liabilities ........................................................................................................................................ 452
59. Strategic Plan ................................................................................................................................................................. 454
60. Events after the balance sheet date .............................................................................................................................. 455
Appendix of the Board of Directors’ Annual Management Report ......................................................................................... 456
EU TAXONOMY REPORTING FORMS ....................................................................................................................................... 458
Availability of Annual Financial Report ................................................................................................................................... 497
STATEMENT BY THE MEMBERS OF BOARD OF DIRECTORS
5 | ANNUAL FINANCIAL REPORT
Statements by the Members of the Board of Directors
(in accordance with article 4 paragraph 2 of Law 3556/2007)
To the best of our knowledge, we declare that the annual financial statements that have been prepared in accordance with the applicable
accounting standards, accurately and truthfully represent the assets, liabilities, equity and financial performance of Alpha Bank S.A. and of the
companies included in the consolidated financial statements taken as a whole, as provided in article 4 paragraph 2 of Law 355 6/2007, and that
the Board of Directors’ Annual Management Report presents correctly the evolution, performance an d financial position of Alpha Bank S.A.,
and of the companies included in the consolidated financial statements taken as a whole, including the description of the main risks and
uncertainties that they face. The Board of Directors’ Annual Management Report was prepared in accordance with the sustainability reporting
standards referred to in Article 154A of Law 4548/2018 and the specifications approved pursuant to Article 8 paragraph 4 of Regulation (EU)
2020/852 of the European Parliament and of the Council of 18 June 2020, on the establishment of a framework to facilitate sustainable
investment, and amending Regulation (EU) 2019/2088.
Athens, February 26, 2026
THE CHAIRMAN
OF THE BOARD OF DIRECTORS
THE CHIEF
EXECUTIVE OFFICER
EXECUTIVE MEMBER
OF THE BOARD OF DIRECTORS
DIMITRIOS C. TSITSIRAGOS
ID No A 00808440
VASSILIOS E. PSALTIS
ID No A 02206685
LAZAROS A. PAPAGARYFALLOU
ID. No Α 02932445
Board of Directors’ Report as at 31.12.2025
6 | ANNUAL FINANCIAL REPORT
Board of Directors’ Report as at 31.12.2025
MACROECONOMIC ENVIRONMENT
Greek Economy
Economic activity in Greece continued to expand during 2025, amid heightened uncertainty surrounding the global and European economic
landscape, due to the rapid intensification of trade and geopolitical tensions. Real GDP recorded a 2% annual increase in the first nine months
of 2025 (Graph 1), compared to 1.7% y-o-y in the EU-27 and 1.5% y-o-y in the euro area. The rise in economic activity in January-September
2025 was mainly supported by private consumption, on the back of, among other factors, the ongoing employment gains, the increase in
households’ disposable income and tourism performance. The positive contribution of private consumption was equal to 1.8 percentage
points (pps), followed by net exports (1.4 pps), investment (1.1 pps) and public consumption (0.3 pps). On the other hand, inventories (incl.
statistical discrepancies) deducted 2.6 pps from GDP growth in the first nine months of 2025.
Inflation based on the Harmonized Index of Consumer Prices (HICP) averaged 2.9% in 2025, compared to 3% in 2024 and 2.1% in the euro area
(Graph 2). The persistence of services inflation is the main driver of headline inflation, accounting for around 80% of the increase in HICP during
2025. In contrast, the contribution of HICP-energy was marginally negative. According to available forecasts (Bank of Greece, Interim Report on
Monetary Policy 2025, December 2025), inflation is expected to moderate to 2.1% in 2026.
According to the Ministry of Economy and Finance's forecast, the achievement of primary surpluses (3.7% in 2025, 2.8% in 2026 and 2.7%
from 2027 to 2029) alongside the projected nominal growth trajectory is expected to reduce the debt-to-GDP ratio further down in the
coming years. In particular, the debt-to-GDP ratio is projected to de-escalate from 154.2% in 2024, to 145.9% in 2025 and further to 119% by
the end of 2029 (Graph 3). Fiscal credibility is reflected in the Greek sovereign credit rating upgrades by rating agencies during 2025 (to BBB
by DBRS, S&P, Fitch and Baa3 by Moody’s), as well as in the bond market developments, where the yield on 10-year Greek government bond
(3.44%), was lower than those of Italy (3.55%) and France (3.56%) on 31 December 2025.
-12%
-8%
-4%
0%
4%
8%
12%
2019 2020 2021 2022 2023 2024 2025 9m
Sources: ELSTAT, Alpha Bank Economic Research calculations
Graph 1. GDP demand-side contributions
Investment Private Consumption Public Consumption
Inventories* Net Exports GDP
*Including statistical discrepancies
0,0
1,0
2,0
3,0
4,0
5,0
6,0
Source: Eurostat
Graph 2. HICP in Greece and the EA (annual % change)
EA20- HICP Greece- HICP EA20- Services Greece- Services
Board of Directors’ Report as at 31.12.2025
7 | ANNUAL FINANCIAL REPORT
Labour market conditions continue to improve. The unemployment rate averaged 8.8% in 2025 down from 10.1% in 2024. This downward
trend is expected to continue in the coming years, though at a decelerating pace, as the rate of unemployment approaches the level of
structural unemployment, which reflects the mismatches in the labor market between supply and demand.
Residential and prime commercial prices remain on an upward trajectory. According to the latest reads, nominal residential property prices
increased by 7.5% y-o-y in the first nine months of 2025, whereas office and retail shops’ prices grew by 4.8% y-o-y and 5.2% y-o-y
respectively, in H1 2025.
The prospects of the Greek Economy
Going forward, growth dynamics in Greece are expected to remain solid, with real GDP growth outperforming the European averages in 2025
and over the medium term. According to the latest forecasts (Ministry of Economy and Finance, European Commission, International
Monetary Fund, Bank of Greece), real GDP growth is estimated to range between 2.0% - 2.4% in 2025 and 2026, significantly above the
projected Euro area average (2025: 1.4%, 2026: 1.2%, ECB, Eurosystem Staff Macroeconomic Projections, December 2025). Economic growth
is projected to be supported mainly by: (i) the increased contribution of investment, on the back of the Recovery and Resilience Facility (RRF)
absorption, the implementation of the Public Investment Budget (PIB) and the increased Foreign Direct Investment (FDI) flows, (ii) enhanced
extroversion of the Greek firms, as well as (iii) resilient private consumption, on the back of employment gains and disposable income growth.
Short-term risks are tilted to the downside and stem from geopolitical tensions, the implementation of the trade agreement between the US
and the European Union, possible adoption of new trade protectionist policies, natural disasters, the impact of climate change and potential
delays in the implementation of the RRP.
Global Economy
In 2025, the global economy was characterized by high geopolitical uncertainty and increasing barriers to trade. However, economic activity
remained quite resilient. According to the Organization for Economic Cooperation and Development (OECD, Economic Outlook, December
2025), global economic growth is projected to slow from 3.3% in 2024 to 3.2% in 2025 and 2.9% in 2026, followed by a slight uptick to 3.1% in
2027. The US tariff policy has not led to a rapid downturn, at least so far.
As far as the USA is concerned, real GDP growth is projected to slow from 2.8% in 2024 to 2.0% in 2025 and 1.7% in 2026, before recovering
to 1.9% in 2027. This slowdown is expected to be the result of various factors, such as a decline in employment growth, a significant reduction
in immigration, the pass-through of tariff increases to the price level, and significant cuts in non-defence spending. Economic growth in China
in 2025 is estimated to reach 5% in 2025, a performance like that of 2024. However, forecasts for the coming years show a slowdown to 4.4%
in 2026 and 4.3% in 2027. Consumption has been supported by the expansion of a program to replace old cars and household electronic
appliances with new technology equivalents. Overall investment activity was relatively low due to several factors, but the most important was
the contraction of the real estate sector.
On the monetary policy front, most central banks eased their monetary policy last year (Graph 4) in order to support economic growth, as
inflation reached or approached its targets. The ECB's interest rates were cut in the first half of 2025 as part of a cycle of monetary easing,
with the deposit rate standing at 2.00% in June. Following this reduction, interest rates remained unchanged at the meetings in July,
September, October, and December. Specifically, the interest rates on the deposit facility, the main refinancing operations, and the marginal
lending facility remained unchanged at 2.00%, 2.15%, and 2.40%, respectively. The US Federal Reserve (Fed) cut the federal funds rate by 25
basis points to a range of 3.5%-3.75% at its December 2025 meeting, following cuts in September and October. At the same time, the Bank of
England (BoE) lowered its policy rate to 3.75% in December 2025, after keeping it at 4% since August 2025.
110%
120%
130%
140%
150%
160%
0
1
2
3
4
5
2024 2025e 2026f 2027f 2028f 2029f
Source: Ministry of Economy and Finance, Multiannual fiscal planning 2026-29
Graph 3. Primary balance and Debt-to-GDP ratio
GG primary balance (% of GDP) Public debt to GDP, rhs
Board of Directors’ Report as at 31.12.2025
8 | ANNUAL FINANCIAL REPORT
Significant challenges remain for the global economy in 2026.
First, trade restrictions and protectionism: Trade tensions and tariff policies are expected to remain a major issue in 2026. In particular, trade
dispute between the US and China, the world's two largest economies, is also likely to continue, although they have eased somewhat since
Trump and Chinese President Xi Jinping met in October and agreed to a one-year truce in their trade war.
Second, geopolitical uncertainty. Increased instability -including armed conflicts like the US military intervention in Venezuela- raises risks to
global stability. Governments face challenges to adjust their fiscal and structural policies to the new reality. A possible intensification of
ongoing military conflicts in the Middle East or Ukraine may disrupt global energy markets, while the diplomatic threats related to Greenland
could lead to a re-pricing of risk in several international markets. While global oil and natural gas markets are adequately supplied at present,
potential tensions could lead to supply chain disruptions and, as a result, a reassessment of the global economic outlook. In addition, a further
deterioration of ongoing geopolitical conflicts could create greater uncertainty, which could hurt consumer confidence and investment
activity.
Third, high debt and tight financial conditions: The public debt-to-GDP ratios are very high in some advanced economies, as well as, in certain
emerging markets and developing economies (EMDEs). Consequently, these countries are facing severe challenges due to high borrowing
costs also and limited fiscal space to promote growth.
Euro area
The euro area economy is proving to be resilient despite the trade tensions and global geopolitical developments. According to European
Central Bank’s macroeconomic projections (December 2025), economic growth is expected to continue being underpinned by domestic
demand, with negative contribution of net exports in 2025 and 2026. Private consumption is projected to grow robustly in the next years,
recording the largest contribution to real GDP growth. The strengthening of households' spending is expected to be supported by their
increasing purchasing power, reflecting robust wages and employment growth. In addition, over the period 2026-2028 investment growth is
expected to outperform GDP growth. Private investment is expected to offset the decline in public investment in 2027-2028 due to the end of
the Next Generation EU (NGEU) program. Net exports, also, are projected to negatively impact real GDP growth in 2025 and 2026, due to US
tariffs, relatively low competitiveness in the euro area and the euro’s appreciation on export performance.
According to the ECB’s macroeconomic projections (December 2025), real GDP growth is estimated to be 1.4% in 2025, 1.2% in 20 26 and 1.4%
in 2027. Based on the Harmonized Index of Consumer Prices (HICP), the euro area inflation is projected to reach 2.1% in 2025 and decline
further at 1.9% in 2026 and 1.8% in 2027. HICP excluding energy and food is expected to decelerate at 2.4% in 2025, 2.2% in 2026 and 1.9%in
2027, mainly driven by the services component. In 2025, euro area business investment has been more resilient than expected, while it is
projected to continue to rise in 2026-28, amid supportive financing conditions, stronger domestic and foreign demand, lower uncertainty and
spillovers from defense and infrastructure spending.
Countries where the Group operates
Cyprus
Economic activity in Cyprus increased by 3.5% (annual change, seasonally adjusted figures) in the first nine months of 2025, recording the
second highest growth rate among the EU Member States.
The expansion of economic activity was supported by both private and public
consumption, investment dynamics and exports of services. The European Commission (Autumn 2025 Economic Forecast) estimates real GDP
growth rate to stand at 3.4% in 2025 and 2.6% in 2026. Economic growth is expected to be supported by domestic demand, while private
consumption growth is likely to moderate, reflecting slower income growth and a deceleration in the inflow of foreign workers. Investment is
expected to be boosted by the implementation of Recovery and Resilience Plan (RRP) and FDI inflows.
Annual harmonised inflation decelerated from 3.9% in 2023, to 2.3% in 2024, and further to 0.9% in January-November 2025 mainly due to
falling energy and non-energy industrial goods prices, as well as moderating food prices. According to the European Commission (Autumn
2025 Economic Forecast), HICP inflation is forecast to accelerate to 1.5% in 2026.
Public debt decreased significantly from 71.1% of GDP in 2023, to 62.8% in 2024 and it is expected to fall to 56.4% in 2025 and 51% in 2026
(European Commission, Autumn 2025 Economic Forecast) mainly due to primary surpluses and continued nominal GDP growt h.
-1,0
0,0
1,0
2,0
3,0
4,0
5,0
6,0
Dec-18
Mar-19
Jun-19
Sep-19
Dec-19
Mar-20
Jun-20
Sep-20
Dec-20
Mar-21
Jun-21
Sep-21
Dec-21
Mar-22
Jun-22
Sep-22
Dec-22
Mar-23
Jun-23
Sep-23
Dec-23
Mar-24
Jun-24
Sep-24
Dec-24
Mar-25
Jun-25
Sep-25
Dec-25
Graph 4. Central banks policy interest rates, %
BoE
FED (upper limit)
ECB (deposit facility rate)
Source:Bloomberg
Board of Directors’ Report as at 31.12.2025
9 | ANNUAL FINANCIAL REPORT
United Kingdom
GDP increased by 1.5%, on an annual basis, in the first nine months of 2025. The European Commission (Autumn 2025 Economic Forecast)
estimates that GDP will increase by 1.4% in 2025 and 1.2% in 2026. The Bank of England cut its policy rate three times in 2025, reaching 4%
from 4.75% in December 2024. Inflation based on the Consumer Price Index (including owner occupiers’ housing costs-CPIH), averaged 3.3%
in 2024, whereas, according to the European Commission (Autumn 2025 European Economic Forecast), it is expected to accelerate to 3.7% in
2025 before de-escalating to 2.6% in 2026.
STRATEGIC PLAN
The Group’s strategy aims on driving significant growth and value creation by leveraging on the identity of its franchise, its distinctive
positioning in highly specialized and profitable segments, its long-standing commitment to create shareholder value and its track record in
delivering on its promises.
Strategic Plan’s priority areas are profitability enhancement, balance sheet resilience preservation and capital generation and distribution. It
builds upon the successful implementation of the Group’s transformation programme and leverages the strengths of the Group.
The Group’s strategy is based on six clearly defined strategic pillars that encompass all Group’s business units:
a) Increase core revenues in retail banking, enhance productivity through automation and migrate core offering to digital channels,
reducing Cost to Income ratio
b) Adapt offering to attract a wider customer base across wealth management/private banking and other selected clients while investing in
technology to modernize service model
c) Reinforce position in wholesale lending, structured finance while at the same time expand the offering in investment banking, insurance
and factoring and ensure adequate returns for capital while growing fees and continuing to refine operating model, leveraging the
UniCredit commercial relationship.
d) Safeguard profitability in international activities by accelerating lending momentum, also through digital channels, capitalizing on
strengths in payments and wealth to grow fees, transform operations and increase productivity
e) Continue to selectively grow lending book while maintaining strong levels of liquidity.
f) Scale-up sustainable finance strategy to meet full market potential and deliver on firm ESG commitments. Incorporate ESG criteria i n
remuneration and risk-management framework and fully integrate sustainable finance strategy across business and operating model.
Furthermore, the Group will exploit excess capital to increase shareholder value by allocating capital resources to EPS accretive M&As and
enhancing current product offering across all operating regions.
The key financial priorities are summarized as per below:
Profitability
•
Significant business profitability improvement across Business units; continuous balance sheet de-risking allows for capital re-allocation
from NPA Unit to other businesses with significant profit generation potentials
•
Revenues increase on the back of a) strong NII performance, largely attributed to NII growth driven by volumes expansion and b)
growing fees and commissions on the back of product penetration initiatives and partnerships (Generali, UniCredit).
•
Cost management limiting inflation impact, and execution of initiatives targeting OpEx reduction in selected areas
Balance sheet
•
Diversified and resilient balance sheet also focusing on non-commercial book expansion when real-estate assets opportunities arise
•
Structural NPE reduction through organic and inorganic actions, lowering NPE ratio and improving coverage while further de-escalating
cost of risk
•
Diversified, granular and resilient deposit base
•
Optimize RWA(Risk Weighted Assets) allocation and liquidity towards non-commercial book expansion exploring selective real estate
and investment securities opportunities
Capital generation and distribution
•
Healthy capital generation on the back of strong returns
•
Maintain solid fully loaded capital ratios (FL CET1) across the period
•
Reward shareholders with gradual payouts increase at par with average European Banking levels.
ANALYSIS OF GROUP FINANCIAL INFORMATION
Following the Group’s decision to broaden its portfolio of investment properties at the Group level achieving higher levels of the related
income from such investments the Group has revised its accounting policy for investment properties. The change of accounting policy has
been applied retrospectively, resulting in the restatement of comparative figures, and has positively impacted the Group’s equity by Euro 28
million as of 31 December 2024, arising from the fair value measurement of investment properties.
In response to the challenges posed by the financial crisis in the preceding decade and subsequent fiscal austerity measures, the Group
initiated a restructuring programme in 2021 (Hive Down), along with a series of sale transactions aimed at disposing and managing its NPA
exposures. Having completed the restructuring program, the Group proceeded in the second quarter of 2025 to the Reverse Merger. Through
this corporate transaction, Alpha Services and Holdings was absorbed by the Bank, resulting in the Bank becoming the ultimate parent
company of the Group and effectively reversing the Hive Down executed in 2021. Since this was an inter-company transaction, the merger
had no financial impact on the Group, aside from IPO costs for listing the new shares issued by the Bank on the stock exchang e.
In 2025,the Group made strategic acquisitions including FlexFin S.A. (the first fintech company providing factoring services in Greece and
Cyprus), AXIA Ventures Group Ltd (which will be merged with Alpha Finance and Alpha Bank’s Investment Banking unit to create a leading
Investment Banking & Capital Markets platform in the region), and certain assets, liabilities, and key operational personnel from AstroBank via
its subsidiaries Alpha Bank Cyprus Ltd, Alpha Group Investment Company Ltd and Alpha Credit Acquisition Company Ltd. Through these
transactions the Group will strengthen its market presence and financial position in Cyprus, thereby enabling Alpha Bank Cyprus to
Board of Directors’ Report as at 31.12.2025
10 | ANNUAL FINANCIAL REPORT
consolidate its status as the third largest bank in the country. The acquisitions resulted in the recognition of Goodwill in line with IFRS 3 for
Euro 83 million. Details of the Group’s acquisitions can be found in Note 56 of the Financial Statements.
As of 31 December 2025, the Group’s Total Assets increased by Euro 5.4 billion, or by 7.4% compared to 31 December 2024, reaching Euro
77.5 billion. This growth was primarily attributable to the expansion of loans and advances to customers (Euro 3.7 billion), investments
securities (Euro 0.8 billion), and the acquisition of investment properties (Euro 0.3 billion) partially offset by the decrease in Held for Sale
assets.
Loans and advances to customers amounted to Euro 43.5 billion as of 31 December 2025 (31 December 2024: Euro 39.8 billion), resulting in a
loan-to-deposit ratio
1
of 78.9% (31 December 2024: 78%). The increase was driven mainly by net loan disbursements totaling Euro 3 billion
and the acquisitions of Flexfin and the loan portfolio of Astro Bank (Euro 653 million), and affected by the completion of the GAIA I & II
transactions which resulted in the retention of tranches of senior, mezzanine, and junior notes amounting to Euro 508 million, the
reclassification of Project Athena loans (Euro 191 million), including mainly non-performing collateralised and non-collateralised retail loans,
to Assets classified as held for sale, and the reduction in CLOs securities (Euro 70 million).
Investment securities amounted to Euro 17.6 billion as of 31 December 2025, up from Euro 16.8 billion as of 31 December 2024, reflecting a
4.5% increase attributable to the acquisition of higher-yielding HQLA securities that support the Group’s profitability and liquidity metrics, as
well as additional securities obtained through the AstroBank transaction.
Cash and balances with central banks increased by 15.7%, reaching Euro 3.5 billion as of 31 December 2025, compared to Euro 3.0 billion as of
31 December 2024.
Subsequent to the completion of the reverse merger, the Group leveraged Law 5193/2025, which allows for the transfer of carry-forward tax
losses from an absorbed entity to the absorbing entity. Consequently, as of 30 June 2025, deferred tax assets of Euro 245 million—previously
unrecognized by Alpha Services and Holdings—were recognized by the Bank as they have assessed as recoverable on the basis that they can
be offset against Bank’s tax profitability in the years 2025-2027, contributing to the overall increase in deferred tax assets compared to 31
December 2024. As of 31 December 2025, the Bank utilized Euro 36 million of these deferred tax assets
On the liability side, amounts due to customers, the primary source of the Group’s funding, of Euro 55.1 billion, increased by Euro 4.1 billion
or 8% compared to 31 December 2024. Approximately, half of the increase can be attributed to the acquisition of Astro Bank’s customer
liabilities. Moreover, amounts owed to other financial institutions remained stable at Euro 6.5 billion (31.12.2024: Euro 6.5 billion), as ECB
funding was replaced by increased funding from repurchase agreements (Repos). Debt securities in issue and other borrowed funds rose by
Euro 596 million compared to 31.12.2024, following the issuance of a Green Senior Preferred Bond for Euro 500 million and new subordinated
debt for an additional issuance of Euro 500 million. This was partially offset by the redemption of Lower Tier II Notes with principal amounts
of Euro 131 million on their call date on 13.02.2025 and Euro 362 million on 17.7.2025. .
The reverse merger was affected by the absorbing entity cancelling its existing share capital and issuing new shares at the same accounting
value as those of the absorbed entity. Any differences resulting from the elimination of Alpha Services and Holdings' investment in the Bank
against Alpha Bank’s share capital and other equity components, as well as the elimination of intra-group assets and liabilities, were allocated
to a designated equity reserve (Merger Reserve). On 14.10.2025, the supervisory authorities approved the offsetting of the merger reserve
with other equity components. Such an offset is subject to the approval of the Annual General Assembly Meeting expected to take place in
2026.
The Group’s Total Equity amounted to Euro 8.8 billion as at 31.12.2025, increased by Euro 604 million compared to 31.12.2024, mainly due to
the results of the year (Euro 943 million) less the dividend coupon payments for the Additional Tier 1 instruments (Euro 70 million), the
payment of cash dividends to shareholders for the 2024 results (Euro 71 million), the payment of interim cash dividend to shareholders for
the 2025 results (Euro 111 million), the purchases of treasury shares as part of the shareholder remuneration and the staff remuneration
programme (Euro 115 million) and expenses recorded in equity in relation to corporate transactions (Euro 3 million).
The Total Capital Adequacy Ratio of the Group as of 31.12.2025 stands at 20.6% (31.12.2024: 21.9%), allowing the Bank and the Group to
operate well above its capital requirements. It is noted that Group’s capital ratios already include a provision for the 2025 dividend to be
distributed upon the approval by the General Shareholders Meeting, in accordance with the distribution policy. Excluding the provision for
dividend payout, capital ratios increased by c. 206 bps and the Total Capital ratio would stand at 22.7%.
Regarding the results of the year ended 31.12.2025, the Group’s net profits after income tax amounted to Euro 943 million (31.12.2024: Euro
654 million). Below are the main drivers for the results of 2025:
•
Net interest income stood at Euro 1,598 million (31.12.2024: Euro 1,645 million), presenting a decrease of 3% versus the comparative
period. The decrease is mainly attributed to the gradual decline in interest rates that has affected interest income from loans, partially
compensated for by the respective decline in cost of funding.
•
Net fee and commission income for the period was Euro 476 million (31.12.2024: Euro 420 million) showing an increase of 13%,
attributed mainly to increased fees from assets under management and mutual funds and increased commissions of loans and credit
cards following the new agreement with Visa, partially counterbalanced by lower transaction income due to the introduction of Law
5167/2024 that led to lower fees for outgoing and incoming SEPA transfers.
•
Gains less losses on financial transactions for 2025 amounted to a profit of Euro 18 million (31.12.2024: gains of Euro 80 million).
“Gains less losses on financial transactions” for the year 2025 has been reduced compared to 2024 mainly due the following:
o Lower results for Equity Securities measured at fair value through profit or loss (2025 losses of € 1 million compared to gains, of €
18 million for 2024).
o Lower result from the derivative financial instruments (2025 losses of € 6 million, compared to gains of € 40 million for 2024).
1
Τhe loan to deposit ratio is presented in Appendix of the Βoard οf Directors’ Management Report.
Board of Directors’ Report as at 31.12.2025
11 | ANNUAL FINANCIAL REPORT
o Lower gains from Foreign exchange differences (2025 gains of € 16 million, compared to gains of € 25 million for 2024).
•
Net income from investment property amounted to Euro 17 million (31.12.2024: loss Euro 3 million) as a result of higher fair values and
increased rental income following the expansion of the investment property portfolio.
•
Other income was affected mainly by higher dividend income in 2025 for Euro 23 million (31.12.2024: Euro 6 million) and share of
profit from associates Euro 43 million (31.12.2024: loss for Euro 3 million) mainly due to a full year’s results from Unicredit Romania.
•
Operating expenses for the period amounted to Euro 850 million (31.12.2024: Euro 852 million) and are analyzed as follows:
➢ Staff costs of Euro 374 million (31.12.2024: Euro 370 million) increased by Euro 4 million mainly due to to a) salary increases and
the new Sectoral Labor Agreement which was signed on the second quarter of 2025 and among others, provides for additional
employee remuneration linked with the Bank’s annual profits and b) the acquisition of Astro Bank.
➢ General and administrative expenses of Euro 345 million (31.12.2024: Euro 308 million) increased mainly due to IT expenses and
maintenance of IT equipment, third party fees and tax and duties.
➢ Depreciation and amortization of Euro 131 million (31.12.2024: Euro 174 million) decreased due to a significant amount of
intangible assets being fully amortised by December 2024 and the write down of intangible assets during the year.
•
Impairment losses and provisions to cover credit risk amounted to Euro 316 million (31.12.2024: Euro 360 million), representing a 12%
decrease compared to 2024, and include impairment losses of Euro 127 million for the NPEs loan portfolio included in assets held for
sale (including the new transaction for Athena loans that were classified as held for sale on 30.6.2025). The underlying cost of risk stood
at Euro 189 million (31.12.2024: Euro 145 million)
1
and includes additional losses of Euro 114 million impairment in relation to retail
loans in order to capture the expected impact from potential management actions that will further reduce risk of redefault in the future
and Euro 11 million impairment for loans denominated in CHF.
•
Impairment losses on fixed assets and equity investments for 2025 amounted to Euro 52 million (31.12.2024: Euro 13 million) and
include mainly impairment losses for intangible assets for Euro 38 million that are no longer in use in the context of IT tra nsformation
activities.
•
Gains/ (Losses) on disposal of fixed assets and equity investments for 2025 amounted to gains of Euro 7 million (31.12.2024: Euro 27
million gain) and include losses from the disposal of real estate assets for project Skyline.
•
Provisions amounted to Euro 13 million (31.12.2024: Euro 85 million) and include Euro 25 million costs for the extension of the Marietta
Giannakou school renovation programme as well as the reversal of Euro 20 million indemnity liability provisions for past NPA sale
transactions that were expired as of 31.12.2025 and therefore the related provision has been released. .
•
Income tax for period ended 31.12.2025 amounted to a tax credit for Euro 15 million (31.12.2024: tax losses 221 million) and includes
Euro 210 million gain from the accounting recognition of previously unrecognized tax losses of Alpha Services and Holdings, following
the reverse merger and a charge of Euro 4 million for the Pillar II framework.
•
Net profit/(loss) after income tax from discontinued operations for Euro 24 million (31.12.2024: Euro 57 million) is mainly attributed to
the results of subsidiary Alpha Life, whereas the comparative figure included also the results of Alpha Bank Romania, that was disposed
in November 2024.
Since the Group has committed to specific targets through the announcements of the updated strategic plan, the Management monitors the
normalized gains/losses of the Group against the targets it has set, in order to monitor the implementation of the business plan. The
Normalized Results do not include results that are not related to the normal course of business activities or that are not repetitive in nature.
Indicatively, the main income and expense items that are excluded for purposes of the normalized profit calculation are listed below:
• Transformation costs;
• Results due to divestment of non-core assets and results of transactions of Non-Performing Exposures;
• Results with a short-term impact or arising from unexpected or exceptional events with a significant economic impact;
• Initial (one-off) impact from the adoption of new or amended International Financial Reporting Standards (IFRS);
• Tax-related one-off expenses and gains/losses.
The normalized profits for 2025 reached Euro 907 million against Euro 861 million in the comparative period of 2024. An analysis of the
normalized profits is presented in the Appendix of the Βoard οf Directors’ Report
SIGNIFICANT EVENTS OF YEAR 2025
• On 27.1.2025, the Group's subsidiary, Alpha Holding S.A., entered into a binding agreement for the acquisition of 100% of the shares of
Flexfin LTD, based in Cyprus, which is the sole shareholder of FlexFin S.M.S.A., based in Greece, with the aim of merging its Greek
factoring activities with ABC Factors. Flexfin is the first fintech company active in the provision of factoring services in Greece and Cyprus,
specializing in liquidity solutions tailored to small and medium sized businesses. Through its innovative platform, it offers convenience,
speed, flexibility and transparency. Facilitating SME access to sufficient financing is a key strategic priority for Alpha Bank, thus the
acquisition and subsequent merger of Flexfin with ABC Factors represents a decisive step towards this goal. With a priority focus on
enabling financing through factoring of SMEs – a crucial pillar of the Greek economy - the merged company will significantly contribute
to SME operational efficiency and growth and consequently to jobs creation. The integration of Flexfin is expected to significantly expand
ABC Factors’ customer base in the Greek market, with financing targets likely to exceed Euro 1 billion in the coming years. The
transaction of the acquisition of 100% stake in FlexFin Ltd, 100% parent company of Flexfin S.M.S.A. by Alpha Holding S.A. was
completed on 5.8.2025.
1
Τhe cost of risk is presented in Appendix of the Βoard οf Directors’ Report.
Board of Directors’ Report as at 31.12.2025
12 | ANNUAL FINANCIAL REPORT
• On 31.3.2025 the Group announced the agreement on the key commercial and legal terms for the acquisition of AXIA Ventures Gro up
Ltd. An agreement has been reached with the founding and main shareholders of AXIA Ventures Group Ltd (“ΑΧΙΑ”) on the key fin ancial
and legal terms for the acquisition of the entire (and in any case not less than 95%) issued share capital of AXIA (the “Transaction”). The
Transaction will include the combination of AXIA with Alpha Finance Investment Services S.M.S.A. (“Alpha Finance”), the investment
services subsidiary of Alpha Holding, as well as the Bank’s Investment Banking unit, reinforcing the Group’s strategic objective of
enhancing fee and commission income generation and diversification of income sources while also significantly strengthening the
product offering for corporate clients. The combination of AXIA with Alpha Finance teams is expected to create a prominent investment
banking platform in Greece and Cyprus offering best-in-class, tailor-made and investment banking services. The transaction of the
acquisition of 100% of the issued share capital of AXIA by Alpha Finance was completed on 04.08.2025, with the signing of the definitive
share purchase agreement.
• On 15.5.2025, it was announced that Scope Ratings has been mandated as a new credit rating agency for the Bank, assigning an Investment
Grade rating of BBB /Stable. The new Investment Grade rating by Scope Ratings reflects Alpha Bank’s leading franchise an d market
positioning in Greece, a strengthened balance sheet, sustainable earnings power and capital generation capacity, as well as the significantly
improved asset-quality metrics and sound funding and liquidity position. The rating adds another Investment Grade rating to Alpha Bank’s
credit profile, complementing the upgrade by Moody’s to Baa2 in March 2025. The decision to appoint Scope Ratings aligns with Alpha
Bank’s broader strategic objective to enhance its interconnectedness within Europe, its unwa vering support for EU institutions (Scope is
today the only European rating agency holding Eurosystem Credit Assessment Framework status since 2023 and has been ESMA registered
since 2011) and its commitment to enhancing the development of European capital markets.
• On 22.5.2025, Alpha Bank and Visa announced a multi-year exclusive strategic partnership. The two leading organizations in the financial
sector and payment technology announced the expansion of their long-term partnership, initiating a new era in the payments sector in
Greece. With the aim of upgrading the Bank's products and services to individuals and businesses, Alpha Bank is expanding its strategic
agreement with Visa, which is expected to accelerate the digital transition and enhance the growth of digital payments in Greece. Through
this new partnership, Alpha Bank will offer a range of new products and services, with the aim of helping its customers better manage their
finances and lifestyle needs. The partnership is expected to modernize payment services, as the two companies, through their joint action,
will make available innovative solutions that enhance the security and ease of transactions. At the same time, leveraging Visa's technology,
global scale and strong risk management capabilities, Alpha Bank will offer advanced digital banking capabilities that will meet the ever-
evolving needs of the market.
• On 6.6.2025, in accordance with the Strategic Plan of the Group for the decrease of the non- performing exposures, the Group completed
the sale of two Non-Performing Loan Portfolios (GAIA I and GAIA II transactions) through a securitization structure in accordance with the
Greek securitization framework (L.3156/2003) and the Hellenic Assets Protection Scheme (L.4649/2019), as amended and in force. The
transactions were performed by transferring the respective loan portfolios to the special purpose vehicles Gaia Securitization DAC and
Gaia II Securitization DAC, which were established for this purpose and by issuing notes initially covered by the Group. The Group retained
100% of the senior notes and 5% of the mezzanine and junior notes of the special purpose entities and transferred the rest 95% of the
mezzanine and junior notes to third party investors.
The aforementioned transactions include:
➢ a perimeter of loans with a carrying value before impairments as of 31.12.2024 of Εuro 464 million, mainly comprising of non–
performing mortgage exposures (“GAIA I”).
➢ a perimeter of loans with a carrying value before impairments as of 31.12.2024 of Εuro 565 million mainly comprised of Small
Businesses and SME/Large corporate NPE exposures (“GAIA II”).
•
As announced on 16.06.2025, Alpha Bank S.A. has purchased 12,705,745 ordinary shares with voting rights of Prodea, a real estate
investment company listed in the Athens Stock Exchange increasing its equity stake from 4.90% to 9.87% of the total share capital of
Prodea by possessing 25,224,977 ordinary shares with voting rights. Alpha Bank has performed this transaction as part of its strategy to
further diversify its income sources, targeting to grow recurring income from yielding real estate assets with predictable cash flows.
•
On 24.6.2025, it was announced that the subsidiary Alpha Bank Cyprus Ltd ("Alpha Bank Cyprus”) entered into a definitive Bus iness
Transfer Agreement with AstroBank Public Company Limited (“AstroBank’”) for the acquisition of substantially the whole of AstroBank’s
assets, liabilities and personnel (the “Transaction”). The acquisition was completed by Alpha Bank Cyprus along with other e ntities of the
Group of Alpha Bank S.A. on 31.10.2025. The Transaction is fully aligned with the Group’s strategic objecti ve of strengthening its market
presence and financial position in Cyprus, while following the completion of the Transaction, Alpha Bank Cyprus is expected to consolidate
its position as the third largest bank in Cyprus, delivering a material increase in its recurring profitability.
• On 27.6.2025 the merger by absorption of “Alpha Services and Holdings S.A.” (hereinafter the “Company”) by Alpha Bank pursuant to the
applicable legislation, has been completed (the “Merger”). As a result, Alpha Bank was substituted ipso jure, in its capac ity as a universal
successor, in all assets and liabilities of the Company, while the latter was dissolved without liquidation and ceased to exist, whereas its
shares have been delisted from the Athens Stock Exchange (hereinafter “ATHEX”). Alpha Bank’s sh ares issued in the context of the Merger
were admitted to trading to the Main Market of the regulated market of the ATHEX and the shareholders of the Company became
shareholders of Alpha Bank with the same number of shares they held prior to the Merger. The hive-down of the banking operations sector
in 2021, followed by its transfer to a newly established, wholly owned subsidiary, marked the final step in a series of strategic actions
designed to permanently resolve legacy issues. This milestone initiated a four-year period during which the Bank effectively isolated non-
performing exposures arising from the financial crisis, thereby significantly enhancing financial resilience. This critical restructuring enabled
the Group to restore balance sheet strength, reinforce capital adequacy, and sharpen its strategic focus on core banking activities, client
support, and contributing to the recovery of the Greek economy. These efforts were further supported by a disciplined program of targeted
acquisitions and partnerships, aimed at accelerating growth and strengthening market positioning.
The successful completion of the reverse merger signals the formal transition from a phase of balance sheet restructuring and operational
transformation to a new era focused on sustainable value creation, strategic agility, international orientation, and enhanced
competitiveness.
• Since the beginning of 2025, Alpha Bank's strategic collaboration with UniCredit in mutual fund distribution has continued to evolve
successfully. Under the agreement, Alpha Bank distributes UniCredit’s OneMarkets Funds, along with other funds managed by U niCredit
or its joint ventures, through its network in Greece.
Board of Directors’ Report as at 31.12.2025
13 | ANNUAL FINANCIAL REPORT
Assets under management in OneMarkets Funds reached Euro 1.1 billion by end 2025, up from Euro 242 million at the end of 2024. This
growth reflects strong client demand for a curated range of mutual fund solutions, including well-known fund houses such as Fidelity and
Capital Group, many of which are exclusively available in the Greek market via Alpha Bank.
Client engagement activity across Private Banking and Alpha Gold Personal Banking, combined with joint initiatives such as investment
insights, marketing campaigns, the onemarkets.gr platform, and dedicated client events, have contributed to broadening the reach of
the OneMarkets Fund offering despite global markets volatility.
Looking ahead, Alpha Bank is committed to further strengthening the collaboration with UniCredit through the introduction of additional
investment solutions in 2026 like Certificates and by continuing co-branded marketing efforts and thematic client events.
This partnership complements Alpha Bank’s open architecture model, which ensures access to a wide range of high-quality investment
products, including the Bank’s own asset management solutions and selected third-party offerings.
• Alpha Bank issued on 23.7.2025 a new subordinated bond with a nominal value of Euro 500 million maturing on 23.7.2036, callable in 6
years and with a fixed annual coupon of 4.308%, which is adjusted to a new coupon applicable from the call date until maturity,
determined on the then prevailing swap rate plus a margin of 1.93%.
• In October 2025, Alpha Bank has successfully completed the pricing of a Green Senior Preferred Bond of Euro 500 million, attracting
demand that exceeded Euro 3 billion through an international bookbuilding process. This transaction marks Alpha Bank's first issuance
since regaining investment grade status, representing a strong vote of confidence in its strategy, financial position, and growth
prospects, which are further enhanced by the extroversion fostered in the context of its strategic partnership with UniCredit. The new 6-
year bond, callable after 5 years, carries a coupon of 3.125%. The final yield of 3.202% corresponds to a credit spread of 92 basis points
above the corresponding midswap, representing the lowest spread ever achieved for a senior preferred bond issuance of similar duration
by a Greek bank. The proceeds from the issuance will be used to support the financing of green investments, thus reinforcing Alpha
Bank's commitment to sustainability as a fundamental pillar of its strategy.
• On 5.12.2025, in the context of the Bank’s strategy for the active management of Non-Performing Exposures, the Group completed the
disposal to Waterwheel Capital Management, L.P., acting through affiliated entities (“Waterwheel Capital”), of a pool of Non-Performing
Loans to Greek Small and Medium-sized Enterprises (the “Portfolio”), with a total gross book value of approximately Euro 0.45 billion as of
31.12.2024. It is noted that the Portfolio was included in the Solar transaction initially structured as part of a joint initiative from the Greek
banks for a securitization transaction under Law 4649/2019, as in force, which was not consummated.
• Alpha Bank, in December 2025, has announced strengthening of its Executive Committee following the successful acquisition of AXIA, in
view of reinforcing its capacity to drive sustainable growth, strengthen risk governance, and unlock new value creation opportunities. Key
enhancements include the establishment of a dedicated Investment Banking area that integrates AXIA, Alpha Finance and existin g
investment banking activities under a single platform, led by Mr. George Linatsas as Chief of Investment Banking and Executive Committee
member and the appointment as Chief Risk Officer of Mr. Konstantino Sarafopoulo, who also joins the Executive Committee, succeeding
Mr. Spyros Andronikakis.
• On 19.12.2025, Alpha Bank S.A. announced that it has reached an agreement on the key commercial and legal terms for a strategic
combination of insurance activities in Cyprus between Universal Life Insurance Public Company Ltd. (“Universal”) and Altius Insurance Ltd.
(“Altius”). In particular, Alpha Bank has agreed (i) to acquire the entire issued share capital of Altius, and (ii) with the majority of the
shareholders of Universal for the merger of Universal and Altius into a single combined insurance entity (the “Combined Entity”), and for
arrangements, pursuant to which a member of Alpha Bank Group will acquire a majority interest in the Combined Entity. The Transaction
is fully aligned with the Bank’s capital allocation policy and is expected to generate strong financial returns while enhancing the quality,
diversification and resilience of the revenue base. Completion of the transaction is expected in the third quarter of 2026, subject to receipt
of all necessary regulatory approvals and fulfillment of customary conditions precedent.
In December 2025, a binding agreement was executed for the sale of a perimeter of loans with a carrying value before impairments of c.
Euro 0.1 billion as of 30.06.2025, comprised of Cypriot mainly secured NPE portfolio exposures. The transaction is envisaged to be
completed within 2026.
GENERAL MEETINGS OF SHAREHOLDERS IN 2025
Alpha Bank
During 2025, the Bank held one Ordinary and two Extraordinary General Meetings. The Extraordinary General Meeting on 30 April, 2025,
approved the listing of all common, registered shares of the Bank on the Main Market of the Athens Exchange. The Ordinary General Meeting
on 21 May, 2025, approved the distribution through dividend of Euro 70,259,328.43 in cash and Euro 13,402,212 to Staff from the Bank’s
2024 net profits and the continuation of the Stock Option Plan. The Extraordinary General Meeting on 12 June, 2025, approved, among other
things, the merger by absorption of Alpha Services and Holdings S.A. by the Bank, including the relevant Merger Documentation and Share
capital increase and decrease by reason of the Merger. It also approved the establishment of a Share Buyback Program and a Stock Award
Plan, as well as authorization to the Board of Directors for their implementation.
Alpha Services and Holdings
From 1 January, 2025 and till the merger by absorption of Alpha Services and Holdings S.A. by Alpha Bank on 27 June, 2025, one Ordinary and
one Extraordinary General Meeting were held. The Ordinary General Meeting on 21 May, 2025, among other things, approved the
distribution in cash of Euro 70,259,328.43 to the Shareholders through the cash payment of Euro 0.03 per share. The above proposal is
combined with the proposal of a Share Buyback Program, serving any and all purposes permitted by applicable laws and the regulatory
framework, including the acquisition of own shares and subsequently their cancelation, thus increasing the value per share, as part of the
overall distribution of dividend to the Company’s Shareholders taking into consideration the Company’s Shareholder Remuneration Policy. It
is noted that, for the above purpose, own existing, common, registered shares corresponding to the amount of Euro 210,777,985.29 will be
acquired under the Share Buyback Program. Additionally, the Ordinary General Meeting approved the distribution of Euro 48,235 from the
Company’s intragroup dividend to Staff and up to Euro 14.5 million by Group Companies to their eligible Staff. The Ordinary G eneral Meeting
approved the early termination of the previous Share Buyback Program, approved in 2023 and amended in 2024, and the establishment of a
new Share Buyback Program under Article 49 of Law 4548/2018. Moreover, amendments to the Company’s Stock Award Plan were also
Board of Directors’ Report as at 31.12.2025
14 | ANNUAL FINANCIAL REPORT
approved and authorized the Board of Directors for its implementation. The Extraordinary General Meeting on 23 June, 2025, approved the
merger by absorption of Alpha Services and Holdings S.A.by Alpha Bank S.A., the Merger Agreement and the Merger Documentation.
RISK MANAGEMENT
The Group has established a framework for the thorough management of risks, based on best practices and regulatory requirements. This
framework, based on the common European legislation and the current system of common banking rules, principles and standards, is
improving continuously over time and is applied in the daily conduct of the Group’s activities within and across borders, making the corporate
governance of the Group effective.
Since November 2014, the Group falls under the responsibility of the Single Supervisory Mechanism (SSM) – the financial supervision system
which involves the European Central Bank (ECB) and the Bank of Greece – and as a significant banking institution is directly supervised by the
ECB. The SSM operates jointly with the European Banking Authority (EBA), the European Parliament, the Eurogroup, the European
Commission and the European Systemic Risk Board (ESRB), within the scope of their respective competences.
The applicable banking regulatory framework in the European Union (EU), i.e., the Basel III capital framework, is effective as of 1 January,
2014. The said framework entered into force through Regulation (EU) No 575/2013 on “prudential requirements for credit institutions and
investment firms” (the “Capital Requirements Regulation” or the “CRR”) published on 27 June, 2013, in conjunct ion with Directive
2013/36/EU on “access to the activity of credit institutions and the prudential supervision of credit inst itutions and investment firms” (the
“Capital Requirements Directive IV” or the “CRD IV”) published on 27 June, 2013 that has been transposed into the Greek legis lative
framework by Law 4261/2014. The framework was amended by Regulation (EU) No 2019/876 (CR R II) of 20 May, 2019 and Directive (EU)
2019/878 (CRD V) of 20 May, 2019. The latter has been transposed into the Greek legislative framework by Law 4799/2021.
The adoption of the Capital Requirements Regulation (CRR III), applicable from 01.01.2025, introduces a series of significant changes to the
regulatory framework established under CRR 2, particularly in the context of standardized approaches to credit risk, market risk, operational
risk and CVA (Credit Valuation Adjustment) risk. These modifications aim to enhance the resilience of financial institutions while ensuring greater
consistency and comparability across jurisdictions.
The transition from CRR 2 to CRR 3 reflects the European Union’s commitment to implementing the final Basel III reforms (Basel IV). CRR 3 aims
to:
• Enhance the risk sensitivity of prudential frameworks.
• Improve the comparability and transparency of financial institutions’ risk profiles.
• Promote a more resilient banking system capable of withstanding economic shocks.
Regarding CRD VI, European Union (EU) member states have 18 months to incorporate the Directive into their national legislation, after which
CRD VI will take effect the next year, on 1 January, 2026. The Fundamental Review of the Trading Book (FRTB) has been postponed to 1 January,
2027, by the European Commission. This delay is part of a broader effort to maintain the competitiveness of EU banks in global capital markets
and to align with international standards. The FRTB aims to introduce more sophisticated risk measurement techniques, allowing for a closer
alignment between capital charges and the actual risks banks face in their trading operations.
For the implementation of the aforementioned regulatory package, the EBA has around 140 mandates from CRR III and CRD VI to develop Level
2 and Level 3 legislation (RTS, ITS, and guidelines) to facilitate the application of the regulations. Of particular importance is the EBA's final
report on the Implementing Technical Standards (ITS) for entity disclosures, which were approved by the Commission and published in the OJEU
as a Regulation at the end of December, and which include changes to the Pillar 3 framework. These changes encompass new and revised
disclosure requirements for the output floor, crypto-assets , credit valuation adjustment (CVA) risk, credit risk, market risk, and operational risk,
as well as minor modifications to the leverage ratio. These ITS are applicable from 1 January, 2025. Moreover, the EBA has already published
several consultations in 2024 regarding credit risk (off-balance-sheet items, default definition, etc.), market risk, operational risk, sustainability,
and reporting and disclosures, for which the final text is still pending publication.
The Group determines and reviews its risk-taking strategy by (a) the determination of the extent to which the Group is willing to undertake
risks (risk appetite), (b) the assessment of potential impacts of the development strategy activities on the definition of the risk appetite limits,
so that the relevant decisions combine the anticipated profitability with the potential losses and (c) the development of appropriate
procedures for the implementation of this strategy through a mechanism which allocates risk appetite responsibilities among the Group
Units.
Specifically, the Group, considering the nature, the scale and the complexity of its activities, as well as the risk profile, develops a risk
management strategy based on the following three lines of defense:
• 1
st
line of defense Units (process owners) have the primary responsibility to own and manage risks associated with day-to-day operational
activities.
• 2
nd
line of defense Units, comprising the areas of Chief Risk Control Officer and the Risk Models & Data Validation Business Area. 2nd line
of defense units operates independently from the other lines of defense and report to the Chief Risk Officer, who in turn reports
functionally to the Board of Directors through the Risk Management Committee. Their function is complementary to the controlling
banking business of the first line of defense in order to ensure objectivity in the decision-making process, to measure the effectiveness of
these decisions in terms of risk undertaking, to design and execute the Risk Appetite Framework and the risk strategy, and to ensure
compliance with the applicable legislative and institutional framework, by monitoring the internal regulations and ethical standards as well
as to display and evaluate the total exposure of the Bank and the Group to risk, based on the established guidelines.
The Risk Model and Data Validation Business Area, provides an independent oversight from a second line of defense perspective, on the
alignment with Risk Data Aggregation and Risk Reporting (RDARR) and BCBS239 principles, as well as the European Banking Authority (EBA)
expectations, IFRS 9 regulatory requirements, and internationally recognized best practices for Risk Models.
• The Internal Audit constitutes the third line of defense. The Internal Audit is an independent function, reporting to the Audit Committee of
the Board of Directors, and audits the activities of the Bank and the Group, including the activities of the Risk Management Function.
Credit Risk
Credit Risk arises from the potential failure of debtors’ or counterparties to meet all or part of their payment obligations to the Group.
The primary objective of the Group’s strategy for credit risk management, in order to maximize the risk-adjusted return, is the continuous,
timely and systematic monitoring of the loan portfolio and the maintenance of credit exposures within the framework of acceptable overall
Board of Directors’ Report as at 31.12.2025
15 | ANNUAL FINANCIAL REPORT
risk undertaking limits. At the same time, the conduct of daily business within a clearly defined framework of granting credit, supported by
specific credit criteria, is ensured.
Τhe Group’s credit risk management framework is being developed based on a series of credit policy procedures as well as systems and
models for measuring, monitoring and controlling credit risk. These models are subject to an ongoing review process in order to ensure full
compliance with the current institutional and regulatory framework and their adaptation to the respective economic conditions and to the
nature and extent of the Group’s business.
Under this perspective and in order to further strengthen and improve the credit risk management framework during 2025, the following
actions were implemented:
• Update of the Credit Policy Manuals for Retail Banking (Housing and Consumer Lending, Small Business Banking) and Wholesale Banking,
taking into account the regulatory guidelines on credit risk management issues and the Group’s business strategy.
• Update of the Group Credit Risk Control Framework in order to ensure compliance with Credit Risk Policies at Bank and Group level.
• Enhancement of credit risk models, where needed, to keep them up-to-date and expand applicability, including but not limited to Climate
Risk.
• Update of the Credit Rating System User’s Manual in order to capture the new ESG implementations in Credit Rating System.
• Ongoing validation of the Risk Models in order to ensure their accuracy, reliability, stability and predictive power
• Benchmarking key risk indicators with the use of EBA risk dashboard.
• Update of a Risk Data Aggregation and Risk Reporting Validation Framework that provides guidance for the assessment - as a second line
of defense - of the accuracy, completeness and consistency of the procedures and controls across the whole range of the directives of
Basel Committee on Banking Supervision's (BCBS239) and of ECB for all types of risk.
• Update of the Concentration Risk and Credit Threshold Policy regarding the maximum acceptable credit limits for large bus iness groups
as
well as the applicable provisions regarding the override of the credit limits thresholds per credit risk rating zone.
• Update of the Credit Risk Early Warning Policy regarding the introduction of new and updating of existing credit risk early warning triggers
as well as the update of the frequency of specific credit risk early warning triggers.
• Update of the Loan Collateral Policy regarding the update of the type of inspection required during the approval process for a new loan
secured by a new or existing property, the enrichment of the cases of ad hoc real estate revaluations, the introduction of the Quality
Assurance process to conduct second level controls and the introduction of criteria for the acceptance of appraisal companies operating
outside Greece and Cyprus.
• Update of the Group Loan Impairment Policy regarding the update of the quantitative and qualitative indicators used in assessing an
exposure for whether it shows Significant Increase in Credit Risk, the update of the expected cash flow calculation methodology (DCF) used
in the individual impairment assessment and the enhancement of the Post Model Adjustments application process.
• Update of the Retail Banking Arrears and Forbearance Policy regarding the update of the framework for managing arrears and assessing
the settlement of debts of the Bank's staff and the update of affordability assessment.
• Update of the Wholesale Banking Arrears and Forbearance Policy regarding the introduction of a framework for Leveraged Transactions to
Non-Performing Borrowers.
• Update of the Group Loan Default Classification Policy regarding the introduction of new and update of existing UTP triggers, enhancement
of the definition of forborne exposures and enrichment of the indications of financial difficulty for Retail Banking exposures.
• Update of the Recovery and Resilience Facility (RRF) program Bank’s Policy regarding the time of finalization of the pre-screening controls
and the possibility to finance on an exceptional basis Small Businesses start-ups classified in the credit risk zone “Moderate Risk – Watch
List” when the request concerns viable investment plans and simultaneously the stipulated criteria are met.
• Update of the Climate Related, Environmental, Social and Governance Risk Management Policy on Group’s Business Lending in ord er to
allow finance of the defense sector up to a certain cap for conventional weapons related activities in accordance with the “D efense Sector
Financing Policy”, to remove the disclosure obligations to EBRD after its disinvestment from Alpha Bank’s share capital and t o amend the
definition of the critical industry sectors connected with potential climate and ESG risks following the relevant amendment of the
Wholesale Banking Credit Manual.
• Participation of the Credit Control Business Area in the Retail Banking Arrears Committees without voting right but with veto right on
forbearance requests with multiple forbearance measures falling under the perimeter defined in the Management Arrears Act.
• Provision of a risk opinion at the Wholesale Banking II Credit Committee, in addition to the opinion provided at the Whol esale Banking
Credit Committee, on concentration issues and adherence to Credit Risk Policies.
• Establishment of quality control assessment as regards the real estate made available as loan collaterals as well as the owned by the Bank
and Group Companies, and provision of a risk opinion to the competent Committees. Control and assessment of real estate impairments
owned by the Bank and the Group Companies.
• Periodic conduct of stress test exercises as a tool for assessing the impact of various macroeconomic scenarios on the business strategy
formulation, the business decision-taking and the Group’s capital position. The stress tests are conducted in accordan ce with the
requirements of the regulatory framework and constitute a key component of the Group’s credit risk management strategy.
Environment, Social and Governance (ESG) Risks
The Group adopts a proactive approach to the management of Environmental, Social and Governance (ESG) risks, with particular emphasis on
risks arising from climate and environmental change, which is a key component of its Risk Management Strategy.
The Group, acknowledging the relevance and potential impact of the risks stemming from climate, environmental and social related factors,
and especially climate change, and as part of its plan and in alignment with the respective external guidelines, has elaborated further on the
ESG incorporation into the risk identification and materiality assessment processes and in the overall risk management framework, and is
committed to monitor, assess, and manage these risks going forward and further enhance its policies and procedures, where deemed
necessary. Leveraging on the work already performed in previous years the Bank proceeded with targeted enhancements during 2025 in
accordance Group’s ESG plan commitments. More specifically, the following activities have been performed following the EBA final
guidelines:
i. The Bank designed and implemented a dedicated internal report including ESG metrics for loans and advances, which is presente d
on a quarterly basis to the Group Sustainability Committee and the RMC (Risk Management Committee), and through the RMC, to
the Board members.
Board of Directors’ Report as at 31.12.2025
16 | ANNUAL FINANCIAL REPORT
ii. ESG-related considerations have been integrated into the Group's Remuneration Policy, aligning executive compensation with
environmental and sustainability goals. Active participation of the risk management function in the target setting and remuneration
process to ensure fulfillment of the supervisory expectations with regards to the implementation of sound remuneration practices
which do not encourage excessive risk taking or lack of controls. In detail, the risk management function review and opine on:
o The Business Unit Balanced scorecards to verify the effective coverage of the most important strategic priorities of the
Group, as well as the sufficient inclusion of risk & control aspects at the Business Unit level.
o The Senior Executives and Key Financial Holders’ APD individual scorecards to ensure that there are included quantitative
risk related KRIs, as well as targets based on RAF which promote further alignment with the Risk Appetite Framework of
the organization.
o The Material Risk Takers’ identification process by reviewing and assessing both the criteria applied in the context of the
process as well as the business areas identified to be included in the “Material Risk Takers” list and the Material Risk takes
list per se.
o How the remuneration policy and specifically the variable remuneration structure is affected by and related with the risk
profile, risk culture and risk appetite of the Bank, as well as supports the HR function with regards to the Policy and the
incentive system for risk related components by validating and assessing specific aspects of the policy.
iii. The second risk culture measurement Survey completed successfully and the results will be presented within Q1 2026.
iv. The Bank updated the perimeter of the Reputational Risk questionnaire aligning with new criteria described by the Omnibus
Regulation. Additionally, the Bank updated the method of sending the questionnaire with an online link in order to facilitate obligors
and automate the process of assessment.
v. The Bank delivered several internal ESG trainings to the 1
st
Line of Defense (LoD) Wholesale Relationship Managers regarding the
Physical Risk assessment and the ESG Overall Assessment of obligors including ESG Obligor Assessment, Transaction Assessment
and Reputational Risk Assessment.
vi. The Bank has centralized data related to the CPRS sector (Climate Policy Relevant Sectors) and Physical Risk assessment on obligor
and real estate level, ensuring both credit assessment and reporting needs are efficiently met.
vii. The Bank completed the process of integrating ESG considerations in the due diligence process of Debt Securities.
viii. Ιn the context of the Internal Capital Adequacy Assessment Process (ICAAP Report), enhancements in the Bank's Climate and
Environmental Stress Test Framework were undertaken during 2025 to
a) extend the applicable perimeter of obligors analysed at counterparty level,
b) provide additional breakdown of sectoral inputs to models further aligning them with the ESG Risk Materiality assessment
c) adoption of newly published Network of Central Banks and Supervisors for Greening the Financial System NGFS short-term
scenarios and
d) the introduction of long-term Nature scenarios.
The Bank aligned with International best practices, has developed climate risk-specific methodologies to estimate the impact of:
•
transition on credit risk across different time horizons (short, medium and long term) by making use of leading global
macroeconomic and sectoral models. Additional characteristics such as buildings’ energy efficiency, geographic and
counterparty level characteristics are also incorporated in the estimation to further account for heterogeneity of impacts
inherent in climate risks. These are examined as stand-alone climate scenarios and used under both the Economic and
Normative perspective. Where applicable these scenarios are also applied on operational risk and business & strategic risks
considering the relevant risk materiality assessment that has been performed.
o
physical risk (chronic and acute risks – specifically flood and wildfire) on credit risk across different time horizons (short,
medium and long term) by making use of leading global macroeconomic and sectoral models, as well natural catastrophe
models for Greece. Additional characteristics such as geographic and counterparty level characteristics are also incorporated in
the estimation to further account for heterogeneity of impacts inherent in climate risks. These are examined as stand-alone
climate scenarios and used under both the Economic and Normative perspective. Where applicable these scenarios are also
applied on operational risk and business & strategic risks considering the relevant risk materiality assessment that has been
performed.
ix. The Bank, for the first time, developed its Geopolitical Risk Materiality Assessment. European Central Bank treats geopolitical risk as
a cross-cutting risk being transmitted to the bank’s traditional risks through three transmission channels, the Financial Market’s
channel, the Real Economy channel and the Safety and Security channel. Therefore, the Bank assessed the materiality of the
geopolitical risk across its traditional risk more specifically credit risk, liquidity risk, market risk, business and strategic risk, and non-
financial risk, following both a sector-based analysis and a country-based analysis, as well as detecting potential vulnerabilities and
dependencies.
The assessment showed the following results from a sector-based analysis:
Credit risk: material due to high concentration in geopolitical vulnerable sectors of the Non-Financial Corporate (NFC) exposures.
Liquidity risk: material from the Greek NFC Deposits perspective.
Market risk: Non-material from the corporate bonds portfolio analysis which constitutes a small share of the Bank’s total portfolio.
Business & strategic risk: Material from a profitability perspective according to a sector-based analysis of Gross Interest, Fees and
Commissions.
From a country-based analysis, there was no evidence of material impact across the Bank’s traditional risks due to the fact that the
Bank’s portfolio is mostly allocated in low or medium risk jurisdictions, as of 31.12.2025.
Regarding non-financial risk, a holistic assessment was conducted across all subcategories of the respective risk. The analysis
showed that geopolitical risk is material from an Information & Communication Technology and third-party risk assessment, as well
as from a reputational and compliance risk perspective.
Thus, in alignment with the respective guidelines, the Bank incorporated geopolitical risk into its risk inventory and, moving forward,
will enhance its methodologies annually, while closely monitoring the external environment given that this type of risk is
multifaceted and difficult to predict in accuracy and across all time horizons.
Board of Directors’ Report as at 31.12.2025
17 | ANNUAL FINANCIAL REPORT
x. The Bank earned a B rating from Carbon Disclosure Project (CDP) reflecting a two-grade improvement as a result of our ongoing
efforts to enhance environmental management and increase transparency and further integrate climate-related consideration into
our business strategy.
xi. The Bank has updated its annual Climate and ESG Materiality assessment with enhancements in alignment with the Bank’s appetite
for a constant enhancement. More specifically the Bank proceeded with the inclusion of the following additional perimeters and
changes:
• The Bank complemented its ESG risk materiality assessment already performed in the context of Credit risk with an
obligor-level materiality assessment focusing on the top 20 obligors of the NFC Loan portfolio, in terms of total GHG
emissions.
• The Bank proceeded with the inclusion of certain additional perimeters in this year’s exercise. In particular, the Bank
proceeded in performing the analysis of off-balance sheet exposures (Credit Risk), the assessment of real estate
investment properties (Business & Strategic Risk) and the assessment of physical risk of repossessed real estate.
• An additional element of identifying sectors sensitive to climate transition has been introduced in Bank’s current
methodology. More specifically, the Bank complemented its ESG risk materiality assessment already performed in the
context of Credit risk with an obligor-level materiality assessment focusing on the top 20 obligors of the NFC Loan
portfolio, in terms of total GHG emissions.
• Regarding the physical risk assessment, new risks have been also assessed (i.e., ocean acidification). The disaggregation of
some risks that were previously assessed under one category was conducted and are now assessed into distinct categories
thus facilitating the result aggregation of the examined physical risks into the four climate-related hazards classes
(Temperature-, Wind-, Water-, Soil- related).
• The Bank transitioned from the UNEP FI tool to the ENCORE tool to identify the key sectors with negative impacts across
the nature-related topics.
• As in the previous year’s impact analysis, the Bank assessed the likely negative impacts for sectors that significantly affec t
each nature-related topic. The assessment was based on literature review across different time horizons. It is also
considered existing and future legislation, regulations, market pressures, technological advancements and innovation, as
well as reputational risks. These factors were combined to produce a likelihood score. In this year’s impact analysis, the
assessment was further improved by calculating sector-level impact scores for each nature-related topic, providing a more
detailed evaluation of risks within the defined scope.
• Greenwashing risk is assessed under the Social- & Governance-related risks, rather than under Climate- & Nature-related
risks considering the nature of greenwashing risk and its treatment within the Bank.
• The Bank has explicitly referred to the likelihood of occurrence and potential magnitude dimensions to fully address the
requirements in accordance with CSRD.
Since the previous submission, updates to the methodologies have led to changes in the materiality assessment of nature-related
risks for non-financial and reputational risk. Specifically, non-financial risk is no longer assessed as material over the medium- and
long-term horizons, while reputational risk is now considered material only over the long-term horizon (and no longer over the
medium term).
Τhe outcome of the materiality assessment for each risk category is outlined as follows:
Climate related risks:
▪ Credit risk:
➢ Transition risk: considered to be materially affected, both in the Non-Financial Corporate (NFC) portfolio and the
Retail portfolio secured by Real Estate in the medium and long-term horizons.
➢ Physical risk: It is, also, considered to be materially affected in the medium and long-term horizons, leveraging on the
vulnerability assessment outcome per sector and region.
▪ Non-financial risk: seems to be materially affected by transition and physical risks in the medium and long-term horizons as
examined in terms of the Bank’s Own used Real Estate Properties.
Regarding Legal/Litigation risk, and specifically Greenwashing Risk seems also be materially affected by C&E risks in medium
and long-term horizons.
▪ Market / Liquidity risk: currently assessed as immaterial to both transition and physical risks across time horizons.
▪ Reputational risk: materially affected by C&E risks in the medium and long-term time horizons.
▪ Business & Strategic risk:
➢ Transition risk: considered to be materially affected by transition risk over the medium- and long-term horizons. The
assessment examines the Gross Interest and Fees & Commissions Income of the Bank’s performing portfolio within
the ESG Sensitive Perimeter, following the same approach as credit risk.
➢ Physical risk: considered to be materially affected by physical risks over the medium and long-term horizons.
A. Nature related risks:
▪ Credit risk: materially affected by nature-related risks (and more specifically by biodiversity) over long-term horizon.
▪ Non-financial risk: materially affected by nature-related factors in the medium- and long-term horizons.
▪ Market/ Liquidity risk: immaterially affected by nature-related risks across time horizons.
▪ Reputational risk: materially affected by nature-related factors in the medium and long-term horizon.
▪ Business & Strategic risk: materially affected by nature-related risks (and more specifically by biodiversity) over long-term
horizon.
B. Social related risks:
▪ Credit risk: no material risks arise from the downstream portfolio due to the processes and controls applied by the institution,
despite the fact that certain part of the NFC portfolio impacts social factors.
▪ Non-financial risk: considered material in the short-medium and long-term. Specifically, the social topics considered as
material are (a) for own workforce: the training & skills development, and (b) for consumers and end users: privacy, access t o
(quality) information and responsible marketing practices.
Board of Directors’ Report as at 31.12.2025
18 | ANNUAL FINANCIAL REPORT
▪ Greenwashing risk: Although Greenwashing risk is considered a significant aspect of Governance risks, the Bank has also
identified and takes into account interdependencies between social risks and Greenwashing risk.
C. Governance risks:
▪ Corruption and Bribery governance topic is considered material in the short, medium- - and long-term.
▪ Greenwashing risk: Overall, greenwashing risk is considered material in the medium- and long-term.
It is noted that all Alpha Bank subsidiaries conducted their own ESG Risk Materiality Assessment within 2025.
More information about Climate and ESG Materiality assessment methodology and other ESG related enhancements is presented in the
Sustainability Statement of the Annual Report 2025.
To address the C&E risks, in 2025 the Bank implemented a comprehensive strategic plan through the following key actions:
a) Identified, assessed, and prioritized the ESG issues related to its activities that may impact the Group’s operations and/or its
Stakeholders. Under this scope, a Double Materiality Analysis (DMA) was performed by leveraging the UNEP FI Principles for Re sponsible
Banking (PRB) Tool, the RSCA inherent risk assessment and outcome from the Compliance Risk Assessments to identify the material
Impacts, Risks and Opportunities (IROs) and connect these with the relevant European Sustainability Reporting Standards (ESRS) topics,
subtopics or sub-subtopics under Corporate Sustainability Reporting Directive (CSRD).
b) Enhanced the regular monitoring of RAF indicators in order to cover all material C&E risks (transition & physical for credit risk in NFCs
and Collaterals, operational losses due to physical risk, social and governance risks, reputational risk due to ESG considerations, business
& strategic risk through the monitoring of income reliance from sectors sensitive to transition risk). The RAF indicators were updated in
Tier III in 2025 adding thresholds.
c) Developed, in 2025, science-based financed emissions targets for material carbon-intensive sectors covering both lending and
investment portfolios. The targets cover the power generation, oil & gas, cement and iron & steel sectors, are aligned with the Net Zero
Banking Alliance recommendations and use the International Energy Agency Net Zero Emissions by 2050 (IEA NZE) scenario as the
benchmark pathway. Going forward, the Bank will continue to progressively align its lending and investment portfolios with net-zero
pathways adding sectoral decarbonization targets, and to expand its sustainable finance solutions to support its customers’ t ransition
through meaningful and effective engagement. In this respect, focus is put on the implementation and ongoing refinement of its climate
Transition Plan.
In order to assess the impact of climate risk on the calculation of Expected Credit Loss (ECL), detailed information on the ESG profile of the
obligor and the collateral (e.g. location of collateral, industry type as well as information on EPCs) is being collected. The information has been
incorporated into the respective data systems and methodological approaches are examined in the models for calculating the ECL.
More specifically, the following are in progress:
•
Data collections regarding ESG related information of the obligor through the use of the inter-banking ESG platform were ongoing
on 2025.
•
The Bank is considering in designing new interbanking ESG Obligor questionnaires targeting SPVs (Special Purpose Vehicles).
•
Further enhancement and recalibration of the Bank’s ESG scorecards leveraging the data above are in progress.
•
Identifying enhancements or additions to the current set of models used for risk parameter estimation and prediction, in order to
integrate ESG risks (nature related risks, counterparty risk).
The Group continues to develop and implement its ambitious ESG Workplan, aiming to enhance the sustainability of its business model and to
ensure long-term value creation for its Shareholders.
Liquidity Risk
Liquidity risk refers to the risk arising from an entity's inability to meet its short-term financial obligations due to a mismatch between its cash
inflows and outflows or due to challenges in converting assets into cash without incurring significant losses. There are two main types of
liquidity risk:
1. Funding Liquidity Risk
Funding liquidity risk refers to the risk that an organization will not have sufficient cash inflows to cover its cash outflows. This can happen
due to several factors, including but not limited to:
• Unexpected Cash Outflows: Sudden and large cash demands that were not anticipated, such as emergency expenses, debt
repayments, or withdrawal of funds by depositors or investors.
• Mismatch in Timing: The timing of cash inflows may not align with the timing of cash outflows leading to periods where the
organization faces cash shortages.
• Credit Issues: Difficulty in securing short-term borrowing or rolling over existing debt due to creditworthiness concerns or
unfavorable market conditions.
2. Market Liquidity Risk
Market liquidity risk pertains to the risk that an organization will not be able to quickly sell assets or investments at their current market value
due to changes in market conditions. This type of liquidity risk can arise from:
• Market Volatility: Significant fluctuations in market prices, which can make it difficult to sell assets without incurring a loss.
• Market Depth: The depth of the market, or the volume of transactions that can be conducted without impacting the asset's price,
can influence the ease of liquidating assets. In thin markets, large sales can drive down prices significantly.
• Regulatory and Economic Changes: Shifts in regulations or broader economic conditions can impact market liquidity, making it more
challenging to convert assets into cash quickly and at minimal loss.
In essence, liquidity risk embodies the challenges an organization might face in maintaining adequate cash flow to meet its obligations and
the difficulties in managing and liquidating assets efficiently in changing market environments. Effective liquidity management is crucial to
mitigate these risks and ensure financial stability and operational continuity.
During 2025, customer deposits on Group Level increased by Euro 4.1 billion mainly due to an increase in foreign subsidiaries’ deposits of
Euro 2.6 billion, supplemented by an increase of Euro 1.5 billion observed within the Greek segment of the Group. The liquidity buffer,
comprising cash and deposits with the Central Banks, government and corporate bonds (both eligible and non-eligible as collateral by the
Central Banks), and other liquid items, stood at Euro 17.1 billion at the solo level and Euro 21.5 billion at the Group level as of 31.12.2025. The
Bank’s financing from the Eurosystem was Euro 2.3 billion at year-end 2025, reduced from Euro 2.6 billion on 31.12.2024.
Board of Directors’ Report as at 31.12.2025
19 | ANNUAL FINANCIAL REPORT
In February 2025, Alpha Bank exercised the early redemption option on the remaining amount of the Euro 131 million subordinated bond,
which carried a coupon of 4.25% and was set to mature in February 2031. Furthermore, in July 2025, Alpha Bank announced the pricing of
the issuance of Euro 500 million subordinated fixed rate reset Tier 2 notes due on July 2036. The new Notes are callable in six (6) years and
are issued with a coupon of 4.308%. In October 2025, Alpha Bank successfully completed the pricing of a Green Senior Preferred Bond of
Euro500 million, callable after 5 years and carrying a coupon of 3.125%.
In March 2025, Alpha Bank was upgraded to Baa2 by Moody’s with a positive outlook. Alpha Bank received an Investment Grade rating
from Scope Ratings (BBB/Stable) in June 2025 and in October 2025 Alpha Bank was upgraded by Fitch to BBB- with a stable outlook.
During 2025, the European Central Bank reduced its deposit facility rate by 100 basis points, from 3% to 2%. Similarly, the Main Refinancing
Operations (MRO) rate was reduced by 100 basis points, from 3.15% to 2.15%, maintaining the 15 basis points spread between the deposit
facility rate and the MRO one.
To monitor liquidity risk, liquidity stress tests are conducted on a regular basis in order to assess potential outflows, contractual or contingent,
and their impact on the liquidity buffer. The purpose of this process is to confirm whether the existing liquidity buffer is adequate to cover the
Bank’s needs. These stress tests are carried out in accordance with the approved Liquidity Risk Policy of the Group. It is no ted that according
to these stress tests the Group remains solvent across all scenarios.
Moreover, following the submission of the 2025 ILAAP report the Contingency Funding Plan was reviewed and updated as part of its annual
review cycle. The Contingency Funding Plan complements the Recovery Plan and is designed to support the efficient management of an
emerging liquidity crisis. Its primary purpose is to enable timely remedial actions to mitigate any reduction in the liquidity buffer.
Interest Rate and Credit Spread Risk in the Banking Book (IRRBB/CSRBB)
Interest Rate Risk in the Banking Book (IRRBB) refers to the potential adverse impact that fluctuations in benchmark interest rates, such as the
Euro swap curve, may have to the Bank’s Net Interest Income and the Fair Value of Assets and Liabilities (Econo mic Value of Equity). Credit
Spread Risk in the Banking Book (CSRBB) captures the risk associated with the changes in market credit spread for liquidity and for potentially
other characteristics of credit-risky instruments, which is not covered by another existing prudential framework such as IRRBB or by expected
credit/(jump-to-) default risk. CSRBB captures the risk of an instrument’s changing spread without any deterioration in the issuer’s
creditworthiness.
Alpha Bank closely monitors the interest rate risk of the banking book and has adopted a strategic approach to manage the overall interest
rate and credit spread risk. The change in the Net Interest Income and the change in the Economic Value of Equity, which result from a change
in base interest rates, are measured under a set of internal and regulatory stress scenarios on a monthly basis. These results are assessed
under the appropriate limits incorporated into the Banks Risk Appetite Framework to monitor its IRRBB exposure. Additionally, the Credit
Spread Risk of the Banking Book (CSRBB), which is calculated based on pre-defined scenario developed by the Bank, is monitored on a
quarterly basis to ensure compliance with supervisory expectations. The relevant IRRBB stress tests scenarios results, along with the limit
usage, are presented to the Assets-Liabilities Management Committee and to the Risk Management Committee of the Board of Directors.
In 2025, the Bank continues the execution of its hedging strategy to manage the interest rate exposure within its risk appetite. The Bank
remains within the ΔEVE (Economic Value of Equity) to Tier 1 and the ΔΝΙΙ to Tier 1 Risk Appetite Framework limits across all different interest
rate stress scenarios.
Market, Foreign Currency and Counterparty Risk
The Group has developed a control environment, applying policies and procedures, in accordance with the regulatory framework and
international best practices.
Market risk is the risk of losses arising from unfavorable changes in the price or volatility of products with underlying interest rates, foreign
exchange rates, stock exchange indices, equity prices and commodities. The valuations of bond and derivative positions are monitored on an
ongoing basis. Stress tests are conducted on a regular basis in order to assess the impact for each scenario on profit and loss and capital
adequacy, in the markets where the Group operates.
A detailed risk framework for the monitoring of trading limits, investment limits and counterparty limits has been designed and implemented.
This framework involves regularly monitoring trigger events that could signal increased volatility in certain markets.
For the mitigation of the interest rate and foreign currency risk of the banking portfolio, hedging strategies are applied using derivatives.
During the -year, the trading book market risk, as measured by Value at Risk, fluctuated between Euro 0.5 million and Euro 2 million. Value at
Risk is the maximum loss that could take place in one day with 99% Confidence level. Value at Risk captures foreign currency risk, interest rate
risk, price risk and commodity risk in the trading book.
With respect to sovereign yields, the 10 year German Government Bond yield increased by 50 basis points (bps) and the 10 year Greek
Government Bond yield increased by 20bps and the 10year Italian Government Bond yield increased by 3 bps.
During the year there was an increase in Investment securities measured at amortized cost (notional value) of approximately Euro 0.8 million.
The key driver was the increase in sovereign bonds by Euro 0.7 million.
Non-Financial Risks
Non-Financial Risk is defined as the risk of financial or qualitative negative effects resulting from inadequate or failed internal processes, IT
systems, people (intentionally or unintentionally) and external events. Non-Financial Risk includes Legal Risk, Information & Communication
Technology (ICT) Risk, Fraud Risk, Conduct Risk, Compliance Risk, Model Risk, Outsourcing Risk, Data Risk, Human Capital Risk, Physical
Damage Risk, Execution Risk, Reputational Risk and AI Risk.
The Group has developed the Non-Financial Risk Management Framework which is compliant with the qualitative and quantitative regulatory
requirements of the Standardized Approach as defined by the Capital Requirement Directive (CRD). The effective implementation of the Non-
Financial Risk Management Framework is monitored by the Group’s competent Non-Financial Risk and Internal Control Committees.
The Group Non-Financial Risk Management Framework’s main components aim to manage the Non-Financial risk exposures effectively and
proactively. In particular:
•
Non-Financial Risk Events: management of Non-Financial risk events occurring across the Group
•
Risk Assessments and Scenario Analysis: various Non-Financial risk assessments are performed (e.g. Risk & Control Self-Assessment,
Third-Party Risk Assessment) and Scenarios are developed to proactively identify and mitigate potential Non-Financial risk
exposures.
•
Indicators: Key Risk Indicators have been developed to Group Entities (both at Risk Appetite Framework and operational level) to
monitor the Non-Financial risk exposures
Board of Directors’ Report as at 31.12.2025
20 | ANNUAL FINANCIAL REPORT
•
Risk Transfer: The partial transfer of certain types of Non-Financial Risk through the purchase and activation of certain Insurance
Policies
•
Mitigating Actions: Corrective actions are developed and monitored to mitigate the Non-Financial risk exposures
•
Reporting: Internal and regulatory reports are generated and disseminated to various stakeholders across the Group
•
Capital Requirements: calculation of capital requirements for Non-Financial risk (under Pillar I and II).
In 2025, the following developments occurred:
•
In Q1 2024, a new operating model was introduced regarding non-financial risk management, effective from April 2024. The
effectiveness of the new operating model assessed in April 2025 and results were presented at Non-Financial Risks and Internal
Control Committee and Risk Management Committee (RMC level). Indicatively, 71% reduction of the average time required to
manage a Non-Financial Risk Event was observed, along with the 100% coverage of the RCSA process vs 45% last year.
•
RAF (Risk Appetite Framework) dashboard materially enhanced to cover the full perimeter of Non-Financial Risks: Introduction of
new RAF Indicators for additional Non-Financial Risk subcategories, such as Human Capital Risk and further enhancement of
Information & Communication Technology risk-related RAF indicators.
•
Insurance Policy Renewal: Τhe BBB (Bankers Blanket Bond)/ CL (Civil Liability)/ D&O (Directors & Officers) and Cyber Risk Insurance
Contracts have been renewed for a two year’s period (01.12.2025-01.12.2027). Liability and Deductible amounts remain unchanged
at Euro 100mn/ Euro 5mn and Euro 75mn/ Euro 1mn respectively. Cumulative reinsurers premium savings amount to Euro 100mn/
Euro 5mn and Euro 75mn/ Euro 1mn respectively. Cumulative reinsurers premium savings amount to 0.6mn. Furthermore in case
Alpha Bank opts for the LTA (Long term Agreement) option and no compensation claims are submitted under the BBB/CL Insurance
policy, a further 15% discount on the BBB/CL combined two years’ net premium (Euro 666k) will be offered upon the said Policy’s
renewal on 01.12.2027.
• Following the gap analysis conducted in 2024 to assess the Group’s level of compliance with the requirements of the Digital
Operational Resilience Act (DORA), the implementation phase for the identified action plans has commenced. A substantial portion
of these action plans has already been completed, while several others remain in progress
• Establishment of new Function: The Operational Resilience Control (ORC) Business Area was introduced by the end of Q3 2025,
under the objective to perform an active oversight on the implementation of Group’s operational resilience objectives, throug h the
provision of independent guidance, evaluation, challenge and monitoring of the 1
st
line of defense Units. In this direction, the ORC is
responsible for establishing the operational resilience policy outlining the framework, the principles and the responsibilities that
govern the Group’s approach to operational resilience, ensuring that the organization can prepare, withstand, respond and rec over
from operational disruptions that could impact its critical business services. Its main areas of oversight are: business continuity,
digital operational resilience, incident management, third-party management.
• Implementation of the Control Testing process: The Control Testing refers to the periodic testing of the effectiveness and efficiency
of the internal controls. The purpose of testing the control effectiveness and efficiency is to understand the current state of
mitigating factors and the extent to which they effectively mitigate the inherent risks of the Bank’s processes. Control test ing is
currently in progress and is performed on the controls of the Bank’s Business Areas.
• Third-Party Risk Assessment: Outsourcing Risk Assessment Methodology was enhanced to include DORA third-party providers.
• SREP 2025 Assessment: Operational and ICT (Information and Communication Technology) score improved from 3 to 3+.
• Policies & Processes Updates: Various non-financial risk policies & processes were updated in the context of the annual review of
the non-financial risks management framework.
NON-PERFORMING EXPOSURES (NPEs) MANAGEMENT
The effective management of NPEs remains a key priority for the Group, aiming to enhance its financial strength and continue funding the
real economy, households and productive business sectors.
The Non-Performing Exposures Strategy, Recovery and Monitoring unit (the " NSRM”) is responsible for the remedial management of the NPE
portfolio of the Group, setting the strategic principles and actively monitoring the performance of the NPE reduction plan.
The NSRM unit acts as a single point of reference between the Bank and mandated Servicers, and, among other, is responsible for:
▪
Formulating the NPE recovery strategies
▪
Monitoring the execution of NPE remedial strategies in accordance with the Bank’s policies
▪
Managing the relationship with external Servicers and monitoring their performance
▪
Developing business analytics tools and overseeing the NPE performance evolution
▪
Ensuring compliance with regulatory requirements and relevant Service Level Agreements (SLAs)
The bank adopted a proactive customer-centric approach, designed in 2024 and implemented gradually in 2025. This initiative is intended to
provide sustainable, long-term solutions to pre-selected groups of borrowers through comprehensive financial assessments and affordability
analysis before they enter into arrears. Furthermore, towards the end of 2025 the Bank intensified its efforts in providing viable and sustainable
restructuring solutions to debtors whose prior restructuring products have amortization plans with increasing instalments (step ups) and will
continue to do so throughout 2026, aiming to maximize the viability of previously distressed debtors.
The anticipated increase on NPE inflows, resulting, among other, from the introduction of a more proactive approach in Greece and the reversals
from the HFS portfolio in subsidiary Alpha Credit Acquisition (ACAC) in Cyprus, led to a Group level increase in total NPEs of c.165million
compared to 31.12.2024 while the NPE Ratio
1
reached the percentage of 3.7% as at 31.12.2025. The NPE formation in Greece slightly
outperformed budget, positively impacted by better performance in management actions and frontloading of NPE Portfolio Sales (Project
Athena).
Additionally, taking into account the specific characteristics of certain portfolios, as well as management actions aimed at providing
sustainable solutions to borrowers with an increased risk of future re-default that cannot be incorporated into the models, the Group has
1
The NPE ratio is presented in Appendix of the Βoard οf Directors’ Report.
Board of Directors’ Report as at 31.12.2025
21 | ANNUAL FINANCIAL REPORT
proceeded with the recognition of additional adjustments amounting to Euro 95 million as at 31.12.2025 and Euro 103 million as at
31.12.2024.
The Bank recognizes the macroeconomic challenges that lie in 2026; nevertheless, it remains steadfast in its commitment to utilize the
proactive management approach, and, in close collaboration with Cepal, deliver superior servicing to its customers, and the implementation
of its strategic plan.
REAL ESTATE OWNED ASSETS (REOs) MANAGEMENT
In addition to the efficient and effective management of its NPEs, the Group has captured within its strategic priorities the successful
management of REOs through the subsidiary Αlpha Real Estate Services S.A. with the aim to:
• Monitor the repossession procedure (asset onboarding).
• Coordinate the asset management operations through the Group’s Special Purpose Vehicles (SPVs).
• Supervise and coordinate asset management and development.
• Supervise and coordinate repossessed asset commercialization, in accordance with the applicable Group policy.
• Set and monitor the Key Performance Indicators (KPIs) for the collaborating asset management agencies (internal units and external
collaborators).
In early 2025, an update of the existing Bank's and Group's Asset Management and Valuation Accounting Policy was carried out, aiming to
outline guidelines and procedures for a more effective administration, operation and maintenance of real estate assets. Real Estate
Management and Appraisal Policy addresses acquisition, leasing, valuation and overall strategies and assigns responsibilities to the related
units.
Additionally, a website was created to facilitate a more effective promotion of non-own-used properties and REOs. Through the website as a
main point of first contact with interested parties, Alpha Real Estate Services S.A., during 2025, has managed to dispose assets representing a
book value of approximately Euro 22 million in Greece and Euro 6 million in Cyprus and SEE (excluding sales of Project Skyline), achieving the
targeted sale prices. This demand was mainly driven by inflation which traditionally favor less liquid assets.
The forecasts indicate that the strong interest in the real estate market will continue in 2026. However we acknowledge that the legal
framework for real estate assets sales (transfer of ownership) remains challenging, albeit improving in recent years with advancements such
as real estate cadastre penetration and the e-property platform from AADE which facilitates the sales execution.
The commercial strategy focuses on optimizing value through market-driven sales of mature assets, the acquisition of properties with upside
potential, and the structured leasing of income-generating assets. The leasing approach aims to secure stable and recurring revenues, with a
particular emphasis on properties located in high-demand areas. This plan supports the Group’s objective to enhance returns, diversify
income streams, and strengthen the long-term performance of the real estate portfolio.
The fundamentals of the Greek economy coupled with the technical characteristics of the domestic market continue to support a favorable
trajectory for real estate assets over the medium term.
CAPITAL ADEQUACY
The objective of the Group’s capital management strategy is to maintain and strengthen its capital adequacy, taking into account both economic
and regulatory requirements. This is achieved through the continuous monitoring and adjustment of capital levels in line with supply and demand
conditions.
The overall Group’s Risk and Capital Strategy sets specific risk limits, based on management’s risk appetite, as well as thre sholds to monitor
whether actual risk exposure deviates from the limits set.
1. Supervisory review and evaluation process (SREP)
According to the Supervisory Review and Evaluation Process (SREP) 2024 decision, communicated by the European Central Bank (ECB), for
2025 Alpha Services and Holdings and as a result its universal successor after reverse merger Alpha Bank S.A. is required to meet on a
consolidated basis an Overall Capital Requirement (OCR) on the Total Capital ratio of at least 14.93% [the OCR includes the Capital
Conservation Buffer (CCB) of 2.50%, the Other Systemically Important Institutions (O-SII) buffer of 1% and the applicable Countercyclical
Capital Buffer (CCyB) of 0.43%, mainly stemming from the contribution of the subsidiaries, for which further information can be found in Note
50 for Capital Adequacy of the Financial Statements].
The OCR consists of the minimum threshold of the Total Equity Ratio (8%), in accordance with Article 92 (1) of the Capital Requirements
Regulation (“CRR”), and the additional supervisory requirements for Pillar II (P2R), in accordance with Article 16 (2) (a) of Regulation
1024/2013/EU, which amount to 3.0%, as well as the combined security requirements (i.e., CCB, O-SII, CCyB), in accordance with Article 128
(6) of Directive 2013/36/EU. The minimum ratio should be kept on an ongoing basis, considering the CRR/CRD IV Transitional Provisions.
On October 2025 Alpha Bank S.A. received the SREP decision 2025 regarding the Capital Requirements for the year 2026. The additional
supervisory requirements for Pillar II (P2R) is set at 2.9%
The Bank of Greece has set the O-SII buffer at 1 % for 2025, and under Executive Committee Act 235/1/07.10.2024 the Countercyclical Capital
Buffer at 0.25% for Greece, applicable from 1 October 2025. The target rate for the positive neutral rate of the countercyclical capital buffer in
Greece at 0.5%.
The capital adequacy requirements set by the SSM/ECB are used by the Group as the basis for its capital management. The Group seeks to
maintain sufficient capital to ensure that these requirements are met.
2. Capital Ratios
On 31.12.2025, the consolidated Common Equity Tier (CET) 1 capital stood at Euro 5.0 billion, while the Risk Weighted Assets (RWAs)
amounted to Euro 32.5 billion, resulting in a CET 1 ratio of 15.4%, down by 0.89% versus 31.12.2024. The above capital ratio for the Group
include period profits post a provision for dividend payout according to the dividend policy. Excluding the provision for dividend, capital ratios
increase by c. 206bps and the Total Capital ratio would stand at 22.7%.
3. Shareholder Remuneration Policy
Alpha Bank S.A. has updated its shareholder remuneration policy following the restoration of profitability. The policy document has been
approved by the Board of Directors (BoD) on the Meeting of 29.01.2026 The Policy sets the framework (legal, accounting, regulatory) under
which the Bank may proceed to a dividend distribution and is reviewed at least annually in the context of ICAAP and/or as often as necessary
in order to reflect amendments in all applicable laws and regulations.
Board of Directors’ Report as at 31.12.2025
22 | ANNUAL FINANCIAL REPORT
The Group applied and received on 15.05.2025 the approval for the distribution of Euro 281million to its shareholders, corresponding to 43%
of Group's net profit for financial year 2024, with a combination of cash (25% of the total distribution amount) and share buyback (75% of the
total distribution amount). Furthermore, on 18.10.2025 the Group received the approval for a cash distribution relating to interim dividend
distribution of Euro 111 million to its shareholders.
Based on the above and in view of the capital Business Plan for 2026-2028, the Bank aims to distribute a 55% of FY2025 and FY2026 Alpha
Bank’s reported accounting profits after tax on a consolidated basis, and 60% for the following two years (2027 and 2028 res ults).
In this context, from 2025 onwards the Bank is committed to accelerate DTC amortization for prudential purposes by voluntarily deducting it
from capital ahead of the scheduled timeline. The acceleration of DTC is set equal to 29% of planned total amount of ordinary shareholder
payouts (cash dividend and/or share buyback) removing any DTC dependencies on shareholder remuneration.
4. EU-Wide Stress Test 2025
The 2025 EU-wide stress test involved 64 banks from 17 EU and EEA countries and covered 75% of EU banking sector assets. The results
confirmed that European banks remain resilient even under a severe hypothetical economic downturn. The simulated scenario involved a
sharp deterioration in the global macro-financial environment, driven by a resurgence in geopolitical tensions, entrenched trade
fragmentation, including increase in tariffs, and persistent supply shocks.
Alpha Bank’s Stress Test results under the adverse scenario incorporate a conservative 50% pay-out ratio in years where the Bank is making
profits. The Bank’s CET 1, Tier I and Total capital ratios of December 2027 are 13.9%, 16.1% and 19.2%, compared to t he starting point at the
level of 15.9%, 18.2% and 21.4% (for reference date 31.12.2024 restated for CRR 3). Pro-forma excluding the dividend payments, capital ratios
are enhanced by c. 1%.
The fully loaded impact from the new CRR (CRR 3) and new Basel implementation for reference date of 31.12.2024 is very limited, affecting
CET 1 by just 0.34%. This compares favorably with the new Basel implementation impact to EU average of c. 1.28%.
In the baseline scenario, the Bank recorded a capital accretion with an increase of the Fully Loaded CET 1 ratio by c. 2.4% in the 3-year
horizon, also incorporating a dividend payout of 50% on Profit After Tax. Specifically, the Bank’s CET 1, Tier I and T otal capital ratios of
December 2027 are 18.3%, 20.5% and 23.6%, compared to the starting point at the level of 15.9%, 18.2% and 21.4% (for reference date
31.12.2024 restated for CRR 3).
Since the EU-wide 2023 Stress Test, the Bank has been transformed, significantly strengthening its balance sheet, decisively reducing its stock
of NPEs, restoring its organic profitability and successfully building a demonstrable track record of execution in the capital markets through
the issuance of capital and MREL instruments while also further enhancing capital and liquidity buffers. In the adverse scenario, the capital
depletion of the Fully Loaded CET 1 ratio over the three-year horizon in the adverse scenario is slightly below 2% for the Bank (c. 3.1% in EU-
wide 2023 Stress Test) compared favorably to c. 3% for the EBA EU average (c. 4.6% the EBA EU average in the EU-wide 2023 Stress Test).
5. Deferred Tax Assets (DTAs)
The Deferred Tax Assets (DTAs) which are included in the Group’s capital base as at 31.12.2025 stand at Euro 4.8 billion.
According to article 5 of Law 4303/17.10.2014, as amended by article 4 of Law 4340/1.11.2015, on the “Recapitalization of fin ancial
institutions and other provisions of the Ministry of Finance” and Laws 4549/2018 and 4722/2020 and, most recently, by Law 4831/2021, DTAs
that have been recognized and are due to the debit difference arising from the Private Sector Involvement (PSI) and the accumulated
provisions and other general losses due to credit risk, which were accounted until 30.06.2015, are converted into final and settled claims
against the Greek State. The above mentioned are set into force in case the accounting result for the period after taxes is a loss, according to
the audited and approved by the Ordinary General Meeting of Shareholders financial statements.
In accordance with article 39 of Regulation (EU) No 575/2013 of the European Parliament and of the Council on “prudential req uirements for
credit institutions and investment firms” (the “Capital Requirements Regulation – CRR”), which amended Regulation (EU) No 648/2012, a risk
weight of 100% will be applied to the abovementioned DTAs that may be converted into tax credit, instead of being deducted from the
Regulatory Equity Capital.
On 31.12.2025, the amount of DTAs, which is eligible for the scope of the aforementioned Law, for the Group and is included in the Common
Equity Tier 1, stands at Euro 2.3 billion and constitutes 45.3% of the Group’s Common Equity Tier 1 and 7% of the resp ective Weighted Assets.
Any change in the above framework that will result in the non-recognition of DTAs as a tax credit will have an adverse effect on the Group’s
capital adequacy.
6. Capital Requirements under Pillar I
The approaches adopted for the calculation of the capital requirements under Pillar I are determined by the policy of the Bank in conjunction
with factors such as the nature and type of risks the Group undertakes, the level and complexity of the Group’s business and other factors
such as the degree of readiness of the information and software systems.
Capital Requirements for Credit Risk are calculated using the Standardized Approach (STA). The advanced method is used for the valuation of
financial collaterals. For the Operational Risk capital requirements, the Group follows the STA. As regards Market Risk, the Bank uses for the
significant exposures a Value at Risk (VaR) model developed at Bank level and approved by the Bank of Greece. Additionally, STA is used to
calculate Market Risk for the remaining non-significant exposures by the financial institutions of the Group at solo level as also on Group level.
The prudential framework for Banks has been amended by the introduction of Capital Requirements Regulation 3 (CRR3). It implements the
international Basel III standards (Basel IV) and the adoption of CRR 3 which is applicable from 01.01.2025, introduces a series of significant
changes to the regulatory framework established under CRR 2, particularly in the context of standardized approaches to credit risk, market
risk, operational risk and CVA risk. These modifications aim to enhance the resilience of financial institutions while ensuring greater
consistency and comparability across jurisdictions.
For Market Risk, the Group will adopt the Fundamental Review of the Trading Book (FRTB) methodology. This approach is currently under
consultation by Supervisory Authorities, with its implementation scheduled to take effect on 1 January, 2027.
7. Internal Capital Adequacy Assessment Process (ICAAP) and Internal Liquidity Adequacy Assessment Process (ILAAP)
The ICAAP and ILAAP are an integral part of the Internal Control System (ICS) of the Group. They are aligned with best practices and the
general principles and requirements set by the regulatory framework, including the guidelines provided by the Single Supervisory Mechanism
(SSM) and/or the European Banking Authority (EBA). These guidelines allow for:
• The identification, analysis, monitoring and the overall assessment of risks to capital and liquidity.
• The improvement of various systems/procedures/policies related to the assessment and management of risks.
Board of Directors’ Report as at 31.12.2025
23 | ANNUAL FINANCIAL REPORT
• The estimation of the Internal Capital required for the coverage of all risks and the determination, the management and the
monitoring of the liquidity buffer.
• Capital and liquidity planning, taking also into consideration the Group’s risk appetite and the approved business plan.
ICAAP and ILAAP are integrated into the business decision-making and risk management processes of the Group, contributing to its continuity
by ensuring its capital and liquidity adequacy from different but complementary perspectives (e.g. the economic perspective and the
normative perspective), while both perspectives mutually inform each other and are integrated into all material business activities and
decisions. The Board of Directors has the overall responsibility of the ICAAP/ILAAP implementation with a clear and transparent assignment of
responsibilities to the Risk Management Committee and to Senior Management Members. The Board of Directors, following the Ris k
Management Committee endorsement, approves the results of the ICAAP and the ILAAP and signs the Group’s Capital Adequacy Statement
(CAS) and the Liquidity Adequacy Statement (LAS). The related reports are updated at least annually or on a more frequent basis if material
changes occur and are submitted to the SSM of the European Central Bank (ECB). The ICAAP and ILAAP Reports are assessed yearly by the ECB
as part of the Supervisory Review and Evaluation Process (SREP).
8. 2026 Geopolitical Reverse Stress Test
The European Central Bank (ECB) will conduct a geopolitical risk reverse stress test on 110 directly supervised banks in 2026. In a reverse
stress test, a pre-determined outcome is prescribed and each bank defines the scenario in which that outcome would materialise. This
reverse stress test will complement the 2025 European Banking Authority stress test, which assumed a common scenario for all banks and led
to differences in their capital depletion. The 2026 thematic stress test will ask banks to assess how geopolitical risk could affect their business
model.
Geopolitical risk is a cross-cutting risk driver that can have an impact on banks’ traditional risk categories, as it cuts across credit, market,
liquidity, business model, governance and operational risks. It can also affect banks through multiple channels, including financial markets,
the real economy and the safety and security of banks’ operations. As a key driver of macroeconomic uncertainty, it remains a t the centre of
the ECB’s supervisory priorities for 2026-2028.
The stress test will provide insights into the geopolitical risk-related scenarios that could materially affect banks, who should identify relevant
geopolitical events and quantify their impact. In addition, they will be asked to describe how they would act to reduce that impact, if
necessary, with a view to ensuring that they have robust governance and operational resilience frameworks in place.
The exercise will assess the extent to which banks’ stress-testing capabilities take geopolitical risks into account. In this regard, the exercise
will aim to foster banks’ own risk management capabilities, particularly in reverse stress testing, and their ability to design relevant and
prudent capital and recovery plans.
Specifically, each bank will be asked to identify the most relevant geopolitical risk events that could lead to at least a 300-basis point depletion
in its Common Equity Tier 1 (CET1) capital. In addition to reporting on how the geopolitical risk scenario would affect their solvency positions,
banks will also be asked to provide information about how it may affect their liquidity and funding conditions.
The reverse geopolitical risk stress test will be conducted as part of the 2026 banks’ Internal Capital Adequacy Assessment Process (ICAAP).
Banks will therefore primarily be able to utilise existing supervisory data collection templates.
In line with previous ECB thematic stress tests conducted to comply with Article 100 of the Capital Requirements Directive (CRD), the
geopolitical risk reverse stress test is not intended to have any implications for Pillar 2 Guidance (P2G). The outcome will be used to inform
and complement the Supervisory Review and Evaluation Process (SREP) in a qualitative way and in line with the broader 2026 ICAAP.
Weaknesses revealed by this stress test will feed into the SREP assessment, with a focus on banks’ abilit y to incorporate geopolitical risks into
their risk materiality assessments, their stress-testing framework and capabilities and their risk data aggregation and reporting capabilities.
9. Regulatory Liquidity Ratios
The evolution of deposits, credit expansion, organic growth and balance sheet funding developments (securities financing transactions and
own issuances) are the main factors affecting the regulatory liquidity ratios’ evolution. As of 31 December 2025, the Group’s Liquidity
Coverage Ratio (LCR) stands at 184% and the Group Net Stable Funding ratio (NSFR) stands at 125% , both comfortably above the minimum
regulatory requirements.
10. MREL
The Minimum Requirement for own funds and Eligible Liabilities (MREL) constitutes a buffer that the Bank has to maintain in order to absorb
losses in the event of resolution. The minimum levels of MREL are determined by the Single Resolution Board (SRB) on an annual basis.
On 22 April 2024, Alpha Bank S.A. received a communication letter from the European Single Resolution Board (SRB) including its decision for
the minimum requirements for own funds and eligible liabilities (MREL). The requirements are based on the Recovery and Resolution
Directive (“BRRD2”), which was incorporated into the Greek Law 4799/2021 on 18.5.2021. At the same time, by the same decision, the
Resolution Authority defined the single point of entry (SPE) resolution strategy.
Following the letter of BoG, regarding the implementation of SRB’s Decision (SRB/EES/2025RPC/59) on 18 December 2025, Alpha Bank
received the binding Minimum Requirement of Own Funds and Eligible Liabilities (MREL), according to which the Bank needs to meet from 18
December 2025 on a consolidated basis an MREL requirement of 23.58% of Total Risk Exposure Amount (TREA) and 5.91% of Leverage
Exposure (LRE). The Decision also sets out that the binding target of Alpha Bank S.A. also reflect the MCC (Market Confidence Charge)
allowance.
The said MREL requirements expressed as a percentage of TREA do not include the Combined Buffer Requirement (CBR), equal to 3.93% as of
31.12.2025.
In Europe, the Single Resolution Board (SRB) published a new package containing Minimum Bail-in Data Templates (MBDT) and released its
2024 MREL policy. This policy allows adjustments in calibrating the Market Confidence Charge (MCC) and monitoring eligibility, among other
changes. Meanwhile, the EBA published two consultations, one on the resolution plan reporting framework and another on independent
evaluators. The EBA also released a monitoring report on AT1, T2, and TLAC/MREL instruments, suggesting that capital instruments (AT1 and
T2) should have a prudential valuation reflecting their loss absorption capacity. It recommended using the carrying amount instead of the
nominal for prudential matters and left open the possibility of extending this treatment to MREL-eligible instruments for resolution, a decision
for the European resolution authority.
Minimum requirements for own funds and eligible liabilities (MREL), are subject to annual review/approval from SRB.
Board of Directors’ Report as at 31.12.2025
24 | ANNUAL FINANCIAL REPORT
On 31 December 2025, Alpha Bank S.A. MREL ratio on a consolidated basis stood at 28.7%, which is well above the binding target of 27.51% of
the Total Risk Exposure Amount (TREA) (including CBR). The ratio includes the profit of the financial reporting period that ended on 31
December 2025 post a provision for dividend payout.
REGULATORY ENVIROMENT FOR ANTI-MONEY LAUNDY AND FINANCIAL SECTORS’ DIGITAL
TRANSFORMATION
Anti-money laundering Regulation
EU AML Package - RTS
The European Banking Authority (EBA), in March 2025, proposed four regulatory technical standards (RTS) to reshape the anti-money laundering
and counter-terrorist financing (AML/CFT) regime in European Union (EU).
These standards will form part of the EBA response to the European Commission Call for Advice on AML/CFT measures under the Sixth Anti-
Money Laundering Directive (2024/1640 or AMLD6). Adopted on 30 May, 2024, the AMLD6, along with the Anti-Money Laundering Regulation
(2024/1620 or AMLR) and the Anti-Money Laundering Authority (AMLA), forms part of the EU AML package aimed at strengthening the AML/CFT
regime in European Union.
This package includes four sets of Regulatory Technical Standards which aim to shape how institutions and supervisors will comply with their
AML/CFT obligations under the new AML/CFT package:
• Draft RTS on the assessment of the inherent and residual risk profile of obliged entities under Article 40(2) of the AMLD
• Draft RTS on the risk assessment for the purpose of selection of credit institutions, financial institutions and groups of credit and
financial institutions for direct supervision under Article 12(7) of the AMLAR
• Draft RTS under Article 28(1) of the AMLR on Customer Due Diligence
• Draft RTS under Article 53(10) of the AMLD6 on pecuniary sanctions, administrative measures and periodic penalty payments
The Bank participated in the consultation process of the proposed RTSs, providing feedback through the Hellenic Banking Association.
In December 2025, AMLA issued a final report that includes two draft Regulatory Technical Standards (RTSs).
1. Draft RTS on the assessment of the inherent and residual risk profile of obliged entities under Article 40(2) of AMLD.
2. Draft RTS on risk assessment for selecting credit institutions, financial institutions and groups of credit and financial institutions for direct
supervision under Article 12(7) of AMLAR.
In parallel, AMLA launched a Consultation on the draft Implementing Technical Standards on cooperation within the AML/CFT supervisory
system for the purposes of direct supervision under Art. 15(3) AMLAR.
FATF Recommendation 16 (Travel Rule) - Executive Committee Act of the Bank of Greece (BoG) on the adoption of the EBA guidelines on the
Travel Rule (EBA/GL/2024/11)
On June 18
th
, 2025, the Financial Action Task Force (FATF) announced that changes to Recommendation 16 of the FATF standard, also referred
as the ‘Travel Rule’ in the context of virtual assets, were agreed by members at the FATF’s June 2025 Plenary meeting. The ch anges intend to
increase the safety and security of cross-border payments to better detect financial crime, to ensure consistency of information required in
payment messages in order to build a clearer picture of who is sending and receiving money, and to help eliminate fraud and error impacting
customers.
On this subject, the Executive Committee Act 242/4/11.6.2025 of the Bank of Greece (BoG) on the adoption of the guidelines of the European
Banking Authority (EBA/GL/2024/11) regarding the requirements for the provision of information related to transfers of funds and transfers of
certain crypto-assets pursuant to Regulation (EU) 2023/1113 ("Guidelines on the Travel Rule") was published.
The Bank participated in the consultation process of the above regulations submitting relative feedback.
EU Sanctions Helpdesk
In March 2025, the European Commission launched the EU Sanctions Helpdesk, a platform that supports European operators in complying with
European Union restrictive measures imposed worldwide.
The EU Sanctions Helpdesk aims primarily to assist Small and Medium-sized Enterprises (SMEs) with offering resources and personalized help
to companies performing sanctions due diligence checks.
"Know Your Business" – ("eGov-KYB")
At the national level, "Know Your Business" – ("eGov-KYB") platform was launched, enabling the automated retrieval and transmission of data
of legal entities from public information systems to credit institutions and financial organizations, ensuring compliance with due diligence
obligations (Joint Ministerial Decision 7671 EX 2025/10.3.2025). BoG’s Banking and Credit Committee Decision 281/17.03.2009, which specifies
the AML/CFT obligations of entities supervised by the Bank of Greece, was accordingly amended.
The Bank actively participated in the consultation process of the proposed Joint Ministerial Decision providing feedback through the Hellenic
Banking Association.
19th EU package of sanctions against Russia and Belarus
On 23 October 2025, the EU adopted 19th sanctions package targeting Russia’s energy, finance, military, and related sectors.
New bans include restrictions on Russian liquefied natural gas (LNG) imports and extended restrictions on Russian oil producers. Additional
sanctions were imposed on third-party entities (from China, UAE, Tajikistan, Kyrgyzstan, and others) accused on facilitating the circumvention
of sanctions. The package targets Russian diplomats’ movements within the Schengen Area to curb potential intelligence threats. Additional
restrictions impact dual-use goods, technology exports, and various services to Russian and Belarusian entities.
eGov-KYC upgrade
The draft Ministerial Decision on the eGov-KYC service, aiming at replacing Ministerial Decision No. 9747/2021 of the Minister of Digital
Governance concerning the “Electronic execution of customer due diligence measures through the eGov-KYC application,” has been released
for public consultation.
The Bank participated in the consultation process for this decision by providing feedback through the Hellenic Banking Association.
Establishment of Criminal Offences and Sanctions for Violations of European Union Restrictive Measures and Transposition of Directive (EU)
2024/1226
Board of Directors’ Report as at 31.12.2025
25 | ANNUAL FINANCIAL REPORT
In September 2025, Law No. 5232/2025 was published in the Government Gazette introducing the determination of offences and sanctions
against natural and legal persons for violations of the restrictive measures of the European Union and transposing the Directive (EU) 2024/1226
of the European Parliament and the Council of 24 April 2024. This legislation introduces criminal liability for individuals and legal entities that
fail to comply with EU sanctions.
Internal Governance Framework update
On 7 July, 2025, the BoG Executive Committee published Act No. 243/07.07.2025 adopting the EBA Guidelines on Internal Governance
(EBA/GL/2021/05) and repealing BoG Governor’s Act No. 2577/9.3.2006 entitled “Framework of principles governing operation and criteria for
the assessment of the organizational structure and Internal Control Systems of credit and financial institutions, and the related responsibilities
of their management bodies.”
This update is in line with the EU’s push for enhanced corporate governance standards and helps ensure that financial institu tions maintain
strong governance frameworks and internal controls.
The Bank participated in the consultation process of the proposed Act, offering feedback via the Hellenic Banking Association.
Remote Electronic Identification Terms for Natural Persons
The BoG Executive Committee Act No. 244/5/25.07.2025 amends BoG Executive Committee Act No. 172/1/29.5.2020, concerning the remote
electronic identification of natural persons when establishing a business relationship with credit institutions and financial institutions supervised
by the Bank of Greece. The amendments broaden the scope of acceptable methods for remote identification and introduce additional risk
mitigation measures to further protect against identity fraud and financial crimes.
The Bank actively participated in the consultation process of the proposed Act by providing feedback to the Bank of Greece.
Regulation in the context of the financial sector's digital transformation
In 2025, the European authorities maintained their focus on digitalization and on the strengthening of the pan-European payments market, in
line with the digital strategy defined by the European Commission (EC) in 2020.
The EU approved the first AI Regulation, imposing obligations employing a risk-based approach. AI systems are classified under one of the
following risk categories: unacceptable risk, high risk, limited risk and minimal risk. General-purpose AI models, including generative AI, are
classified under the systemic risk category if they fulfill specific criteria. High-risk applications, like credit scoring and insurance, will be
regulated from August 2026. General-purpose AI obligations start in August 2025. As part of the Group’s Digital Transformation, a dedicated
team has been set up to oversee the development and deployment of Artificial Intelligence (AI) models and systems, to ensure their
effectiveness and compliance with quality standards, including data quality assessment, model development, human oversight, and post-
market monitoring. A policy is being finalized defining the rules, standards and principles adopted by the Bank, in the context of a proactive
and responsible approach to AI integration, in alignment with Regulation (EU) 2024/1689 (AI Act), ensuring that all AI systems used by the
Bank are lawful, ethical, secure and subject to appropriate oversight. The EC also consulted on AI's impact on financial services and
regulations.
In addition, the proposal for the Financial Data Access Regulation (FiDA) remains under negotiation at the EU level. Although earlier
expectations pointed to a final compromise by the end of 2025, no final agreement was reached during December. Interinstitutional
discussions continue, focusing on the scope of data to be shared (including savings, credit, investment, insurance and pension products), the
interaction with the Payment Services Directive (PSD3) and the Payment Services Regulation PSR, and the operational, governance and
liability framework for data holders and authorized third parties. FiDA is now clearly positioned within the EU legislative agenda for 2026.
Despite the delay, it remains a key enabler of the EU’s Open Finance agenda, with the pot ential to support new data-driven products,
partnerships and advisory services beyond compliance-driven data sharing.
In the payment’s domain, the PSR and the PSD3 have advanced significantly through the legislative process. During 2025, the European
Parliament adopted amended texts at first reading, and interinstitutional negotiations are at an advanced stage, with final political agreement
expected during 2026 and phased implementation extending into 2027. The new framework strengthens fraud prevention, expands a nd
clarifies the definition of customer authorization, and reinforces reimbursement obligations for unauthorized or manipulated transactions
unless gross negligence or fraud by the customer is proven. The mandatory introduction of payee verification mechanisms (e.g. IBAN-name
matching) will have material implications for customer experience, fraud management and operational processes, while the shift to a directly
applicable regulation is expected to reduce national divergence but increase compliance intensity.
These developments form part of the European Commission’s broader Payments Package, complemented by the Instant Payments
Regulation, which has been effective since April 2024 and is now moving into full operational implementation. By end οf 2025 and into 2026,
payment service providers across the EU and EEA are required to offer instant euro credit transfers with execution times of up to 10 seconds,
continuous availability (24/7/365), pricing parity with traditional credit transfers, and integrated payee verification. While this significantly
enhances speed and availability, it also increases demands on real-time fraud prevention, AML screening and cost management. Alpha Bank is
aligned with this direction, with IRIS P2P and P2B services operating on instant payments infrastructure and continuously enhanced in terms
of fraud controls, user experience and customer adoption. As of mid-2025, the IRIS daily transfer limit was increased to Euro1,000.
In parallel, the European initiative for a potential digital euro continues to progress. The ECB completed its preparation phase during 2025 and
has moved into deeper technical and design work, while the proposed legal framework remains under discussion in the European Council and
Parliament. The legislative process aims to define the digital euro’s legal tender status, distribution model via supervised intermediaries, and
key design features such as privacy safeguards, offline functionality and holding limits. A final decision on issuance will depend on the
completion of the legislative framework, with potential pilot phases expected later in the decade. Alpha Bank actively contributes to the
ongoing dialogue through the Hellenic Bank Association and the European Banking Federation.
Finally, the Markets in Crypto-Assets Regulation (MiCA) is now fully implemented across the EU. During 2025, ESMA and EBA finalized most
second-level regulatory and technical standards, providing clarity on authorization, governance, prudential requirements, consumer
protection and market conduct for crypto-asset issuers and service providers. Regulatory focus has therefore shifted from legislative
uncertainty to supervisory enforcement and operational compliance.
The Digital Operational Resilience Act (DORA), which entered into application on 17 January 2025, establishes a comprehensive framework to
strengthen the digital resilience of financial entities. Internationally, the Basel Committee issued a consultation on principles for third-party
risk management. Τhe following major Bank initiatives are on-going :
1. Reinforcement of its governance structure and policies for the management and monitoring of ICT and cybersecurity risks, including
ICT third-party risk.
Board of Directors’ Report as at 31.12.2025
26 | ANNUAL FINANCIAL REPORT
2. Enhancement of the digital operational resilience testing to ensure robustness of the Bank’s ICT assets that support its critical
business functions, under stress scenarios.
3. Enrichment of the business continuity plans aiming at minimizing business disruptions in the event of threat realization.
4. Optimization of processes for ICT incidents assessment and reporting.
5. Development of strategies for digital resilience & ICT third-party risk.
TRANSFORMATION
Transformation Program
During 2025, Alpha Bank continued its transformation through various project implementations delivering most of the projects included in the
Program.
With regards to Wholesale Banking, Relationship Managers were further empowered with new capabilities following the successful delivery
of new credit tools ("Corporate Workflow", "Swimlanes - Digital credit papers - DCPs"), in 2025, which aim to redirect their time to more
client-engagement activities. Moreover, the Bank has also finalized projects related to workflow redesign and enhancements for SME
targeting to increase process automations and efficiency.
In the field of Wealth Management Services, the Bank continued the comprehensive redesign of wealth management infrastructure, including
systems and key processes, to address legacy issues and establish a unified scalable platform with one advisory engine / portfolio approach,
advanced advisory capabilities & automations, for all customer segments & business growth aspiration (incl. beyond domestic limits) and
operational efficiency. The whole initiative is in progress following a phased approach with expected completion by the end of 2026. In
addition, Light Discretionary Portfolio Service for Gold Customers was launched as a pilot in several Branches in December 2025 with the
target to scale up early 2026.
Finally, the Bank has further progressed automations, process streamlining, and branch operations centralization, focusing on improving
customer experience and operational efficiency. These initiatives align with a comprehensive strategy to enhance service delivery and
streamline internal processes
Digital Transformation and Innovation Activities
The Group is advancing its Strategic Plan 2023–2026, focusing on digital solutions to enhance customer banking experiences. The Digital
Factory (multifunctional project-delivery teams for the Bank’s digital channels), which was established in 2023, has expanded to 15 agile
teams, significantly improving its productivity. These squads, supported by User Experience (UX) and Customer Experience (CX) specialists,
ensure intuitive and accessible digital services. The Bank is also integrating AI tools for processing large-scale data, enhancing decision-making
and operational efficiency. Digital Sales teams continue to meet digital penetration targets, especially in consumer lending.
Digital Banking
2025 was a year of further maturity and acceleration of Alpha
Bank’s digital strategy, with a strong focus on the continuous
evolution of digital channels, strengthening technological
infrastructure, and delivering innovative, high-value solutions for
Individual and Business customers. Throughout the year, the Bank
introduced new digital products and enhanced existing services,
prioritizing functionality, speed, and a user-friendly experience.
Digital channels continued to play a pivotal role in overall banking
activity, accounting for 98% of total transaction volume, with e-
Banking transactions increasing by 14% in number and 11% in value
compared to 2024.
• e-Banking for Retail customers
In 2025, e-Banking for Individuals maintained its upward trajectory, with transactions growing by 19% and their value by 10% versus 2024. At
the same time, 1 in 2 customers continued to choose online registration, and 4 out of 5 e-Banking users accessed the mobile app on a
monthly basis.
New digital services launched during the year included the digital assistant (chatbot), online pre-approval for mortgage loans, and a fully
digital process for consumer loans up to Euro 15,000.
To upgrade everyday transactions, new myAlpha Benefit packages (Base / Advanced / Unlimited) were introduced, designed to hel p
customers manage transactions effectively while reducing monthly costs. In insurance, Credit Card Protection during credit card application
and Alpha Health Care for outpatient medical services were added. Additionally, the partnership with car.gr enables customers to purchase
vehicles with instant online financing from Alpha Bank.
The enhanced Retail Onboarding process via myAlpha Mobile allows new customers to start their banking relationship entirely from their
mobile device through eGov-KYC and video call identification, obtaining an account, debit card, and e-Banking access within minutes.
Meanwhile, the e-Banking Walkthrough team continued to provide personalized training via video calls, ensuring a secure and comprehensive
digital banking experience.
• e-Banking for Business customers
E-Banking for businesses recorded a 3% increase in transactions and 11% in value, while more than 6 out of 10 new corporate customers
chose Alpha Bank’s digital channels to begin their relationship with the Bank.
The myAlpha Web for Business platform was enriched with new features such as applications for auditor certificates and free access to
myAlpha Code. User experience was improved through targeted notifications, and a new role, “myAlpha Documents Signatory,” was
introduced to enhance digital document signing.
Additional upgrades included the launch of myAlpha Business Benefit Advanced for Airbnb professionals and the ability to transfer funds
abroad with Live Exchange Rate. Significant improvements were also made in cards and transaction limits, including corporate card
transaction history up to 18 months and the ability to adjust daily purchase limits on prepaid bizpay cards. Furthermore, the eLG service for
98%
2%
Monetary Transactions
Digital Channels
(Web,Mobile,ATM,APS)
Branch
Reference Period: 2025
Board of Directors’ Report as at 31.12.2025
27 | ANNUAL FINANCIAL REPORT
issuing guarantees via myAlpha Web was made widely available, and the limit for simple imports was raised to Euro 5,000,000, supporting
businesses with increased commercial and transactional needs.
• Distinctions
Alpha Bank received significant distinctions in 2025, validating its digital transformation strategy. Awards included:
o Digital Finance Awards 2025: Five awards, including Gold for the myAlpha Quick Loan and the bizpay app.
o Mobile & IoT Awards 2025: Four awards, including Gold for the bizpay app and the Bonus app.
o e-volution Awards 2025: Four awards, including Gold for Credit Card Acquisition via e-Banking and the bizpay app.
o UX | CX Awards 2025: Four awards, two of which recognize Alpha Bank’s digital assistant.
ATM Network & Automated Payment Systems
Self-Service Banking devices remain the primary service channel for branch transactions. During 2025, 262 studies were conducted to
optimize the ATM network, resulting in 15 new off-site ATMs. A new partnership with a specialized external provider for ATM Monitoring and
Disputes Resolution services increased network availability to over 97%, achieving a 1.1% increase compared to 2024. The ATM network
maintained stable transaction volumes. Additionally, 98% of the Bank’s branch network is equipped with at l east one Automated Payment
Systems (APS), enabling customers to independently carry out deposits and payments.
Digital Sales
In 2025, digital sales through the Bank's channels grew significantly, with 30% of products offered to Retail banking customers sold digitally.
Digital sales of the myAlpha Quick Loan saw a notable increase, with 78% of consumer loans disbursed via digital channels, representing over
50% of total amounts disbursed. Online issuance of debit cards reached 36%, and more than 47% of new term deposits were completed
through digital channels. Additionally, 26% of new accounts were opened using the Retail On Boarding service via myAlpha Mobile. The
myAlpha Vibe application allowed customers to give digital "pocket money" to their children, adopted by over 7,000 families. The new credit
card issuance capability achieved 39% of total cards issued in 2025.
User Experience (UX)
Our Design hub focused on shaping and user testing the new Digital Experience for Mobile App & Web banking for Business & Individuals. Key
design principles include simplicity, facilitation, and personalization. More than 50 digital journeys and episodes were redesigned.
In addition, three other important pillars are being built with new UX Expertise, recognizing their importance for the bank:
a. Design System, bringing consistency, efficiency, and clarity to our UX and digital delivery process. By aligning teams around shared
principles, components, and patterns, we have reduced duplication of effort and accelerated design and development workflows.
This common foundation has improved collaboration across disciplines, enabling designers, developers, and product teams to wo rk
from the same source of truth while maintaining high-quality user experiences.
b. Accessibility Pillar, building and designing Accessibility standards in the Digital Experience, based on the European Accessibility Act
c. Employees System Pillar, for the creation of a friendly digital experience in strategic new employee systems & Customer Journeys,
like Wealth, Mortgage.
Customer Experience (CX)
In 2025, the Bank launched the Universal Customer Experience Program (UCX) to address key pain points and create a 3-year CX strategic
plan. Key projects include the Operational CRM, CX training for front-line staff, and Daily Banking optimization projects. The new Relationship
NPS was rolled out across all Alpha Bank customer segments, including Individuals, Small Business, Wholesale (primarily the Commercial
Division), and Private Banking customers. To assess the Bank’s competitive positioning across segm ents and channels, new Competitive NPS
surveys were also conducted for both Individual and Business segments. Internal NLP (Natural Language Processing) text analysis was
developed and delivered in H2 2025 to enhance the processing of customer comments and support advanced CX initiatives. One such
initiative was the Close the Loop (CTL) mechanism, which was piloted for all Individual-segment detractors in Q4 2025. The corresponding CTL
process for Small Business customers is currently under design, with launch planned.
In Q1 2025, the Front-Line Survey of Retail Employees, was completed to capture all related CX operational challenges. Additional extensive
voice of the Front-Line sessions took place in Q3 2025. The combined insights from Voice of Customer (VoC) and Voice of Employee (VoE)
sources resulted in the creation of a CX Registry, identifying 88 pain points across the Individual and Small Business segments. All pain points
were prioritized and embedded within existing Bank programs or UCX program initiatives. 50% of them are already under solution design or
customer journey re-design, with a commitment to eliminate them by end of 2026.
Finally, as part of the new customer centric culture, CX is actively integrated in the new Purpose & Values employee events (DOTS) and the
cascade of the NPS System in the central divisions. Since Q3 2025 CX training has also been incorporated into the new Alpha Way Induction
program for all new bank hires.
AI – Advanced Analytics
30%
70%
Retail Banking Sales
Digital Channels
(Web,Mobile)
Branch
Reference Period: 2025
78%
22%
Consumer Loans
Digital Channels
(Web,Mobile)
Branch
Reference Period: 2025
Board of Directors’ Report as at 31.12.2025
28 | ANNUAL FINANCIAL REPORT
In 2025, the Bank focused on strengthening AI capabilities, expanding the use of Natural Language Processing (NLP) and generative AI (genAI)
technologies to new use cases, including RM feedback analysis, following client interviews, to automate lead identification and follow-up
campaigns, as well as client feedback (NPS surveys, complaints) analysis to identify key client pain points. We are developing MVPs (Minimum
Viable Product) of AI agents in areas like digital banking, SB, Retail Credit and Internal Audit, mainly focusing on automation of information
retrieval and information synthesis tasks. We are leveraging Microsoft 365 Copilot to
increase employee productivity, maintaining high engagement (>80% active users) and
expanding to additional 350 users. Personalized communications were enhanced
through AI and NLP, leading to a substantial increase in both the volume and
effectiveness of customer interactions. In 2025, we executed 1,904 campaigns,
representing a 28.9% increase compared to 2024. These efforts delivered almost 39
million messages to 3.1 million unique customers, underscoring our commitment to
scale and relevance. The adoption of GenAI technologies further strengthens our
personalized communication strategy, ensuring that each customer receives timely,
relevant offers and information tailored to their needs and preferences. This approach
enhances both customer experience and loyalty to the Bank.
Innovation
In 2025, the Innovation Function advanced Alpha Bank’s innovation agenda, fostering
collaboration and accelerating the adoption of new ideas and solutions. The establishment of the Innovation Committee introduced a
structured governance framework for pilot initiatives, complemented by a fast-track process that speeds up execution while ensuring
compliance.
Open innovation remained a strategic priority, with more than 100 startups evaluated. Through a series of pilot projects, the Bank tested and
validated innovative solutions in areas such as credit assessment using advanced analytics, digital learning to en hance employees’ children’s
skills, online travel services offering secure holiday packages, ESG initiatives encouraging employee participation in social and environmental
actions, accessibility improvements for customers with hearing impairments, and new value propositions for younger customers. In addition,
the Painted Door Testing method was applied to assess early-stage customer interest. Many pilots have delivered positive and actionable
results, while others are still in progress as part of the Bank’s innovation pipeline.
The Innovation Function also organized Innovation Day, a flagship conference dedicated to Artificial Intelligence. For the first time, a Greek
bank brought together representatives from across the entire banking sector, alongside leaders from other industries, to engage in an open
dialogue on AI and its impact. By doing so, the Bank acted as a convener of the ecosystem, fostering collaboration and shared learning around
emerging technologies. In 2025, the Bank also organized the 4th edition of the international innovation competition FinQuest, fully focused
on Artificial Intelligence. The competition attracted proposals from 20 countries, highlighting its strong international reach. Seven finalists
joined a two-month accelerator, and the top three teams—Dikaio.ai (1st), Dry Run Z (2nd), Agri Now (3rd)—received financial awards and
development support, with the winner piloting its solution at the Bank.
Externally, the Bank strengthened its presence in the innovation ecosystem by participating in notable events such as the Microsoft
innovation competition and the Foundation Conference, engaging widely with startups, corporates, and technology leaders. Through these
efforts, the Bank continues to foster innovation, share knowledge, and contribute to dialogue around emerging technologies.
International
Significant progress was also made in the foreign subsidiaries in 2025:
➢ Alpha Bank London
The successful implementation of the new Core Banking System marks a pivotal milestone in Alpha Bank London’s transformation
programme, strengthening operational resilience and laying the foundation for Bank's future aggressive growth strategy. The rollout of the
online banking is progressing well and remains on track for completion in phases in Q1 and Q2 2026. In parallel, development of the new
Group’s Retail Mobile app is advancing as planned, with a first launch scheduled for Q4 2026 and full go-live targeted for mid-2027,
supporting the Group’s strategic ambition to deliver a unified, next-generation digital experience.
Complementing these initiatives, the CRM MVP (Minimum Viable Product) has successfully gone live, enabling enhanced customer
engagement and streamlined relationship management—critical for driving personalisation and loyalty. Additionally, a new Debit Card is
under development and expected to launch in Q1 2026, reinforcing the bank’s payments modernisation roadmap and competitive po sitioning
in the retail segment.
➢ Alpha Bank Cyprus
Alpha Bank Cyprus continues to advance its 2025–27 Transformation Program alongside the Astro Bank operational merger, ensuring stability
while accelerating modernization and growth readiness. Of 77 initiatives, 50 are completed, 16 in progress, and 11 in the pipeline. Building on
this momentum, the Bank has identified 16 flagship projects to strengthen customer, digital, and operational capabilities. Key priorities
include the CRM platform, digital onboarding for individuals, companies, and international clients, complemented by Digital KYC Review.
Additional initiatives focus on loan workflow automation, enhanced digital services via Alpha 360, payments platform optimization, and
establishing an Automation Factory. Following the legal acquisition of Astro Bank on 31.10.2025, the Bank is prioritizing system migration and
initiatives that support business growth and profitability, laying a robust foundation for market share expansion and value creation post-
merger.
OTHER
Alpha Bank’s Share Capital
On 31.12.2025, Alpha Bank S.A share capital stood at Euro 671,425,793.82 million divided into 2,315,261,358 common, nominal, paperless
shares with voting rights, of a nominal value of Euro 0.29 each, which are listed for trading on the Securities Market of the Athens Stock
Exchange ("ATHEX").
UniCredit
1477
1904
0
400
800
1200
1600
2000
2024 2025
Campaign Comparison 2024 vs 2025
+28.9%
Board of Directors’ Report as at 31.12.2025
29 | ANNUAL FINANCIAL REPORT
According to the announcement made by UniCredit S.p.A. (“UniCredit”) on 30.10.2025, UniCredit has received ECB authorization to acquire a
direct stake in Alpha Bank S.A. of up to 29.9%.
On 5.1.2026 Unicredit announced the conversion of a c. 20% synthetic position in Alpha Bank S.A. having received all necessary legal and
regulatory approvals, taking its share ownership and effective voting rights to 29.796% of the total. As per the same announcement UniCredit
has entered into certain financial instruments with Alpha Bank S.A. shares as underlying security, which instruments provide for cash
settlement as the default method and physical settlement as an alternative, subject to receiving all necessary regulatory approvals. If physical
settlement is opted for, it may result in the acquisition of additional common shares with voting rights corresponding to 2.272% of the total
voting rights of Alpha Bank S.A. resulting in a total holding of 32.069% of voting rights. It is noted that until - and subject to - the physical
settlement of the relevant financial instruments, UniCredit S.p.A. does not have any influence over the exercise of the voting rights attached
to the shares underlying such financial instruments.
Type of Financial
Instrument
Expiration Date
Exercise / Conversion
Period
Number of voting rights
% of voting rights
Total Return Swap
27.3.2026
28. 5.2025 - 27. 3.2026
8,735,935
0.377%
Total Return Swap
27.3.2026
19.12.2025 – 27.3.2026
5,300,000
0.229%
Total Return Swap
3.4.2026
25.8.2025 – 3.4.2026
22,393,395
0.967%
Total Return Swap
24.3.2026
25.5.2025 - 24.3.2026
9,516,837
0.411%
Put/Call Combination
16. 1.2026
23.12.2025-16.1.2026
6,666,667
0.288%
Total
52,612,834
2.272%
Stock price
In 2025, the Company’s share price increased from Euro 1.62 to Euro 3.58, up by 121.4%. Over the same period, the EURO STOXX Banks
Index, the main stock market index that tracks the performance of large banking sector companies within the Eurozone, increased by 80.3%.
Treasury shares
A share buyback program was approved and amended by the Ordinary General Shareholders Meetings on 27.7.2023 and 24.7.2024 of Alpha
Services and Holdings S.A. accordingly, for the acquisition of own shares to serve any and all purposes permitted by applicable laws and the
regulatory framework, including the free distribution of treasury shares to Members of Management and Personnel of the Company and its
Affiliates, within the meaning of article 32 of Law 4308/2014 (the “Share Buyback Program”).
More specifically, in the context of the dividend distribution program for the year 2023 the Alpha Services and Holdings S.A. during the 1st
quarter of 2025 repurchased 5,649,854 treasury shares amounting Euro 9 and thus completed the program by repurchasing in total
38,550,720 treasury shares for a total cost of Euro 61. The said 38,550,720 treasury shares were cancelled on 27.6.2025, following the
resolutions of the Extraordinary General Shareholders’ Meeting of Alpha Services and Holdings S.A.
During the Annual General Shareholders’ Meeting of Alpha Services and Holdings S.A. on 21.5.2025 the above-mentioned Share Buyback
Program was terminated and a new one was established noting that the new Share Buyback Program would also be adopted and respectively
implemented by the Bank , as the surviving entity of the Reverse Merger. Following the above, the Extraordinary General Shareholder
Meeting of the Bank on 12.6.2025, decided the establishment of a Share Buyback Program, as per the terms and conditions of the Share
Buyback Program approved by Alpha Services and Holdings S.A. , for the acquisition of own shares in accordance with article 49 of L.
4548/20218, that will serve any and all purposes permitted by applicable laws and the regulatory framework, including the free distribution
of treasury shares to Members of the Management and the Personnel of the Bank and its Affiliates, within the meaning of article 32 of Law
4308/2014, as well as, the acquisition and the consequent cancellation of own shares in the context of the dividend distribution policy
towards the shareholders.
In addition, the subsidiary company Alpha Finance S.A. performs transactions with the shares of the Bank in the context of market making. As
at 31.12.2025 the carrying amount of the treasury shares was Euro 5.
The transactions of treasury shares of the Group and the Bank are described below:
30
Alpha Bank S.A.
Alpha Services and Holdings S.A.
Total (a)
Alpha Finance S.A. (b)
Total Group (a)+(b)
Dividend distribution
Share awards
Dividend distribution
Share awards
Market making
No. of
shares
Carrying
amount
No. of
shares
Carrying
amount
No. of
shares
Carrying
amount
No. of
shares
Carrying
amount
No. of
shares
Carrying
amount
No. of
shares
Carrying
amount
No. of
shares
Carrying
amount
Balance 1.1.2024
-
-
-
-
-
-
5,855,794
9
5,855,794
9
1,385,675
2
7,241,469
11
Changes for the period 1.1-31.12.2024
Purchases
32,900,866
51
32,900,866
51
41,632,447
66
74,533,313
117
Sales
(38,906,960)
(61)
(38,906,960)
(61)
Share awards
(3,690,333)
(6)
(3,690,333)
(6)
(3,690,333)
(6)
Balance 31.12.2024
-
-
-
-
32,900,866
51
2,165,461
3
35,066,327
54
4,111,162
7
39,177,489
61
Changes for the period 1.1-31.12.2025
Purchases
26,260,464
93
3,501,556
11
5,649,854
10
1,123,533
3
36,535,407
117
65,782,307
173
102,317,714
290
Sales
(68,733,129)
(175)
(68,733,129)
(175)
Share awards
(992,440)
(3)
(3,288,994)
(6)
(4,281,434)
(9)
(4,281,434)
(9)
Cancelation
(38,550,720)
(61)
(38,550,720)
(61)
(38,550,720)
(61)
Balance 31.12.2025
26,260,464
93
2,509,116
8
-
-
-
-
28,769,580
101
1,160,340
5
29,929,920
106
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
31 | ANNUAL FINANCIAL REPORT
Number of Branches
As at 31.12.2025 the Group is operating with 270 Branches, out of which 244 are established in Greece and 26 are established abroad.
Events after the balance sheet date
1. In January 2026 the Bank repurchased 10,125,018 of its Treasury Shares with a cost of € 39 million, in the context of the distribution to
shareholder for the 2024 according to the Shareholder Remuneration Policy and the distribution of share awards to employees.
2. On 14.1.2026 the Executive Committee of the Bank approved a new Voluntary Exit Scheme programme with an estimated cost of € 44 million
and an estimated participation of 350 employees. The program was completed on 30.1.2026.
3. On 23.1.2026, the Bank participated pro-rata to its shareholding (26.46%) in the share capital increase of its associate company REOCO SOLAR
S.A. with an amount of €6.61 thousand.
4. On 23.1.2026, the reorganization of the Group's subsidiary, Alpha Leasing S.M.S.A. was completed by way of a common demerger and
dissolution of the company, in accordance with all applicable laws and regulations and approved by the General Commercial Registry (GEMI).
Through the Demerger, the performing leasing contracts of Alpha Leasing along with the related real estate interests were transferred to the
newly established and licensed leasing company of the Group, Alpha Leasing Single Member S.Α. (ex. Alpha Ereunas Agoras SMSA). Further, a
selected perimeter of mainly non-performing financial leases along with the related real estate interests with a Gross Book Value of
approximately Euro 0.24 billion, was transferred to Hellas Capital Leasing Single Member Société Anonyme (“HCL”), in exchange of newly issued
shares in HCL (the “Temporary HCL Shareholding Interest”) to Alpha Holding S.A., which was the sole shareholder of Alpha Leasing. Furthermore,
certain other real estate assets of Alpha Leasing were transferred to Group companies.
Following the completion of the Demerger, Alpha Holding S.A., proceeded with the sale and transfer of the Temporary HCL Shareholding
Interest, to HCL’s main shareholder.
The financial impact of the above on the Group’s capital and liquidity is immaterial. The reorganization through the Demerger forms part of the
targeted transformation initiatives in the context of the Strategic Plan of the Group, aiming to strengthen the prospects for further expanding
its activities in the financial leasing sector.
5. On 3.2.2026, Alpha Bank S.A. invited the holders of its € 450 million fixed-rate reset senior preferred notes, maturing on 16 June 2027, to tender
their notes for cash at a price of 101.80% of their nominal value. On 12 February 2026, notes with a total nominal amount of € 293.97 million
were validly tendered and redeemed, while notes with a total nominal amount of € 156.03 million remain outstanding.
6. On 10.02.2026, Alpha Bank S.A. issued new Senior Preferred bonds with a reset clause, with a nominal value of € 750 million maturing on
February 10, 2033, a call option on February 10, 2032, and a fixed annual coupon of 3.5%, which resets to a new coupon from the call date
until maturity, determined based on the then-prevailing swap rate plus a margin of 0.90%
7. In February 2026, it was announced that the Plenary Session of the Supreme Court (Areios Pagos), following deliberations resolved by a
majority that the calculation of interest on non-performing loans which have been restructured under Law 3869/2010 must be based on each
monthly installment rather than on the principal amount of the debt. The official publication of the judgement and the analysis of its
reasoning are currently pending. The Group anticipates the official issuance and publication of the judgement in order to assess its potential
impact on the financial statements.
Application of par. 3 article 97 and article 99 of Law 4548/2018
During 2025, in application of article 97 par. 3 of Law 4548/2018, the Executive Members of the Board of Directors (BoD) of Alpha Bank S.A.
(the “Bank”), Messrs. V.E. Psaltis and S.N. Filaretos (BoD Member until 27.2.2025), abstained in total on three (3) occasions during BoD
meetings, where decisions were made on the following agenda items: the Material Risk Takers (MRTs) list for the year 2024 at Group level, the
amendments of the Combined Bonus Plan as well as the Gates and Bonus Pool for the 2024 Combined Bonus Plan, as they are included in the
perimeter of the Band Senior Leadership Team (SLT).
Moreover, the Executive Members of the BoD of the Bank, Messrs. V.E. Psaltis and L.A. Papagaryfallou (BoD Member since 27.2.2025),
abstained in total on ten (10) occasions during BoD meetings, where decisions were made on the following agenda items: the MRTs list for the
year 2025 at Group level, the Bonus Plan Amendments, the increase of the maximum ratio between the fixed and variable components of
remuneration for Executives of the Bank and the Group, the award under the Combined Bonus Plan 2024, the profit distribution to Bank’s
Staff, the Goal setting 2025 (2025 Scorecard) for the Chief Executive Officer and the Deputy Chief Executive Officer, the SLT variable
remuneration ranges, the amendments to the 2025 Remuneration Policy for Alpha Bank and the other Companies of the Group along with the
Variable Remuneration Framework Annex as well as the extension of the already existing 2025 Group Benefits and Corporate Expenses Policy
for 2026 as well, as they are Members of the Executive Committee and are included in the perimeter of Band SLT.
Furthermore, the Chair, Mr. D.C. Tsitsiragos, abstained on one (1) occasion during a BoD meeting where a decision was made on his annual
remuneration.
The Non-Executive Member of the BoD, Mr. J.-H.-F.G. Umbgrove abstained on one (1) occasion during a BoD meeting where a decision was
made on his nomination as Independent Non-Executive Member of the Board.
The Independent Non-Executive Member of the BoD, Mr. J.L. Cheval, abstained on one (1) occasion during a BoD meeting where a decision
was made on his participation in the Board of Directors of GIFI.
The Independent Non-Executive Member of the BoD, Ms. D.C. Lebot, abstained on two (2) occasions during BoD meetings where a decision
was made on her participation in the board of directors of Barclays PLC as well as to her new board role as Chair of the board of directors of
Barclays Bank Ireland PLC.
The Independent Non-Executive Member of the BoD, Ms. E.R. Hardwick, abstained on one (1) occasion during a BoD meeting where, after
reviewing the issue of the Board Member with knowledge and experience related to Information and Communication Technology (ICT) and
security risk, the BoD ascertained its collective competence with regard to the sufficient knowledge and experience related to ICT and security
risk, in line with the European Central Bank’s (ECB) Supervision Newsletter on “New policy for more bank board expertise on ICT and security
risks”.
The Independent Non-Executive Member of the BoD, Mr. P.I.-K. Papazoglou, and the Non-Executive Member of the BoD, Ms. A.G. Areni,
abstained on one (1) occasion during a BoD meeting where a decision was made on the assignment to an audit firm of the audit of the
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
32 | ANNUAL FINANCIAL REPORT
Financial Statements of Alpha Bank S.A. and the Group Companies in Greece and abroad for the year 2027 and for a maximum period of ten
years, subject to annual assessments, due to the connection of the said Members with the audit firms considered for the assignment.
The Non-Executive Member of the BoD Ms. A.G. Areni abstained on three (3) occasions during BoD meetings where decisions were made on
the update of the Euro Medium Term Note (EMTN) Programme, since the recommendations include the appointment of UniCredit as Arranger
of the Programme as well as dealer of the Programme together with the Bank, on the amendment of the International Syndication Policy
regarding a new special limit for Italy as well as on the update on the Strategic Partnership with UniCredit and the approval of the Cooperation
Agreement with UniCredit, due to her relation with UniCredit.
Moreover, in application of article 99 of Law 4548/2018, the BoD granted special authorization on 31.7.2025 for the execution of the
transaction pertaining to the purchase by the Bank of a horizontal property (store) from the company with the corporate nam e “ALPHA
EPENDYTIKIS PERIOUSIAS KALLITHEAS MONOPROSOPI ANONYMOS ETAIREIA A.E.”, who is related party with the Bank, in accordance with
articles 99-101 of law 4548/2018, after having taken into account the Fairness Opinion dated 21.7.2025, prepared by NAlRealAct, through
which it was assessed that the terms of the transaction are fair and reasonable for the Bank and its Shareholders who are not related parties,
including minority Shareholders. The above-mentioned decision was registered to the General Commercial Registry (G.E.MI.) on 12.8.2025. On
28.8.2025 the Board of Directors announced to G.E.MI. its confirmation, pursuant to article 101 par. 2 of law 4548/2018, for the inactive lapse
of the 10-day period deadline, which is provided for in article 100 par. 3 of the said law for the exercise by the Shareholders of the right to
convene a General Meeting for this issue.
Transactions with Related Parties
According to the corresponding regulatory framework, this report must include the main transactions with related parties. All the transactions
between related parties are performed in the ordinary course of business, conducted according to market conditions and are authorized by
corresponding management personnel.
A. The outstanding balances of the Group’s transactions with key management personnel consisting of members of the Bank’s Board of
Directors and the Executive Committee, their close family members and the entities controlled by them, as well as, the results related to these
transactions are as follows:
Group
(Amounts in thousands €)
31.12.2025
31.12.2024
Assets
Loans and advances to customers
3,733
3,181
Total Assets
3,733
3,181
Liabilities
Due to customers
5,758
5,222
Employee defined benefit obligations
158
278
Debt securities in issue and other borrowed funds
1,538
4,268
Provisions
2,615
1,011
Total Liabilities
10,069
10,779
Letters of guarantee and approved limits
410
422
Group
(Amounts in thousands €)
From 1 January to
31.12.2025
31.12.2024
Income
Interest and similar income
125
151
Fee and commission income
9
6
Total
134
157
Expenses
Interest expense and similar charges
123
174
Remuneration of Board members, salaries and wages
13,469
14,052
Total
13,592
14,226
Remuneration of key executives and their closest relatives is analyzed as follows:
Group
(Amounts in thousands €)
From 1 January to
31.12.2025
31.12.2024
Remuneration of Board members, salaries and wages
8,118
7,511
Benefits paid
20
14
Bonus incentive program expenses
3,775
3,862
Severance payment
648
1,890
Employer contributions
683
603
Other
225
172
Total
13,469
14,052
In addition, according to the decision of the General Meeting of Shareholders held at 29.6.2018, a compensation scheme is operating for the
Bank’s Senior Management, the terms of which were specified through a Regulation issued subsequently. The program is voluntary, does not
constitute business practice and it may be terminated in the future by a decision of the General Meeting of the Shareholders. The program
provides incentives for the eligible personnel to comply with the terms of departure, proposed by the Bank, thus ensuring the smooth (only
during the period and under the terms and conditions approved by the Bank) departure and succession of Senior Management.
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
33 | ANNUAL FINANCIAL REPORT
At the end of October UniCredit S.p.A («UniCredit») disclosed that through shares and synthetic financial instruments it has increased its
participation in the Bank by more than 20%, and as a result became the main shareholder.
B. The outstanding balances of the transactions with UniCredit and its related companies as at 31.12.2025 are as follows:
Group
(Amounts in thousands €)
31.12.2025
31.12.2024
Assets
Due from financial institutions
321,048
Derivate financial instruments
1,071
Other Assets
100
Total
322,219
-
Liabilities
Due to banks
313,969
Derivative financial liabilities
97,539
Other Liabilities
346
Total
411,854
-
Letters of guarantee ,others guarantees and undrawn commitments
The results from the transactions with UniCredit and its related companies are as follows:
Group
(Amounts in thousands €)
From 1 November to
31.12.2025
31.12.2024
Income
Interest and similar income
685
Fee and commission income
2,101
Other income
100
Total
2,886
-
Expenses
Interest expense and similar charges
1,206
Commission expenses
68
General administrative expenses
25
Total
1,299
-
C. The outstanding balances with the Bank’s subsidiaries as well as the results related to these transactions are as follows :
Name
Assets
Liabilities
Income
Expenses
Letters of Guarantee ,others
guarantees and undrawn
commitments
Banks
1
Alpha Bank London Ltd
20,479
25,825
10,857
6,682
45,840
2
Alpha Bank Cyprus Ltd
158,444
1,604,333
12,161
28,682
24,920
Leasing companies
1
Alpha Leasing S.A.
188,430
59,664
6,373
10
37,163
2
Alpha Leasing Romania IFN A.E.
760
3
ABC Factors S.A.
684,537
5,249
19,909
4
Alpha Erevna Agoras S.M.S.A.
143,358
5
FlexFin S.A.
20,177
1,991
305
4,951
Investment Banking
1
Alpha Finance A.E.P.E.Y.
46,211
34,557
3,587
1,139
2
Alpha Ventures S.A.
1,080
21,677
3
Alpha Ventures Capital Management-AKES
137
4
Emporiki Ventures Capital Emerging Markets Ltd
95
5
AXIA Ventures Group Ltd
304
Asset Management
1
Alpha Asset Management A.E.D.A.Κ.
10,473
73,582
32,728
1,100
69
2
ABL Independent Financial Advisers Ltd
Insurance
1
Alphalife A.A.E.Z.
8,865
47,030
10,861
496
11
2
Astrobank insurance agency Ltd
Real estate and hotel
1
Alpha Real Estate Services S.A.
15,226
63,506
67
13,470
4,498
2
Alpha Real Estate Management and
Investments S.A.
30,737
1
169
3
Alpha Investment Property Attikis S.A
5,641
1
52
4
Stockfort Ltd
1,905
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
34 | ANNUAL FINANCIAL REPORT
Name
Assets
Liabilities
Income
Expenses
Letters of Guarantee ,others
guarantees and undrawn
commitments
5
APE Fixed Assets S.A.
119
1
6
AGI-SRE Participations 1 D.O.O.
19,531
7
Alpha Investement Properties Commercial
Assets I S.M.S.A.
1,907
17,569
1
638
8
AIP INDUSTRIAL ASSETS S.M.S.A.
2,230
1
9
Alpha Group Real Estate Ltd
6,906
10
AIP Residential Assets Rog S.M.S.A.
320
11
AIP Attica Residential Assets I S.M.S.A.
1,240
12
AIP Thessaloniki Residential Assets S.M.S.A.
4,390
13
AIP Cretan Residential Assets S.M.S.A.
3,678
14
AIP Aegean Residential S.M.S.A.
7,200
15
AIP Ionian Residential Assets S.M.S.A.
2,864
16
AIP Attica Residential Assets III S.M.S.A.
1,182
17
AIP Attica Residential Assets II S.M.S.A.
1,319
18
AIP Land II S.M.S.A.
2,691
19
AIP Attica Residential Assets IV S.M.S.A.
9,119
20
AIP Commercial Assets ΙΙ S.M.S.A
7,328
21
AIP Commercial Assets III .M.S.A.
411
22
Abinvest II S.M.S.A.
21,348
23
Abinvest I S.M.S.A.
51,357
24
Abinvest III S.M.S.A.
43,885
25
AEP Oikistikon Akiniton Attikis V S.M.S.A.
10,040
66
26
AEP Perifereias II S.M.S.A.
9,897
56
27
Greco Delta S.M.S.A.
439
28
HIGR S.M.S.A.
821
29
Ιόλαος Κτηματική Μ.Α.Ε.
14,737
564
30
Alkanor S.M.S.A.
25,984
2,053
Special purpose and holding entities
1
Alpha Group Investments Ltd
57,532
839
2
Ionian Equity Participations Ltd
8,752
3
AGI-RRE Participations 1 Ltd
10,000
260
4
AGI-RRE Poseidon Ltd
171
5
AGI-RRE Hera Ltd
1,528
6
ALPHA HOLDINGS SINGLE MEMBER S.A
4,337
58
55
7
AGI-BRE Participations 4 Ltd
537
8
AGI-RRE Ares Ltd
100
9
AGI-RRE Artemis Ltd
148
10
Zerelda Ltd
1,352
11
AGI-Cypre Ermis Ltd
206
12
Alpha Credit Acquisition Company Ltd
159,126
5,891
8,735
13
Alpha Internatioal Holdings S.M.S.A
43,140
10,144
8,325
14
FlexFin Ltd
2,872
54
15
Alpha Holding Luxembourg S.A.
1,575
Other Companies
1
Alpha Supporting Services S.A.
721
22,373
1,073
1,902
4
2
Emporiki Management S.A.
2,544
5
3
Alpha Bank Debt Notification Services S.A.
1,239
Total
1,387,720
2,316,343
117,626
63,680
282,492
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
35 | ANNUAL FINANCIAL REPORT
D. The outstanding balances with the Bank’s associates as well as the results related to these transactions are as follows:
Name
Assets
Liabilites
Income
Expenses
ΑEDEP Thessalias and Stereas Ellados
720
Alpha Investment Property Elaiona S.A
57
2,419
61
Aurora SME I DAC
47
6,053
Alpha Blue Finance Designated Activity Company
70
11,48
Cepal
178,323
47,224
2,998
17,389
Alpha Compass DAC
1,183
16,913
Nexi Payments Hellas S.A.
87,277
855
9,35
1,78
Propindex AEDA
268
Skyline Properties M.S.A.
64,462
110,009
5,142
3,997
Banking Information Systems S.A.
1,963
Zero Energy Buildings Energy Services S.A.
37
Perigenis Commercial Assets S.A.
22,14
Τοtal
331,419
185,636
17,552
57,612
Within the reporting period total transaction costs for the Gaia Transaction of € 17,735 thsd. were incurred between the Bank and the Group’s
associate company “Cepal Holdings S.A.”. As at 31.12.2025 Alpha Bank has acquired fixed assets of € 1,600 thsd. from Skyline group.
E. The outstanding balances with the Bank’s joint ventures as well as the results related to these transactions are as follows:
Name
Assets
Liabilites
Income
Expenses
APE Commercial Property Α.Ε.
13
537
14
Alpha Taneo A.K.E.S.
230
APE Commercial Property Α.Ε.
6
21
10
487
APE INVESTMENT PROPERTY A.E
40
9,884
116
AVRAMAR
72,705
331
ISIDE SPV SRL
25,726
1,863
12
Τοtal
98,491
10,672
2,335
500
F. The results with the Bank’s former parent Company Alpha Services and Holding S.A until the merger date are as follows:
Bank
From 1 January to
(Amounts in thousands €)
27.6.2025
31.12.2024
Income
Interest and similar income
638
770
Fee and commission income
11,355
11,750
Other income
552
591
Total
12,544
13,111
Expenses
Interest expense and similar charges
29,702
25,965
Gains less losses on financial transactions
5,363
17,942
Impairment losses and provisions to cover credit risk
4
31
Total
35,065
44,338
IOPR, founded in March 2023, is a post-employment benefit plan for the benefit of the employees of the Group of Alpha Bank S.A., that aims
to provide additional insurance protection, beyond that provided by the main and auxiliary social security with a salaried mandate relationship
or with a dependent work relationship of indefinite duration. More specifically the subsidiary companies participating are ABC Factors S.A.,
Alpha Asset Management A.E.D.A.K, Alpha Bank S.A., Alpha Finance A.E.P.E.Y., Alpha Leasing S.A., Alpha Real Estate S.A., Alpha Supporting
Services S.A., Alphalife A.A.E.Z.
The results related to the transactions with IOPR are as follows:
Bank
(Amounts in thousands €)
From 1 January to
31.12.2025
31.12.2024
Expenses
Staff cost and expenses
6,934
6,690
IOPR, keeps a deposit with the Bank amounting to € 44 thsd. as at 31.12.2025 (31.12.2024: € 24 thsd.)
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
36 | ANNUAL FINANCIAL REPORT
Explanatory Report of the Board of Directors of Alpha
Bank S.A. for the year 2025
A. INTRODUCTION
The present Explanatory Report of the Board of Directors of Alpha Bank S.A. (hereinafter the “Bank”) for the year 2025 to the
Ordinary General Meeting of the Shareholders of the Bank contains detailed information, pursuant to the provision of article
4 pars. 7 and 8 of Law 3556/2007, with reference date 31.12.2025, in accordance with the order in which it appears in the
said provision. In particular:
B. INFORMATION
B1.
On 31.12.2025 the share capital of the Bank stood at the total amount of Euro
671,425,793.82, divided into 2,315,261,358 common, registered, dematerialized shares with
voting rights, of a nominal value of Euro 0.29 each. All shares are listed for trading on the
Regulated Market of the Athens Exchange.
The share capital of the Bank as of 31.12.2025 was formed following the share capital
increase pursuant to the resolution of 26.9.2025 of the Board of Directors of the Bank, in
accordance with article 113 par. 3 of Law 4548/2018, in the context of the implementation of
the Stock Options Plan, following the resolution of the Ordinary General Meeting of the
Shareholder of the Bank dated 21.5.2025, which approved the Stock Options Plan, as it had
been originally approved by the Ordinary General Meeting of the Shareholders of Alpha
Services and Holdings S.A. (former Alpha Bank S.A.) dated 31.7.2020. The Ordinary General
Meeting of the Shareholders of Alpha Services and Holdings S.A further resolved to continue
the Stock Options Plan’s implementation for the two remaining vesting periods following the
completion of the merger by absorption of Alpha Services and Holdings S.A. by Alpha Bank
S.A (i.e., September 2025 and September 2026), by the amount of Euro 39,823.38, by issuing
and granting to the Stock Options Beneficiaries/Employees of the Bank and its Affiliated
Companies 137,322 common, registered, dematerialized shares of the Bank with voting
rights, of a nominal value of Euro 0.29 each.
Each share incorporates all rights and obligations as these derive from Law 4548/2018 and
the Bank’s Articles of Incorporation, the provisions of which are in line with the provisions of
the Law, including, among others, the right to participate in and vote at the General Meeting
of Shareholders, the right to access the Annual Financial Report, with all the statements and
reports it incorporates, the preemptive right to each share capital increase in cash and to
each issue of new shares as well as the right to a dividend, as specified in the applicable legal
framework, when a dividend distribution is decided by the Bank, pursuant to articles 159 et
seq. of Law 4548/2018 and article 149A of Law 4261/2014. Each share carries one vote in any
General Meeting of Shareholders.
Bank’s Share Capital
Structure
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
37 | ANNUAL FINANCIAL REPORT
B2.
The Bank’s shares are listed for trading on the Athens Exchange and are transferred
according to the law.
The Articles of Incorporation of the Bank contain no restrictions on the transfer of its shares,
save as otherwise provided for in the law.
Restrictions on the transfer
of the Bank’s shares
B3.
According to Law 3556/2007, as amended and in force, the following significant
shareholdings in the Bank’s share capital have been notified to the Bank:
• On 1.7.2025, Alpha Bank announced, in accordance with the provisions of Law
3556/2007, that UniCredit S.p.A., following a relevant notification dated 30.06.2025,
holds 9.768% of the total voting rights of the Bank. This change follows the completion
of the merger (as defined above). Furthermore, UniCredit S.p.A. notified the Bank that it
holds financial instruments which may be settled, by cash as the default option or,
alternatively, by physical settlement, subject to the condition of having obtained all the
necessary regulatory approvals. These instruments may potentially result in the
acquisition of 247,918,401 common, registered shares, representing 10.709% of the
Bank’s total voting rights, thus UniCredit S.p.A.’s total voting rights in the Bank would
amount to 20.477%. (For more information, please refer to the announcement, through
the link https://www.alpha.gr/-/media/AlphaGr/Files/Group/Corporate-
Announcements/2025/20250701etairikianakoinosi-en.pdf ).
• On 29.8.2025, Alpha Bank, pursuant to the provisions of Law 3556/2007, informed the
investors that, according to the notification dated 28.8.2025 by UniCredit S.p.A. in the
context of article 11 par. 1 (b) of Law 3556/2007, the latter’s participation in financial
instruments increased on 25.8.2025, with the default method being cash settlement
and, alternatively, physical settlement, which, subject to physical settlement and all
necessary regulatory approvals, may potentially result in the acquisition of additional
107,770,830 common shares with voting rights, corresponding to 4.655% of the total
voting rights of Alpha Bank. (For more information, please refer to the announcement,
through the link https://www.alpha.gr/-/media/AlphaGr/Files/Group/Corporate-
Announcements/2025/20250829-etairiki-anakoinosi-en.pdf).
• On 30.10.2025, Alpha Bank, pursuant to the provisions of Law 3556/2007, informed the
investors that, according to the notification dated 29.10.2025 by UniCredit S.p.A. in the
context of article 11 par. 1 (b) of Law 3556/2007, the latter’s participation in financial
instruments increased on 24.10.2025, with the default method being cash settlement
and, alternatively, physical settlement, which, subject to physical settlement and all
necessary regulatory approvals, may potentially result in the acquisition of additional
102,121,889 common shares with voting rights, corresponding to 4.410% of the total
voting rights of Alpha Bank. (For more information, please refer to the announcement,
through the link https://www.alpha.gr/-/media/AlphaGr/Files/Group/Corporate-
Announcements/2025/20251030-etairiki-anakoinosi-en.pdf).
• On 13.11.2025, Alpha Bank, pursuant to the provisions of Law 3556/2007, informed the
investors that, according to the notification dated 12.11.2025 by UniCredit S.p.A. in the
context of article 11 par. 1 (b) of Law 3556/2007, the latter’s participation in financial
instruments increased on 10.11.2025, with the default method being cash settlement
and, alternatively, physical settlement, which, subject to physical settlement and all
necessary regulatory approvals, may potentially result in the acquisition of additional
5,859,978 common shares with voting rights, corresponding to 0.253% of the total
voting rights of Alpha Bank. (For more information, please refer to the announcement,
through the link https://www.alpha.gr/-/media/AlphaGr/Files/Group/Corporate-
Announcements/2025/20251113-etairiki-anakoinosi-en.pdf).
Significant direct and indirect
shareholdings as per Greek Law
3556/2007
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
38 | ANNUAL FINANCIAL REPORT
• According to a notification received on 9.1.2026 from UniCredit S.p.A. and in accordance
with article 11 par. 1 (b) of Law 3556/2007, on 5.1.2026 UniCredit exercised financial
instruments, resulting in an increase of its direct shareholding in Alpha Bank to
689,860,498 common, registered shares with voting rights, representing 29.796% of the
total voting rights of Alpha Bank. As a result, UniCredit increased its direct shareholding
in the Bank from 9.768% to 29.796% of its total voting rights (For more information,
please refer to the announcement, through the link https://www.alpha.gr/-
/media/AlphaGr/Files/Group/Corporate-Announcements/2026/20260109-etairiki-
anakoinosi-en.pdf).
B4.
There are no shares issued by the Bank granting special rights of control to their holders.
Shares with special rights of
control
B5.
The Articles of Incorporation contain no restrictions on voting rights and on the exercise
periods of voting rights on shares issued by the Bank.
Restrictions on voting rights
B6.
To the knowledge of the Bank, there are no shareholder agreements providing for
restrictions on share transfers or restrictions on the exercise of voting rights on shares
issued by the Bank.
Shareholder agreements
B7.
There are no rules in the Articles of Incorporation for the appointment and replacement of
Members of the Board of Directors as well as for the amendment of the Articles of
Incorporation of the Bank, which are at variance with the stipulations of the legal and
regulatory framework, including Law 4548/2018, as in force.
Relevant provisions regarding the appointment and replacement of Members of the Board
of Directors are mainly included in:
• the Hellenic Corporate Governance Code of the Hellenic Corporate Governance
Council, dated June 2021, adopted and implemented by the Bank,
• the Charter of the Board of Directors,
• the Suitability and Nomination Policy for the Members of the Board of Directors and
Key Function Holders,
• the Suitability and Nomination Process for the Members of the Board of Directors,
• the Policy for the Succession Planning of Senior Executives and Key Function Holders.
Rules regarding the
appointment and replacement
of Members of the Board of
Directors and amendments of
the Articles of Incorporation
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
39 | ANNUAL FINANCIAL REPORT
B8.
The Bank may increase its share capital by virtue of a resolution of the General Meeting of
Shareholders or of the Board of Directors, in accordance with the law and the Articles of
Incorporation.
In accordance with article 6 of the Bank’s Articles of Incorporation, the General Meeting of
Shareholders may, by virtue of a resolution, delegate to the Board of Directors the power
to decide, by a majority of two thirds (⅔) of its Members and within five (5) years from the
date of the relevant resolution, on the increase of the share capital with the issuance of
new shares. The amount of the increase may not exceed three times the amount of the
share capital existing on the date of the delegation to the Board of Directors of the relevant
power to increase the share capital. The above apply accordingly to the issuance of
convertible bonds, in accordance with article 71 of Law 4548/2018. The above authority of
the Board of Directors may be renewed by the General Meeting of Shareholders for a
period not exceeding five (5) years for each renewal.
It is noted that there are no resolutions of the General Meeting of Shareholders in force for
the concession of the above authority to the Board of Directors.
Stock Options Plan
On 21.5.2025, the Ordinary General Meeting of the Shareholder of the Bank, following a
relevant recommendation by the Board of Directors, in view of the completion of the
merger by absorption of its parent company “Alpha Services and Holdings S.A.” by the
Bank, approved the Stock Options Plan, as originally approved by the Ordinary General
Meeting of the Shareholders of Alpha Services and Holdings S.A. on 31.7.2020, and decided
to continue its implementation for the two remaining vesting periods following the
completion of the merger (i.e., September 2025 and September 2026). According to the
Stock Options Plan, each stock option right granted, in accordance with article 113 of Law
4548/2018, corresponds to one (1) new share. The offer price of each new share is equal to
the nominal value of the share. After the timely payment by the Beneficiaries of the value
of the shares corresponding to the option rights exercised by them, the Board of Directors
will proceed with a corresponding increase of its share capital, in accordance with article
113 of Law 4548/2018.
More detailed information regarding stock options exercised during the reference year is
provided at the respective note on Staff Costs in the Annual Financial Report.
Share Buyback Program
On 12.6.2025, the Self-Convened Extraordinary General Meeting of the Shareholder of the
Bank approved, pursuant to article 49 of Law 4548/2018, the establishment and
implementation of a Share Buyback Program (the “Share Buyback Program”) for the
acquisition by the Bank (or any of its Subsidiaries) of its own existing common, registered,
dematerialized shares, with voting rights, in a price range between the current nominal
value of the share, i.e. currently Euro 0.29 (minimum price) and Euro 7.00 (maximum price)
per share for a period of 15 months, starting from the day immediately after the day of its
approval by the Self-Convened Extraordinary General Meeting of the Shareholder of the
Bank, and authorized the Board of Directors of the Bank to determine at its discretion any
other detail and to proceed with all necessary actions for the implementation of the Share
Buyback Program.
Following the above authorization, the Board of Directors, by virtue of its resolution dated
15.9.2025, proceeded with the commencement of the Share Buyback Program, as per the
above terms and conditions set by the Self-Convened Extraordinary General Meeting of the
Shareholder of the Bank, and approved additional terms and details in respect of the Share
Buyback Program, including the fact that the share buybacks will be carried out on the
regulated market and will be managed by the Bank, while their execution on the Athens
Authority granted to the
Board of Directors to issue
new shares or to acquire own
shares
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
40 | ANNUAL FINANCIAL REPORT
Exchange will be conducted through Alpha Finance Investment Services S.A., which is a
licensed investment firm.
It is noted that, the Self-Convened Extraordinary General Meeting of the Shareholder of the
Bank dated 12.6.2025 also resolved on the establishment and implementation of a Stock
Award Plan, in accordance with article 114 of Law 4548/2018, in order to be implemented
through the distribution of the Bank’s own shares acquired through the Share Buyback
Program for free to the Management Team and to other Employees of the Bank, including
those providing services on a permanent basis pursuant to article 114 par. 1 of Law
4548/2018, and its Affiliated Companies, within the meaning of article 32 of Law
4308/2014.
B9.
The Bank has entered into no major agreement which comes into effect, is amended or
expires upon a change of control of the Bank following a public tender offer.
Significant agreements put in
force, amended or terminated
in case of a change in the
Bank’s control following a
public tender offer
B10.
The Bank has entered into no agreement with Members of the Board of Directors or with
its Employees, providing for compensation upon their resignation or dismissal without just
cause or upon termination of tenure or employment owing to a public tender offer, excep t
in accordance with the provisions of the law.
Agreements with Members of
the Board of Directors or with
Employees providing for
compensation in the event of
resignation
or dismissal without good
reason or termination of their
term
of office or employment due
to a public offering
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
41 | ANNUAL FINANCIAL REPORT
Sustainability Statement FY 2025
GENERAL INFORMATION
ESRS 2
[BP-1] General basis for preparation of sustainability statements
The Sustainability Statement covers information for Alpha Bank Group (hereinafter the “Group”), and its value chain. It has b een prepared on a
consolidated basis, consistent with the Group’s financial statements.
Qualitative information for the upstream value chain is presented in sections [G1] “Business conduct” and [S4] “Consumers and End Users”
where Group’s business conduct with its value chain is described, as well as in [BP-2] “Value chain estimations and relevant uncertainty”
describing any estimates used for quantitative figures. Quantitative information for the Group’s upstream value chain is incl uded in [E1-6]
“Gross Scopes 1, 2, 3 and Total GHG emissions”.
Regarding the downstream value chain, qualitative information is included in [BP-2] “Value chain estimations and relevant uncertainty”, and
[E1] “Climate Change”. Quantitative information for the Group’s downstream value chain is included in [E1-6] “Gross Scopes 1, 2, 3 and Total
GHG emissions”.
It is noted that in [SBM-3] “Strategy, business model and value chain” and [IRO-1] “Description of the process to identify and assess material
impacts, risks and opportunities” the Group’s material impacts, risks and opportunities are described in detail which have been drawn
considering the Group’s own operations, its upstream and downstream value chain. The Group enhances its business model and aligns its
strategy by implementing actions that promote sustainable practices, strengthen transparency, and mitigate reputational, financial, and
regulatory risks, while fostering long-term value creation for all stakeholders. The disclosures address material impacts, risks and opportunities
pertaining to the Group’s value chain without applying omissions or exempt ions.
The list of all entities included in the present Sustainability Statement can be found on the “Νοte 46 Group Consolidated Companies” of the
Financial Statements of the Annual Report 2025. The largest subsidiary of the Group is Alpha Bank S.A. (denoted hereinafter a s “Alpha Bank”
or the “Bank”).
The Group is in the process of continuously improving the level of availability of information, methodologies used and alignment of actions and
targets currently implemented by the Bank and all its subsidiaries, as well as improving its monitoring and management approach regarding its
joint ventures and associates. No subsidiary undertakings included in the consolidation are exempted from consolidated or individual
sustainability reporting, and no information is omitted corresponding to intellectual property, know-how or innovation. Furthermore, no
exemption has been used for disclosures linked to developments in the course of negotiations.
The Sustainability Statement has received an Independent Limited Assurance in accordance with ISAE 3000 (Revised).
[BP-2] Disclosures in relation to specific circumstances
Time horizons
For Alpha Bank Group the time horizons are classified in alignment with the ESRS definitions as:
• Short-term: One year (2026)
• Medium-term: 2027-from the 2nd year and up to 5 years (2030)
• Long-term: >2030 more than 5 years (2050)
Value chain estimations and relevant uncertainty
Where relevant and applicable, the Group has utilized methods to estimate value chain data. This was the case for the estimation of Scope 3
emissions and their disaggregation per subsidiary, economic activity and source type, as disclosed in [E1-6] Gross Scopes 1,2,3 and Total GHG
emissions. More specifically, indirect sources used for the calculation of some Scope 3 emissions categories were:
• For Alpha Bank S.A. DEFRA 2025 Conversion Factor (Business Travel-land/Cars by size/Medium/CNG), as well as PCAF’s European
building emission factor database, were deployed.
• For Alpha Bank London Ltd, the equivalent carbon footprint factor from DEFRA Guide (2025) was used.
• For Alpha Bank Cyprus, DEFRA 2025 (Business Travel-land» + «WTT- pass vehs and travel- land.), as well as PCAF’s European building
emission factor database, were deployed.
Adhering to the PCAF Standard guidance, the Group prioritized obligors' actual emissions and activity data in order to calculate financed
emissions. In cases where actual emissions were not publicly available/easily retrievable, proxies have been developed as a means to estimate
emissions, resulting in lower data quality. These proxies were calculated using activity proxies rather than proxies based on financial data.
It is noted that regarding quantitative metrics and monetary amounts that are under disclosure, no case of high level of measurement
uncertainty has been identified and overall, the uncertainty level of methodologies and estimations used is acceptable. However, the Group
continuously aims to increase transparency and accuracy to its sustainability reporting and to improve data quality. Therefore, where primary
data is available, the Group prioritizes the utilization of this data over estimations and assesses and improves its methodologies for
measurements.
Specific notes to OpEx & CapEx
Due to the nature of the Group’s business activities, no significant operational (OpEx) and/or capital expenditures (CapEx) t hat relate to the
implementation of its actions towards the achievement of policy objectives and targets have been specifically attributed to material
sustainability matters, unless otherwise stated within the relevant chapters.
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42 | ANNUAL FINANCIAL REPORT
Changes in preparation or presentation of sustainability information
For 2025 there is only one Reporting Group compared to the previous reporting year (2024) further to the completion of the merger by
absorption of Alpha Services and Holdings S.A. by the Alpha Bank S.A. (Reverse Merger) in June 2025.
During the 2025 reporting year, the Group invested in several subsidiaries and sold others, please refer to the ‘Significant events’ section in the
Board of Directors’ Management Report and Notes 55 and 56 to the Consolidated Financial Statements in the Annual Report 2025.
Additionally, in comparison to the previous reporting period, no metrics previously used have been replaced.
Sustainability reporting stemming from other legislation and standards
For the compilation of the present Statement, reporting data stemming from other legislative requirements have been utilized. In addition, to
complement information based on other widely accepted sustainability reporting standards, data from generally accepted sustainability
reporting standards and frameworks have also been used. The paragraphs per standard are presented in the following table:
Table 1 Paragraphs per standard
Legislation/Standard
Paragraphs
GRI
4
417-2, 417-3, GRI 418-1(b)
S4 Consumers and end-users
SASB
5
FN-CB240a.4, FN-CB-230a.2
S4 Consumers and end-users
Additionally, the Group relies on the following International Standards published by ISO, International Organization for Standardization and
other management standards, as follows:
Table 2 Management standards
Standard
Subsidiary certified
ISO 14064 Management System
Alpha Bank S.A.
ISO 50001 Energy Management System
Alpha Bank S.A.
ISO 45001 Occupational Health and Safety Management System
Alpha Bank S.A., Alpha Supporting Services S.A., Alpha Bank Cyprus Ltd
ISO 22301 Business Continuity Management System
Alpha Bank S.A., Alpha Supporting Services S.A., Alpha Leasing S.A., Alpha
Finance A.E.P.E.Y.
ISO 27001 Information Security Management System incorporating ISO
27017 Information Security Controls for Cloud Services and ISO 27018
Protection of Personally Identifiable Information on Public Clouds
Alpha Bank S.A. and for Alpha Supporting Services S.A applies only the 27001
ISO 27701 Privacy Information Management
Alpha Bank S.A.
ISO 14001 Environmental Management System
Alpha Bank S.A., Alpha Supporting Services S.A., Alpha Bank Cyprus Ltd, Alpha
Real Estate Services S.A.
ISO 9001 Quality Management System
Alpha Bank S.A, Alpha Real Estate Services S.A., Alpha Supporting Services S.A.,
Alpha Leasing S.A.
ISO 20000-1 Information technology –Service Management System
Alpha Bank S.A, Alpha Supporting Services S.A.
EMAS Eco-Management and Audit Scheme
Alpha Bank S.A, Alpha Supporting Services S.A.
ISO 22316 Security and Resilience
Alpha Bank S.A.
ISO 20400 Sustainable Procurement
Alpha Bank S.A.
The following information has been incorporated by reference:
Table 3 Disclosure requirements incorporated by reference
Disclosure requirements
Location
GOV-1
The role of the administrative, management and supervisory bodies
Section “Corporate Governance Statement” of the Annual
Report 2025
GOV-2
Information provided to and sustainability matters addressed by the
undertaking’s administrative, management and supervisory bodies
Section “Corporate Governance Statement” of the Annual
Report 2025
SBM-1
Strategy, business model and value chain (products, markets, Customers)
Section “Strategic Plan” of the Annual Report 2025
[GOV-1] The role of the administrative, management and supervisory bodies
Board of Directors general information
On 31.12.2025, the Board of Directors (BoD) of Alpha Bank S.A. consisted of 11 Members, who are appointed for a 4-year term, 2 of which are
Executive Members, 1 Non-Executive Member and 8 are Independent Non-Executive Members, which is in line with the target of ensuring a
majority of Independent Members. There is no representation of Employees and other workers at the BoD, however through its Executive
Members interacts regularly with Employee representatives.
In terms of gender balance and diversity, the female BoD Members represented the 45%, while male BoD Members represented the 55%, with
the average ratio of female-to-male members being 5:6. In terms of age diversity, it is noted that 55% of BoD Members are under the age of
61, 36% between 61-70, and 9% and over 70 years old. In terms of Independent Non-Executive Members, they comprise 73% of the BoD
(based on the composition of the Board of Directors on 31.12.2025).
For the structure and composition of Alpha Bank, please refer to the Corporate Governance Statement.
4
Global Reporting Initiative (GRI 2021)
5
Sustainability Accounting Standards Board (SASB)
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.202 5
43 | ANNUAL FINANCIAL REPORT
Board of Directors relevant experience
The Members of the BoD have strong experience in the Greek and/or international markets and possess deep knowledge and expertise
relating to banking and financial markets, regulatory framework and legal requirements, strategic planning, the understanding of the Group’s
business strategy or business plan, risk management, accounting and auditing, Information technology and security, ESG factors and risks. An
assessment of BoD Members’ collective suitability, as well as individual self-assessment, in terms of knowledge, skills and experience, based on
the ESMA/EBA “Guidelines on the assessment of the suitability of members of the management body and key function holders” (th e
“ESMA/EBA Guidelines”), is conducted annually with the support of the Corporate Gover nance, Sustainability and Nominations Committee
(CGSNC). The relevant information is stated in the annual Corporate Governance Statement which is included in the Annual Report 2025.
Responsibility for oversight of impacts, risks, and opportunities
Among others, the BoD has the overall responsibility for the Bank and approves and oversees the implementation of the Bank’s strategic
objectives, risk strategy and ESG strategy, as well as its internal governance, including relevant impacts, risks and opportunities.
There are four (4) Committees that operate at the BoD level, each with an advisory role and with the possibility to assume delegated
authorities, as determined by the BoD. The duties and mandates of each Committee are included in their respective Charters, ensuring
accountability and clarity of their respective duties.
The Audit Committee, among others, assists the BoD in safeguarding the integrity of the financial and sustainability reporting processes,
reviews the scope, frequency and results of the audit assurance on ESG reporting, including statutory requirements. The Committee
collaborates with the Risk Management Committee as necessary on the effective oversight of the mitigation of certain key areas of risk,
including climate-related or other ESG risks and liaises with other Board Committees in relation to issues on effective ESG control environment,
internal controls and compliance. It also ensures adherence to and compliance with the Code of Conduct and Ethics, oversees the Bank’s effort
to foster a culture of ethics and discourages unethical behavior in all operational levels as well as makes recommendations to the BoD for
approval the “Anti-bribery and Corruption Policy”. The full scope of the duties and responsibilities of the Audit Committee are set out in its
Charter, which is posted on the Alpha Bank S.A. website.
The Risk Management Committee, among others, monitors that Alpha Bank S.A. adequately embeds ESG risks in its risk appetite statement
and framework, business strategy and risk management framework. Specifically, it collaborates with the Corporate Governance, Sustainability
and Nominations Committee, as well as with the Audit Committee as necessary on the effective oversight of the mitigation of certain key areas
of risk, including climate-related or other ESG risks, and capital management and their repercussions on the Internal Control System. The
Committee reviews and recommends annually to the BoD for approval the Group’s risk appetite framework and statement, consider ing also
ESG risks i.e the risks of any negative financial impact on the Bank, stemming from current or prospective impacts of ESG factors on its
counterparties, such as climate-related risks, and ensuring alignment with the Group’s strategic objectives and capital allocation. The
Committee is also responsible for the development of a sound risk culture at all levels throughout the Bank and its Subsidiaries.
The full scope of the duties and responsibilities of the Risk Management Committee are set out in its Charter, which is posted on the Alpha
Bank S.A. website.
The Remuneration Committee, among others, assesses the alignment of the Remuneration Policies with the Bank’s ESG objectives, e.g. long-
term resilience of the business strategy, including ESG and risk appetite, in order to avoid conflicts of interest when business decisions are
made and to facilitate the implementation of ESG risk-related objectives. The Committee is also responsible for ensuring that the
Remuneration Policy for Alpha Bank and other Companies of the Group as well as the “Remuneration Policy of the Members of the Board of
Directors as per the provisions of Law 4548/2018” are consistent with the values, culture, business strategy, risk appetite a nd strategic
objectives of the Group, taking into account ESG risks that affect the business environment in the short, medium or long term. Moreover, it
discourages excessive risk-taking, promotes effective risk management and prevents the emergence of conflicts of interest or minimizes any
conflicts of interest that might arise. The full scope of the duties and responsibilities of the Remuneration Committee are set out in its Charter,
which is posted on the Alpha Bank S.A. website.
The Corporate Governance, Sustainability and Nominations Committee (CGSNC) is responsible for, among others, assisting the Board in
ensuring the implementation of ESG standards according to regulatory requirements and the relevant best practices, ensuring that there is an
adequate level of effective communication on ESG issues with the Risk Management, Remuneration, and Audit Committees, reviewing at least
semi-annually current and emerging ESG trends and regulatory developments reporting that may significa ntly affect the Bank’s activities;
recommending to the BoD areas that may require actions, and reviewing the Sustainability/ESG Policy, at least annually, and if necessary,
providing proposal for amendments and recommending its approval by the BoD as needed. The Committee also assists the BoD in achieving
objectives such as pursuing the implementation of international corporate governance best practice, including through the implementation of
adequate checks and balances across the Group. It is also regularly informed from Heads of internal control functions, concerning the overall
risk profile and risk culture of Alpha Bank, and ensures that there is effective communication reinforcing ethical values and good practice in the
daily business of the Bank and the Group. The full scope of duties and responsibilities of the CGSNC are set out in its Charter, which is posted
on the Alpha Bank S.A. website.
For more information on the Committees, please refer to Corporate Governance Statement 2025.
Reporting lines for the Board of Directors and its Committees
The BoD, through its direct interaction with the four Committees, has the overall responsibility for the Bank and approves and oversees the
implementation of the Bank’s strategic objectives, risk strategy, and ESG strategy, as well as its internal governan ce. The BoD also ensures the
integrity of the accounting and financial reporting systems, including financial and operational controls and compliance with the law and
relevant standards. It oversees the process of disclosure and communications and is responsible for providing effective oversight to the Senior
Management.
Through the Risk Management Committee, the Board receives regular reports from the CRO and CFO on the implementation of the risk
strategy and risk appetite of the Bank and the Group, including as it relates to ESG risks. All Committee Chairs regularly inform the BoD of the
work of the respective Committee.
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44 | ANNUAL FINANCIAL REPORT
All Committees can be directly reported to from any relevant corporate and control function (e.g. legal, finance, human resources, IT, internal
audit, risk, compliance, including information on AML/CTF compliance and aggregated information on suspicious transaction reports and
ML/TF risk factor), as needed and requested, in order to fully discharge their duties.
For the full scope of potential reporting lines in terms of the Committees, please refer to their respective Charters.
Executive Management Level
At the Executive Management level, central to the ESG Governance structure is the Group Sustainability Committee which is chaired by the
Chief of Wholesale Banking and its regular members include: the Deputy Chief Executive Officer (Deputy CEO), Chief Risk Officer, Chief Retail
Client Strategies Officer, Chief of Corporate Center and General Counsel. Members of the Executive Committee, as well as Executives of the
Bank or Group Companies or external partners, may also be invited to participate in the meetings. The Group ESG Coordinator acts as the
Secretariat.
The Group Sustainability Committee convenes regularly and oversees sustainability matters, steers the Group’s ESG Strategy, and oversees its
implementation. In addition, it ensures that the Executive Committee is informed on key subjects discussed and decisions taken. The Chief
Executive Officer (CEO), as a Member of the Board and Chair of the Executive Committee, is informed on sustainability and ESG matters and, in
this capacity, provides input when needed. Finally, it supports the Board of Directors in their oversight of Climate & ESG Risks and
Sustainability issues.
The specific duties and responsibilities of the Executive Committee are set out in Alpha Bank’s Corporate Governance Statemen t of the Annual
Report 2025.
Operational Implementation Level
The Group ESG Coordinator leads sustainability-related initiatives, oversees the ESG objectives within the cross-functional ESG Working Group
and is responsible for its oversight, in addition to being the Secretariat of the Group Sustainability Committee. The ESG Working Group
represents all areas of the Group that take ownership of ESG integration and ensures the flow of information across relevant teams. Those
teams consist of ESG specialists and dedicated representatives of relevant functions, including Retail Banking, Wholesale Banking, Risk
Management, Strategy, Human Resources and Wealth Management and Treasury.
The Governance and Sustainability Business Area drives the ESG agenda and ensures the adoption of best market practices across the Group,
with an emphasis on ESG Strategy and integration, Sustainable Finance operationalization, stakeholder engagement, and disclosures in line
with relevant regulatory requirements. To deliver on the above, a dedicated Program has been established that is governed by the Operating
Committee which comprises representatives from all relevant business areas.
The Climate, ESG and Enterprise Risk Management is a horizontal risk business area which collaborates and coordinates with the rest of the
functions and business areas under the supervision of the Chief Risk Control Officer, while undertaking the management of a limited number
of risks under its controlling capabilities, related to Bank- wide and even Group matters. Amongst others, the business area is responsible for
maintaining a proficient understanding of climate risk, ESG-related regulations and emerging trends, providing expert guidance for ESG
integration into the risk management framework.
Controls and procedures integration with other internal functions
The consideration of ESG impacts, risks and opportunities are embedded in the Group’s operating model, which defines how role s and
responsibilities concerning sustainability are allocated across the Alpha Bank S.A. ESG risks are considered across all vertical risk types and the
dedicated Climate and ESG Risk Team is involved in their assessment.
Specifically, detailed responsibilities are listed and discharged for all internal processes that are instrumental in ESG Integration. For more
information on these processes, please refer to [GOV-1] “Responsibility for oversight of impacts, risks, and opportunies”.
Oversight of target setting and progress monitoring
The Group has set concrete targets to ensure the continuous attainment of its strategic and operational objectives. Notably, commitments and
associated targets developed for each of the ESG pillars are described in [SBM-1] “Strategy, business model and value chain”.
In addition, the BoD has approved the targets, while it is informed on a quarterly basis on the progress of KPIs towards the pledged
commitments and associated targets through a thorough report across the ESG pillars of the Group.
Ensuring appropriate level of skills and expertise
Ensuring adequate training regarding sustainability matters is a central consideration for the overall suitability of the Members of the BoD. In
order to promote effective oversight of sustainability matters, the Members of the BoD receive relevant training. According to the “Induction
and Training Policy and Procedure for the Members of the Board of Directors”, all the newly-appointed Members of the BoD receive key
information one month after taking up their position at the latest, and the induction should be completed within six months. For this purpose,
the Alpha Bank offers to all new Members of the BoD an induction program on, among others, the Bank’s structure, business model, risk
profile and governance arrangements, legal and regulatory requirements in relation to the Bank and the services it provides, the Corporate
Governance principles, Risk Management, Compliance and Internal Audit, Wholesale and Retail Banking, Wealth Management and Treasury,
External Statutory Audit, Capital Adequacy, Financial and Accounting Services, Credit Risk and NPEs, ESG, Sustainability Information;
Information Technology and Security, Human Resources, International Network, Digitalization, Transformation, Strategic Planning.
Sustainability matters are incorporated horizontally across these topics, as relevant.
Additionally, Alpha Bank, in the framework of the continuous training of the Members of the BoD, provides informative and/or training
sessions to all of them as well as the possibility for relevant informative and/or training seminars and meetings on the abovementioned or on
other topics concerning the financial sector. The training places emphasis on conceptual and strategic issues and focus on new developments
and on the influence these developments may have on the Bank. As a result of this training, Members of the BoD develop concrete skills and
expertise linked to the management of the Bank’s sustainability impacts, risks, and opportunities. The Members of the BoD during 2025
participated in the UNEP FI Climate Mitigation Journey program pertaining to ESG.
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45 | ANNUAL FINANCIAL REPORT
More information pertaining to the expertise and training programs of the Members of the BoD is available in the “Board of Di rectors and
Committees of Alpha Bank’s Corporate Governance Statement within the Annual Report 2025”.
Further to the above, Alpha Bank also provides its BoD Members with the opportunity to participate in training and education sessions offered
by external institutions. Upon request by any Member, the Bank may offer tailor-made programs to further enhance the Members’ knowledge
and competences.
[GOV-2] Information provided to, and sustainability matters addressed by the undertaking’s administrative, management and
supervisory bodies
The CGSNC acts as the ultimate liaison between the Board Committees with respect to all sustainability/ESG issues at least on quarterly basis
and promotes respective communications and feedback from all the BoD Committees. Based on the results of the Double Materiality
Assessment, the Group systematically revisits and refines its policies, actions, targets, and metrics to enhance performance monitoring and
strengthen the management of material impacts, risks and opportunities stemming from its operations and business relationships.
The CGSNC, among others, ensures and regularly evaluates that its Members collectively possess the required knowledge, skills and experience
relating to sustainability and ESG issues as well as to the business of the Bank to assess the appropriate composition of the BoD. For further
information on the management oversight please refer to [GOV-1] “The role of the administrave, management and supervisory bodies”.
The Bank is committed to identifying and managing the positive and the negative impacts to environmental, social and governance matters
created through its business operations, and across its value chain, through a robust due diligence process. The list of the material IROs
addressed by the administrative, management and supervisory bodies are presented under [SBM-3] “Material impacts, risks and opportunies
and their interacon with strategy and business model”.
The Audit Committee, among others, assists the BoD in safeguarding the integrity of the financial and sustainability reporting processes.
The Risk Management Committee, among others, monitors that the Bank adequately embeds ESG risks in the overall risk appetite statement
and framework, business strategy and risk management framework. More information pertaining to the responsibilities of the Committees of
the Board of Directors is available at the Corporate Governance Statement within the Annual Report 2025.
[GOV-3] Integration of sustainability-related performance in incentive schemes
As described in the 2025 Remuneration Policy of the members of the Board of Directors, the Combined Bonus Plan (CBP), which as of 2025 is
the only active variable remuneration scheme, incorporates wider ESG-related goals for Material Risk Takers, including members of the SLT
and Directors. This variable remuneration scheme is designed to enhance the alignment of executive remuneration with the Bank’s long-term
strategic objectives and sustainable value creation and incorporates short and long-term targets, which may vary annually and are always
subject to the approval of the BoD. In terms of short-term targets and among other criteria for the award and payment of variable
remuneration, specific criteria linked to corporate social responsibility and wider ESG-related goals, related to actions and initiatives that the
Alpha Bank S.A. may be developing, must be fulfilled. Long-term performance targets of the CBP include profitability and sustainability metrics,
such as non-financial targets (weighted at 20%) relating to sustainable finance disbursement targets, and female participation at middle
management level and above aiming to incorporate ESG criteria in long-term incentive remuneration. These metrics are linked to the material
impacts, risks and opportunities identified through the Group’s due diligence processes. In terms of governance on the incentive scheme
approval and update, the Remuneration Policy is submitted for approval to the Board of Directors and subsequently to the General Meeting of
Shareholders following its endorsement by the Remuneration Committee.
[GOV-4] Statement on due diligence
Table 4 Due diligence process
Core elements of due diligence
Chapters in the Sustainability Statement
Embedding due diligence in governance, strategy and
business model
[GOV-2] Information provided to, and sustainability matters addressed by the undertaking’s
administrative, management and supervisory bodies
[GOV-3] Integration of sustainability-related performance in incentive schemes
[SBM-1] Strategy, business model and value chain
[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and
business model
Engaging with affected stakeholders in all key steps of the
due diligence
[SBM-2] Interests and views of stakeholders
[IRO-1] Description of the process to identify and assess material impacts, risks and
opportunities
[E1-2] Policies related to climate change mitigation and adaptation
[E1-4] Targets related to climate change mitigation and adaptation
[E4-2] Policies related to biodiversity and ecosystems
[E4-4] Targets related to biodiversity and ecosystems
[E5-1] Policies related to resource use and circular economy
[S1-1] Policies related to own workforce
[S1-5] - Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
[S4-1] Policies related to Customers
[S4-5] Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
[G1-1] Business conduct policies and corporate culture
Identifying and assessing adverse impacts
[IRO-1] Description of the process to identify and assess material impacts, risks and
opportunities
[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and
business model
Taking actions to address those adverse impacts
[E1-3] Actions and resources in relation to climate change policies
[E4-3] Actions and resources related to biodiversity and ecosystems
[Ε5-2] Actions and resources related to resource use and circular economy
Tracking the effectiveness of these efforts and
communicating
[E1-4] Targets related to climate change mitigation and adaptation
[E4-4] Targets related to biodiversity and ecosystems
[Ε5-3] Targets related to resource use and circular economy
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46 | ANNUAL FINANCIAL REPORT
[S1-5] Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
[S4-5] Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
Entity-Specific Information
Contribution to Healthy Economies
[GOV-5] Risk management and internal controls over sustainability reporting
The Group has established comprehensive risk management and internal control processes and systems specifically for sustainability
reporting.
These ensure the accuracy, reliability, and integrity of our sustainability data and disclosures. This approach leverages the same rigorous
processes applied to financial reporting, ensuring consistency and high standards across both areas. The risk management and internal control
processes cover all aspects of sustainability reporting, including data collection, processing, and disclosure. This includes risk identification, risk
assessment, control activities, information and communication, and monitoring. The Reporting Center of Excellence (RCOE) is critical
component in this process serving as the focal point and internal control mechanism for data reporting.
The Sustainability Statement under the CSRD is subject to internal assessment and reviews through which the identified areas for
improvement from the previous reporting period have been addressed, and further enhancements are under way including the deve lopment
and approval of a formal procedure for the production of the Sustainability Statement.
In terms of process the Steering Committee acts as the first control frontier with the participation of Directors of the key business areas and
subsidiaries, including Governance and Sustainability, Climate and ESG Risk, Internal Audit, Legal, Accounting, Group Data Protection, Human
Resources. The Group Sustainability Committee functions as the second level approval, followed by the Group Sustainability Committee, the
CGSNC and the Audit Committee.
The Group’s risk assessment approach is based on the Basel Committee on Banking Supervision's standard 239 (BCBS 239) and the Principles of
Risk Data Aggregation and Risk Reporting (RDARR). RDARR processes are independently validated within the Group, by the second line of
defense.
The Data Governance and Quality Business Area owns the risk assessment process by overseeing the proper implementation of the Data
Governance Framework across the Group, ensuring the valuation, and monitoring of data quality. In that context the use of proxies is
continuously minimized, as referenced in [BP-2] Disclosures in relaon to specic circumstances. Through the framework, a well-structured
operating model, with roles and responsibilities concerning data quality, is defined. In addition, the Data Quality Policy provides guidance for
data quality monitoring and remediation actions performed by data stewards and overseen by the Data Governance and Quality Business
Area. The Finance and Risk Reporting Framework defines the responsibilities of the report owners and producers (the respective business
areas within the Group), ensuring consistency and timeliness of reporting. Applied to the entire process, end-user Computing Developed
Applications are governed by the end-user Computing Policy, foreseeing the criteria for risk assessment and respective controls, ensuring data
integrity across the reporting landscape. As part of the Risk Appetite Framework, four Key Risk Indicators (KRIs) have been defined in order to
measure data quality risk – covering data ownership, reliability, accuracy and timeliness. In addition, the Risk Management Committee
oversees climate and environmental risks.
Based on the aforementioned process, Non-Financial Risks (NFRs), including Sustainability Reporting risks are identified through various
methods, spanning across Risk and Control Self-Assessments (RCSA), scenario analysis, internal and external loss data reviews, regulatory and
audit findings, key risk indicators (KRIs), third-party risk assessments, and employee or Customer surveys. Once identified, these risks are
prioritized using risk scoring and heat maps, materiality assessments, alignment with risk appetite thresholds, and evaluations of
interdependencies or concentration risks. Mitigation strategies include strengthening internal controls, implementing policies and training,
transferring risk through insurance or outsourcing, and establishing robust business continuity and incident response plans. Continuous
monitoring through regulatory compliance tools, stress testing, assurance reviews, and independent internal audits helps validate the
effectiveness of these measures.
Once the reporting by the relevant Business Area has been reviewed internally, in line with the aforementioned process, the Governance and
Sustainability Business Area receives the data from the data providers and ensures it is properly incorporated into the report. An external
auditor is also engaged to assess the reliability of the data prepared. The Risk Management Committee, the Corporate Governance,
Sustainability and Nominations Committee and the Audit Committee also collaborate as necessary to promote effective mitigation.
The Audit Committee and the Risk Management Committee provide oversight of certain areas of risk management, and their repercussions on
the Internal Control System.
The Risk Management Committee is regularly informed about the quality of the sustainability reporting and convenes at least once a month,
inviting, as appropriate, any Member of the Group’s Management or Executive to attend its meetings. The Chief Risk Off icer (CRO) is a regular
attendee of the Committee meetings and has unhindered access to the Committee Chair and Members.
The Data Governance and Quality Committee, Risk Committee and the Board of Directors are periodically updated on data quality issues and
on the implementation of the Data Governance and the development of the Quality Framework.
[SBM-1] Strategy, business model and value chain
Significant groups of products and services offered
The Group’s activities span across the Banking sector, Asset Management, Investment Banking and Treasury, Insurance, other Fi nancing
services, Financial Services, Provision of Information technology services and consulting, as well as Real Estate management. During 2025, the
Group executed the sale of certain subsidiaries, with main activities related to Leasing and Real Estate management as well as the acquisition
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47 | ANNUAL FINANCIAL REPORT
of companies with activities in Banking, Real Estate Management, Factoring and Investment Banking
6
. Alpha Bank S.A. is the largest Group
Entity, therefore the Group’s significant group of products and services relate to banking activities.
Alpha Bank's purpose is to enable progress in life and business for a better tomorrow, which is achieved through its core values of excellence,
efficiency, collaboration, and empowerment. These values guide the bank in fostering strong, trusting relationships with clients, supporting
businesses for a sustainable economy, and addressing social issues like equality and financial health.
Through serving its clients and the projects it finances, Alpha Bank is cementing its position in improving more people’s fin ancial health,
helping clients transition to a green and digital economy and driving sustainable returns for its investors. Alpha Bank applies the UN
Environment Programme Finance Initiative (UNEP FI) Principles for Responsible Banking (PRB) framework to align its strategy with the
Sustainable Development goals as well as the Paris Agreement on climate change.
The Group strategy integrates material sustainability matters, with the aim of scaling sustainable finance and making positive contribution in
the areas of climate and financial health & inclusion, while reducing the negative impacts from its operations.
To support its client needs, the Bank integrates ESG criteria across its financial product suite to support Sustainable investments and consumer
choices. Through its Alpha Green Solutions package, the Bank offers a variety of green loans with preferential interest rates for home energy
upgrades, eco-friendly transportation (including electric and hybrid vehicles), and energy-efficient home equipment such as photovoltaic
panels and heat pumps. Alpha Bank also actively participates in state-supported energy-saving programs like "Exoikonomo 2025" and "e-
Astypalea," providing tailored financial support particularly in local communities such as Astypalea. For more information on the 2025
products/services, please refer to [S4.SBM-3] ‘Material impacts, risks and opportunities and their interaction with strategy and business model
in relation to consumers’.
For small businesses, the Alpha Photovoltaic product facilitates investment in photovoltaic stations up to 1 MW to boost renewable energy
generation. Additionally, in collaboration with the Hellenic Development Bank, the Green Co-Financing Loans program offers loans with
attractive terms—including interest-free portions and subsidies—to encourage sustainable projects.
For large corporate clients the Bank draws on its expertise in project finance to provide financing for investments in RES, large infrastructure
projects, waste treatment, recycling, and green buildings. The Bank also deploys co-funding initiatives, to support clients’ transition plans
including the EU Resilience and Recovery Facility (RRF) Green transition pillar to accelerate sustainable investments. Through the Recovery and
Resilience Facility, the Bank provides financing for the green transition, with a focus on Renewable Energy Sources. Eligible categories under
the “green pillar” include green technologies, green skills, biodiversity, energy efficiency, building renovation, preservation of energy security,
circular economy, sustainable development, and creation of jobs.
The Bank continues to expand its offerings, including green mortgages, consumer loans for energy efficiency upgrades, and sustainability-
linked loans, aligning with evolving market demands and regulatory frameworks.
Significant groups of Customers and location of operations
For information on significant groups of Customers (denoted hereinafter as “Customers” or the “Clients”) and how the Group’s activities serve
these Customers, please refer to [S4.SBM-3] 'Material impacts, risks and opportunies and their interacon with strategy and business model
in relaon to consumers'. The Group is active in Greece, its principal market, and in markets in Cyprus through its wholly-owned subsidiary
Alpha Bank Cyprus Ltd. The Group also maintains a presence in the United Kingdom (through its wholly-owned subsidiary Alpha Bank London
Limited), Luxembourg, Romania, Bulgaria, Serbia, Ireland.
Details on the total number of Employees in 2025 in addition to the breakdown across its geographical scope of operations can be found under
[S1-6] “Characteriscs of the undertaking’s Employees”.
Exclusion list and limited activities and revenues from specific sectors
As per its exclusion list, Alpha Bank has limited appetite in financing activities in the production and trade of tobacco, and does not finance
controversial weapons, please refer to [E1-2] “Policies related to climate change migaon and adaptaon”.
Alpha Bank S.A. and Alpha Asset Management A.E.D.A.K. comply with Regulation (EU) 2019/2088 (SFDR) on sustainability disclosures in the
financial services sector, as per its Sustainable Finance Statement and ESG sustainability disclosures. Alpha Asset Management A.E.D.A.K.
product-level sustainability disclosures are available on its website. Currently, no SFDR Principle Adverse Impact indicators are available
regarding exposures and revenues from companies active in fossil fuel (coal, oil and gas) or chemical productions; however, the Group may
have limited exposure through its financing of clients who may be active in or have exposure to these sectors.
Sustainability-related goals and strategic priorities
The Group commits to create long-term value for its stakeholders, by setting sustainability-related goals in all areas of operation and
establishes a comprehensive sustainability strategy to achieve them:
Support an environmentally sustainable economy
• Support its Customers’ decarbonization and align its portfolio emissions with the objectives set in the Paris Agreement
• Mitigate key drivers of biodiversity loss
• Support the transition to a circular economy
• Achieve Net Zero emissions in its own operations
Foster healthy economies and societal progress
6
For detailed description of the subsidiaries sold in 2025 please refer to the notes 55 and 56 of the Annual Consolidated Financial Statements for the period
ended 31.12.2025.
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• Enhance people’s financial health through inclusive access to financing
• Provide an inclusive and safe work environment
• Support inclusion and access to Healthcare, Education, Culture and Heritage
Ensure a robust and transparent governance
• Ensure the Diversity and Independence of the Board of Directors
• Embed sustainability in Governance practices and strategy
The Group integrates sustainability into its core business model by offering tailored financial products and services that enable corporate and
SME Customers to invest in renewable energy, reduce waste, and transition to sustainable operations.
For retail Customers, the Group provides current and new sustainability-focused products designed to educate and empower individuals to
make responsible financial decisions. This includes facilitating access to affordable housing and green financing, contributing to social
resilience and inclusive growth.
In line with its commitment to financial inclusion, the Group delivers accessible banking services to underserved communities, reducing
inequalities and expanding economic participation. These initiatives reflect the Group’s strategic response to material sustainability risks and
opportunities, driving systemic change across industries and ensuring alignment with stakeholder expectations and regulatory requirements.
In Greece, significant Group products and services include Green Retail and Small Business Banking Products. These products and services
support the sustainability-related goals “Support an environmentally sustainable economy” and “Foster healthy economies and societal
progress”.
Since 2022, the Group has applied the Sustainable Finance Framework (SFF) which was developed in accordance with market practice
requirements reflected in the principles established by the International Capital Market Association and the Loan Market Association. The SFF
defines in detail the criteria and process to classify financial products and services as sustainable covering both dedicated and general-purpose
financing. It also incorporates the EU Taxonomy Regulation on economic activities that significantly contribute to climate mitigation and
climate adaptation, enabling the implementation of a multi-step assessment process at the Customer and transaction level. Please refer to [E1-
2] “Policies related to climate change mitigation and adaptation” for the detailed Sustainable Finance Framework description.
The SFF identifies eligible activities for sustainable financing grouped into the following themes:
Table 5 Eligible activities for sustainable financing
Green eligible activities for sustainable financing
Social eligible activities for sustainable financing
Energy Efficiency
Economic Inclusion
Renewable Energy
Access to Essential Services
Sustainable Transport
Affordable Basic Infrastructure
Resource efficiency and pollution control
Affordable Housing
Green Buildings
In 2025, the implementation of the Sustainable Finance Framework (SFF) advanced the Group’s commitment to sustainable lending, resulting in
Euro 2.1 billion of new financing classified under the SFF criteria.
In January 2025 Alpha Bank launched its Green Bond Framework (GBF) which provides a clear and transparent roadmap for how the Bank intends
to channel capital into projects that advance environmental goals. The Green Bond Framework aligns with 2021 ICMA Green Bond Principles
(with June 2022 Appendix I) and follows its four core components:
1. Use of Proceeds
2. Evaluation and Selection Process
3. Management of Proceeds
4. Reporting
With the Green Bond Framework Alpha Bank aims to incorporate the EU Taxonomy requirements and to achieve future alignment with its
eligibility criteria wherever feasible.
As a result, in October 2025 Alpha Bank successfully completed the pricing of a Green Senior Preferred Bond of Euro 500 million. The transaction
was more than six times oversubscribed, underscoring the depth of investor confidence in Alpha Bank’s renewed f inancial standing and strategic
direction.
Main challenges and critical solutions
The rapidly evolving EU regulatory landscape (i.e. Paris Agreement, and EU Taxonomy, Corporate Sustainability Reporting Directive -CSRD and
its transposition into the national laws
7
, the Greek National Energy and Climate Plan (NECP)
8
, SFDR, ECB Disclosure Requirements) is putting
pressure on all industries to adapt and comply rigorously to the new requirements. Balancing economic growth objectives with climate risk
mitigation, decarbonizing operations and financed emissions to align with global net-zero targets and supporting clients in high-emission
industries to transition to sustainable business models without significant financial risk are key challenges for the financial sector. In addition,
promoting workplace DE&I as well as bridging the financial inclusion gap for underserved communities always remain priorities.
To navigate through these challenges, the Sustainability strategy has been developed by the Group to integrate further sustainability into its
core business model and core strategy for the short-term time horizon (2025-2027). The Sustainability strategy considers the UN Sustainable
Development Goals (UN SDGs) and reflects the Bank’s approach to address Climate change, Biodiversity, and Circularity aspects, related mainly
to its portfolio, and own operations, to deliver positive outcomes for its Own Workforce, and Consumers and End-Users, as well as to ensure
7
On December 10, 2024, the Greek Parliament approved the legislation (Law 5164/2024), which, among others, incorporates into Greek law the European
Directive 2022/2464 on the submission of sustainability reports by companies, also known as the Corporate Sustainability Reporting Directive – CSRD.
Cyprus transposed CSRD into Cypriot law on July 29, 2025.
8
In August 2024, an Updated version of the NECP 2021-2030 was published and submitted to the European Commission in January 2025.
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responsible Business Conduct. The Sustainability strategy has been reinforced further with the adoption of a robust Sustainable Finance
Framework from the Bank, as a critical solution to enhance Green and Social Finance, such as renewable energy investments, decarbonization
of operations, Climate risk management and Financial Inclusion. The Sustainability strategy and the Sustainable Finance Framework is
reviewed and updated regularly, in line with the long-term goals set.
Furthermore, the Alpha Bank Group continuously focuses on the improvement of internal processes and mechanisms for ensuring
transparency in all its sustainability disclosures.
Business model and value chain
The Group invests in its Employees, its network and its infrastructures to develop and place high-quality services and products on the market.
The Group balances its goals for economic growth with the needs of their Customers, the environment and society as a whole. This requires
the Group to consider ESG factors when making business decisions, by supporting a Net-Zero Economy, fostering Healthy Economies that
support Society and Safeguard Robust Governance, in line with its purpose for: “Enabling progress in life and business for a better tomorrow”.
Table 6 Inputs and expected and achieved outputs and outcomes of the business model
Capitals
Inputs
Outputs
Current and expected benefits
Financial
Interest income, Fees and
commission, Investors’ funds.
Offering financial products and services,
supporting the markets the Group operates
in.
Enhanced access and Inclusion to financial
products and services to its Customers and
improved Customer experience
Increased trust to the Group’s governance
and ethical practices for all stakeholders,
including investors, Employees, business
partners and suppliers and Customers
Provision of a healthy inclusive work
environment, with opportunities for career
development and promotion of diversity to
its Employees
Human
Skill set and development of the
workforce, tools and processes.
Providing a healthy work environment and
investing in its People’s development.
Manufactured
The infrastructure, supply chain, and
other external resources.
Improving its Customers’ experience by
investing in the infrastructure.
Intellectual
Research and Development (R&D)
investments for products, services
and infrastructures.
Strengthening advisory and digital services,
to meet Customers’ changing needs.
Natural
Use of natural resources, including
energy for the operation of the
Group.
Constantly improving its environmental
footprint via our products and operations.
Social
Cooperation with the stakeholders
to support society and the local
economy.
Focusing on providing a safe and inclusive
work environment, the financial inclusion of
underrepresented groups and the provision
of access to culture and healthcare services.
Gathering, developing, and securing these inputs requires structured management approach evidenced by the Group robust governance
mechanisms, processes, and the utilization of resources to ensure accuracy, efficiency, and alignment with regulatory and stakeholder
expectations.
Through its business model the Group aims to create value for its stakeholders across the value chain, i.e. for:
• Upstream value chain, including Main suppliers, providing IT (hardware and software) and multiple other services (e.g. consultants,
legal advisory, marketing companies, etc.)
• Downstream value chain, including Customers, including corporate, SMEs, and retail Customers, Broader society, and communities
• Own operations, including Employees
[SBM-2] Interests and views of stakeholders
Key stakeholders and stakeholder engagement
The Group maintains continuous and structured engagement with its key stakeholder groups, as identified through the Double Materiality
Assessment (DMA) and the stakeholder-mapping exercise conducted in 2025. This process applied ESRS criteria, assessing stakeholders across
based on the following criteria:
• Whether they are an affected stakeholder,
• Whether they are a user-of-sustainability-statement,
• Their power and influence, and
• Their interest in or exposure to the Group’s impacts, activities and decisions.
Based on this analysis, the Group recognizes the following four prioritized stakeholder groups with the highest strategic relevance:
• Shareholders and Investors
• Customers (Wholesale and Retail)
• Employees and Society
• Regulatory and Supervisory Authorities
Engagement with primary stakeholders occurs both via structured, regular processes, as well as an ad-hoc basis, throughout the business year
in line with each group’s level of influence and interest. Activities include bilateral meetings, surveys, roadsho ws, community-dialogue
initiatives, and regulatory interactions. In this context, during 2025, the Group conducted engagement with:
• shareholders and investors, including equity and fixed income analysts
• wholesale and retail Customers
• interactions with regulatory and supervisory authorities, and
• civil-society and community representatives
• Employees and trade union representatives
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Other stakeholders including suppliers, business partners, correspondent banks and reinsurers are considered in the context of the
stakeholder mapping exercise, but do not form part of the primary stakeholder set due to their lower interest and/or lower power
categorization within the 2025 prioritization matrix.
The Group engages with these other stakeholders primarily through value-chain due-diligence processes, contractual onboarding and periodic
ESG assessments.
These engagement activities are integral to the Group’s strategic discussions, the DMA methodology, and the identification of sustainability-
related impacts, risks, and opportunities. Further details on how the interests and views of prioritized stakeholders relate to the Group’s
strategy and business model are provided in “Interests and views of key stakeholders in relationship with strategy and business model”.
Effective stakeholder engagement requires clear, structured and consistent communication channels tailored to each group’s ne eds and
expectations. The Group uses a range of formal and informal mechanisms to ensure continuous two-way dialogue. These channels support
transparency, enable timely feedback, and ensure that stakeholder insights are systematically integrated into strategic decision-making, risk
management, and the overall sustainability framework. The primary communication channels per stakeholder group are summarized below.
Table 7 Means of communication per stakeholder group
Stakeholder group
Communication method
Shareholders and Investors
Financial Statements, Quarterly Earnings Reports, Annual Reports, General Meetings, Investor Briefings, Sustainability
and Climate Reports, One-to-one meetings, Sustainability and Corporate Governance roadshows, Website, Press releases,
Economic Research updates
Customers (Wholesale, Retail)
Branch network, Relationship Managers, Customer Newsletters, Sustainability Statement within the Annual Report,
Customer Satisfaction Surveys, Online Customer Portals, Mobile application, Customer service center, Website, Social
Media, Press releases, Corporate Service Centers (for Wholesale Customers)
Employees and Society
Internal Newsletters, Intranet, Town Hall Meetings, Training Sessions and Reskilling Programs, Employee Surveys, HR
Business Partners, Sustainability Statement within the Annual Report, Community Engagement Reports, Press Releases,
Social Media Updates, CSR initiatives, NGO memberships, Volunteering, Sponsorships
Regulatory and Supervisory
Authorities
Regulatory Filings, Supervisory Submissions, Compliance Reports, Direct Consultations and Bilateral supervisory dialogue,
Participation in thematic regulatory working groups, Climate-risk and ESG-risk reporting required under EU legislation
Through the engagement, the Group aims to understand and anticipate stakeholders’ needs, interests, expectations, and concern s, evaluate
their significance, and to incorporate them into the Group’s strategy, risk-management framework, and sustainability planning. A dedicated
team analyses all feedback using a structured approach that includes:
• Mapping and prioritization of stakeholder groups
• Review and categorization of issues raised
• Escalation of key findings to Senior Management and Board Committees
• Integration of stakeholder perspectives into the DMA and strategic planning processes
• Monitoring progress and reporting back to stakeholders.
Outputs from stakeholder engagement are systematically incorporated into decision-making processes across the Group. Key findings from
engagement activities are translated into management action plans and inform updates to strategic priorities, policies and sustainability
initiatives. For example, investor feedback received during 2025 engagements contributed to further evolving the Group’s sustainability
strategy, including climate risk mitigation and adaptation, enhancing sustainability disclosures, and ensuring robust Board-level oversight of
climate-related risks. Customer feedback informed the development of new sustainability-linked financing products and advisory support, and
improvements in digital service delivery. Employee survey results supported Diversity Equity and Inclusion initiatives and highlighted health
and safety as an area of prioritization. Community engagement inputs supported financial inclusion and financial literacy initiatives.
Supervisory dialogue informed enhancements in ESG risk integration, the refinement of sustainability reporting processes, and the alignment
with European and national supervisory and legal requirements and energy plans.
Emerging themes identified through stakeholder engagement are reviewed during the Double Materiality Assessment and may result in the
introduction of new priority sustainability topics or the reprioritization of existing focus areas.
Detailed information on stakeholder engagement for Employees and Customers is provided in chapters “E1-Climate Change”, “E4-Biodiversity
and Ecosystems”, “E5- Resource Use and Circular Economy”, “ESRS S1-Own workforce” and “S4- Consumers and End Users”.
Interests and views of key stakeholders in relationship with strategy and business model
Stakeholder feedback forms an essential input to the Group’s strategic planning. The views and interests of affected stakehol ders regarding
sustainability-related impacts, risks, and opportunities are systematically communicated to the Group’s administrative, management, and
supervisory bodies. Key findings from stakeholder engagement activities are summarized in regular reports to Senior Management and
relevant Board Committees. These bodies review material stakeholder concerns as part of strategic planning, risk appetite setting, and
approval of sustainability-related policies and targets.
Insights gathered through the 2025 engagement cycle and updated stakeholder mapping provide a clear view of expectations regarding the
Group’s impacts, risks, and opportunities and long-term direction, ensuring that the business model remains aligned with the needs of those
who are most affected by, and those who are influential over, its activities.
Based on these insights, the Group has begun to adapt elements of its strategy and business model to better address stakeholder
expectations, particularly in relation to sustainable finance growth, ESG risk integration, and Customer value propositions. Outcomes from
stakeholder engagement are reviewed as part of the annual strategic planning cycle and may result in adjustments to sector financing policies,
product development priorities, risk methodologies, and sustainability targets.
As part of this adaptation, the Group is evolving its business model by strengthening sustainable finance and transition support capabilities
across relevant business lines, including through enhanced product design and integration of sustainability considerations into its client
engagement processes. This evolution supports the alignment of the Group’s offerings with stakeholder expectations and susta inability-
related risk management.
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Shareholders and Investors, including bondholders, lenders, analysts, and rating agencies, continue to express a strong interest in the Group’s
long-term climate and sustainability strategy. Engagements throughout 2025 underlined the importance they place on transparent, credible
transition plans and on the integration of climate considerations into core business practices. Investors seek clear decarbonization pathways
aligned with science-based methodologies, consistent disclosure of financed emissions, and robust scenario-analysis results. Their
expectations extend to strengthened governance, with particular attention to Board oversight of ESG risks, the alignment of remuneration
with sustainability outcomes, and improved transparency regarding the Group’s risk-management framework. The demand for detailed
progress reporting and taxonomy-aligned disclosures has also intensified, reflecting investors’ emphasis on comparability and accountability.
In response to investor feedback, the Group has strengthened its transition planning framework, expanded financed emissions, enhanced
sustainability disclosures, and ensured robust Board-level oversight of climate-related risks. Going forward, further steps are planned to
increase sustainable finance origination, expand and define sectoral decarbonization pathways, and refine the integration of ESG performance
indicators into remuneration. These developments are expected to reinforce long-term investor confidence and deepen engagement with
sustainability-focused capital providers.
Customers’ expectations reflect both their day-to-day banking experience and their evolving sustainability needs. Retail Customers continued
to prioritize accessibility, Customer experience, and secure, transparent handling of data, while also expressing increasing interest in products
with positive environmental or social characteristics. Wholesale Customers, including SMEs and large corporates, demonstrated heightened
expectations for Sustainability-linked financing solutions and sought advisory support to advance their own decarbonization strategies. Across
both segments, Customers highlighted the importance of clarity and simplicity in product information, as well as the need for seamless digital
interactions.
Customer insights are considered in product development, service-design and the Group’s approach to sustainable finance offerings, ensuring
the evolving expectations are reflected in ongoing business model refinements. As a result of Customer feedback, the Group has expanded
sustainability-linked financial products and enhanced digital services. Further developments are planned going forward in order to broaden
advisory services supporting corporate decarbonization strategies and improve transparency of sustainability features in retail products. These
steps are expected to strengthen Customer trust and increase long-term Customer engagement with the Group’s sustainable finance offering.
Employees consistently emphasized the need for a workplace culture grounded in fairness, inclusion, and professional development. The 2 025
engagement cycle highlighted sustained expectations for stronger diversity, equity and inclusion practices, enhanced health, safety and
wellbeing programs, and opportunities for reskilling and career mobility.
Following employee feedback, the Group has introduced enhanced well-being initiatives and reinforced diversity and inclusion efforts, as well
as training and development programs. Going forward, further actions are being planned to embed DEI objectives in leadership development
processes, extend health and safety assessments across all locations, and increase employee access to well-being support services. These
measures are expected to strengthen employee trust, engagement, and retention, and reinforce th e Group’s culture and alignment with
sustainability commitments.
Society and local communities expect the Group to deepen its contribution to social inclusion, financial literacy, and community wellbeing.
Local communities expressed the importance of responsible financing practices, especially in relation to activities that may carry
environmental or social risks and emphasized the need to transparent communication about the Group’s sustainability commitments. Broader
societal stakeholders also value the Bank’s role in supporting vulnerable groups, promoting accessibility in financial services, and contributing
to long-term sustainable development at local and national levels. In response to societal expectations, the Group has prioritized financial
inclusion initiatives. Further initiatives are being planned, in order to target community investment in these areas and improve public
transparency on sustainability commitments. These steps are expected to enhance trust with communities and civil society stakeholders.
Regulatory and Supervisory Authorities continue to emphasize the importance of accurate, timely, and comprehensive compliance with
evolving EU sustainability regulations. Throughout 2025, supervisory authorities focused on the robustness of the Group’s ma nagement of
environmental, social and governance risks, including the integration of climate-related considerations into credit, market and operational risk
frameworks. Authorities expect enhanced governance controls, credible climate stress-testing practices, and transparent reporting under
CSRD, ESRS and prudential Pillar 3 sustainability standards. Additional dialogue centered on strengthening operational resilience across the
value chain and the alignment of the Bank’s activities with national and Europ ean climate and energy objectives.
Following supervisory dialogue, the Group has enhanced integration of ESG drivers into risk management framework and strengthened
internal controls, while further refinements are planned for future time horizons. These developments are expected to support continued
constructive supervisory engagement and regulatory compliance.
Stakeholder perspectives gathered through the 2025 engagement cycle remain central to the Group’s understanding of its materi al impacts,
risks, and opportunities. These insights continue to guide ongoing strategic planning and business model refinement and support the
alignment of the Group’s sustainability commitments with the expectations of those most affected by, and influential over, it s activities. The
Group remains committed to maintaining open dialogue, enhancing transparency, and integrating stakeholder expectations into its pursuit of
long-term, sustainable value creation.
[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model
Material impacts, risks and opportunities
The Group has performed its annual double materiality assessment in 2025 to identify material impacts, risks, and opportunities taking into
consideration its business operations, and value chain across countries of operation, drawing also from international best practices. The 2025
results highlight that material topics and associated IROs have been enhanced (where applicable) compared to the previous reporting cycle
and are presented in the following table:
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Table 8 Materiality Assessment Results
Link with ESRS topics/sub-
topics and sub-sub-topics,
entity-specific topics
IMPACT
Actual
impact
Potential impact
RISK
Current
Financial
Effect
Anticipated
Financial Effect
OPPORTUNITY
Current
Financial
Effect
Anticipated
Financial Effect
Value Chain Segment and Affected
Stakeholders
2026
2030
2050
2026
2030
2050
2026
2030
2050
E1 Climate
Change
• Climate
Mitigation
• Energy
Negative
impact on
Climate
Stability
●
●
●
●
Climate
Transition
Risk
●
●
Climate
Change
Mitigation
●
●
●
●
OWN OPERATIONS: Material negative
impact on climate stability through
energy consumption in own operations.
DOWNSTREAM: Material negative
impact on climate stability though GHG
emissions created indirectly by the
Group’s products/services and business
relationships.
Material risks derive from the Group’s
exposures to sectors sensitive to
transition risk. These risks affect the
creditworthiness of counterparties and
the recovery value of such exposures
(e.g., non-compliance with climate-
related regulations, increased cost of
raw materials/energy, technological lag,
or shift in consumer preferences).
Material opportunities derive from
Group’s sustainable financings related
to climate change mitigation.
• Climate
Adaptation
Climate
Physical Risk
●
●
Climate
Change
Adaptation
●
DOWNSTREAM: Material risks from
physical risk events affecting clients’
ability to meet financial obligations and
reduce the value of their properties or
premises (e.g., collateral values in real
estate portfolios)
Material opportunities in the long term
are expected to derive from the Group’s
sustainable financings related to climate
change adaptation.
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Link with ESRS topics/sub-
topics and sub-sub-topics,
entity-specific topics
IMPACT
Actual
impact
Potential impact
RISK
Current
Financial
Effect
Anticipated
Financial Effect
OPPORTUNITY
Current
Financial
Effect
Anticipated
Financial Effect
Value Chain Segment and Affected
Stakeholders
2026
2030
2050
2026
2030
2050
2026
2030
2050
E4
Biodiversity
and
ecosystems
• Impacts on
the extent
and
condition of
ecosystems
Negative impact
on Habitats
(Biodiversity and
Ecosystems)
●
●
●
●
Biodiversity
& Ecosystems
risk
●
Protection
and
restoration of
biodiversity
and
ecosystems
●
DOWNSTREAM: Material negative impact
on Habitats (which affects the status of
Biodiversity and Ecosystems), through the
Group’s products/services and business
relationships.
Material risks derive from exposures to
sectors with high negative impact on
biodiversity and ecosystems, affecting
their creditworthiness in the long term.
Companies unable to comply with
biodiversity-related regulations or
dependent on ecosystem services (e.g.,
agriculture, forestry, fisheries) may face
fines, litigation, or reduced productivity,
reducing their financial stability and
leading to credit losses.
Material opportunities in the long term
are expected to derive from the Group’s
sustainable financings related to
biodiversity & ecosystems.
E5 Resource
use and
circular
economy
• Resources
inflows,
including
resource use
Negative impact
on Resource
Intensity
●
●
●
●
Transition
to a circular
economy
●
DOWNSTREAM: Material negative
impact on Resource Intensity (which
affects the development of a Circular
Economy), through the Group’s
products/services and business
activities.
Material opportunities in the long term
are expected to derive from the Group’s
sustainable financings related to
resource use and circular economy.
S1 Own
workforce
• Secure
employment
• Social
dialogue
• Freedom of
association
Contribution to
Livelihood of
own workforce
●
●
●
●
OWN OPERATIONS: Material positive
impact on own workforce through
securing employment, social dialogue
and freedom of association
• Training and
skills
development
Training and
skills
development
●
●
●
●
Staffing and
training
issues
●
●
●
OWN OPERATIONS: Material positive
impact through training and skills
development programs offered to own
workforce.
Material risks related to inadequate
training and skills development within
the Group’s workforce. Such risks may
reduce productivity, limit adaptability to
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54 | ANNUAL FINANCIAL REPORT
Link with ESRS topics/sub-
topics and sub-sub-topics,
entity-specific topics
IMPACT
Actual
impact
Potential impact
RISK
Current
Financial
Effect
Anticipated
Financial Effect
OPPORTUNITY
Current
Financial
Effect
Anticipated
Financial Effect
Value Chain Segment and Affected
Stakeholders
2026
2030
2050
2026
2030
2050
2026
2030
2050
evolving technologies and processes,
heighten dissatisfaction, and increase
turnover.
• Diversity
Contribution to
Equality and
Justice of own
workforce
●
●
OWN OPERATIONS: Material potential
positive impact on own workforce by
embedding Diversity as a strategic
priority in the Group’s future plans.
• Health and
safety
Contribution
to health and
safety of own
workforce
●
●
●
●
OWN OPERATIONS: Material positive
impact on own workforce through
significant investments in Health, Safety
and Wellbeing initiatives.
S4
Consumers
and end
users
• Access to
products and
services
Access to
Housing
●
●
●
●
DOWNSTREAM: Material positive
impact on Customers, and broader
society/economy through the Group’s
products/services and business
relationships.
Access to Finance
●
●
●
●
• Privacy
Disclosure and
data protection
issues
●
●
●
OWN OPERATIONS: Material risks
related to consumers and end-users
typically stem from the potential failure
of internal processes and control
mechanisms established to ensure data
protection, responsible marketing, and
access to quality information. While
such risks may also indirectly affect the
Group’s Customers, their root causes
and potential impacts are primarily
linked to the operational practices and
governance framework.
• Access to
quality
information
Fiduciary
breaches
(miscellaneous)
●
●
●
Unsuitable
promotion
practices
●
●
●
Disputes over
advisory
activity
●
●
●
• Responsible
marketing
practices
Product
suitability
issues/
Inadequate
disclosure of
product terms
●
●
●
Entity-specific
Contribution to
Healthy
Economies
●
●
●
●
DOWNSTREAM: Material positive
impact on Customers and broader
society/ economy through the Group’s
products/services and business
relationships.
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55 | ANNUAL FINANCIAL REPORT
Link with ESRS topics/sub-
topics and sub-sub-topics,
entity-specific topics
IMPACT
Actual
impact
Potential impact
RISK
Current
Financial
Effect
Anticipated
Financial Effect
OPPORTUNITY
Current
Financial
Effect
Anticipated
Financial Effect
Value Chain Segment and Affected
Stakeholders
2026
2030
2050
2026
2030
2050
2026
2030
2050
G1 Business
Conduct
• Corporate
culture
Contribution to
Transpar-ency
and the Rule of
Law
●
●
●
●
ACROSS THE VALUE CHAIN: Material
positive impact on stakeholders across
the value chain through initiatives that
foster an ethical corporate culture
9
.
• Corruption &
Bribery
AML/CFT
●
●
●
ACROSS THE VALUE CHAIN: Material
risks related to corruption and bribery
risks across the value chain, arising from
the Group’s own operations and also
through interactions with third parties,
intermediaries, and clients, where
insufficient due diligence or weak
controls could expose the Group to
compliance breaches and reputational
harm.
● : Positive impact
● : Negative impact
● : Risks and Opportunities
9
The impact “Contribution to Transparency and the Rule of Law” is governing the way the Group operates across its value chain, regardless of the differing materiality levels of its individual value chain segments.
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56 | ANNUAL FINANCIAL REPORT
Ιmpacts
Material impacts of the Group for the short-term, mid-term and long-term time horizon are focused on its own operations, and downstream
value chain affecting the natural environment, and society, its Employees and Customers in all areas where the Group has main presence.
This is a result of the inherent nature of the Group’s products/services, business model as well as its strategy, which are related to its own
operations, portfolio and its business relationships.
Material impacts related to the downstream value chain include:
• Climate Stability: Actual and potential negative impact on climate stability in the short-, mid- and long-term time horizons though
GHG emissions created mainly through the financing activities of sectors that are contributing negatively to climate stability.
• Habitats (Biodiversity and Ecosystems): Actual and potential negative impact on habitats in the short-, mid- and long-term time
horizons mainly through the financing activities of sectors that are contributing negatively to habitats, and the preservation of good
condition of ecosystems.
• Resource intensity: Actual and potential negative impact on resource security in the short-, mid- and long-term time horizons mainly
through the financing activities of sectors that are contributing in a negative way to the preservation of natural resources.
• Access to Housing: Actual and potential positive impact on accessibility to Housing in the short-, mid- and long-term time horizons
mainly through the offering of products/services that support affordable housing for Customers.
• Access to Finance: Actual and potential positive impact on access to Finance in the short-, mid- and long-term time horizons mainly
through the offering of products/services that support Customers’ financial inclusion.
• Contribution to Healthy Economies: Actual and potential positive impact on Customers, including small and medium enterprises in
the short-, mid- and long-term time horizons mainly through the offering of products/services, that contribute to the creation of
healthy economies.
Furthermore, material impacts have also been identified across the Group’s own operations, which refer to:
• Climate Stability: Actual and potential negative impact on climate stability in the short-, mid- and long-term time horizons due to
energy consumption in the Group’s facilities.
• Contribution to Livelihood of own workforce: Actual and potential positive impact on own workforce in the short-, mid- and long-
term time horizons through the provision of secure employment, social dialogue, freedom of association and through the offering of
training and skills development programs to own workforce.
• Contribution to Equality and Justice of own workforce: Potential positive impact on own workforce in the mid- and long-term time
horizons through the Group’s strategic priority towards improving diversity.
• Contribution to Health and Safety of own workforce: Actual and potential positive impact on own workforce in the short-, mid- and
long-term time horizons through the significant investments made by the Group in Health, Safety and Wellbeing initiatives.
Finally, the following material impact governs the Group’s relationships with its stakeholders across the entire value chain, however, material
impacts related specifically to the upstream activities (supply chain and the natural environment) have not been identified due to their overall
low materiality across the entire value chain and the Group’s activities and business model.
• Contribution to Transparency and the Rule of Law: Actual and potential positive impact on all stakeholders in the short-, mid- and
long-term time horizons through initiatives that foster ethical corporate culture.
Risks
The Group has identified material risks to the following sustainability matters:
• Climate Transition and Physical risk: The Group has identified risks related to Climate change as material in the medium- and long-
term time horizon.
o Climate transition risks impact both the creditworthiness of counterparties and the recovery value of such exposures, e.g.,
non-compliance with climate-related regulations, increased cost of raw materials / energy needs, failing to keep up with
the pace of technological change, and shift in consumer preferences. Taking into consideration the above, climate
transition risks are primarily related to the downstream portfolio of the Group.
o Climate physical risks affect clients’ ability to meet financial obligations and reduce the value of their properties or
premises due to physical risk events within sectors or geographies vulnerable to physical risk. For instance, there may be
lower collateral valuations in real estate portfolios as a result of increased flood risk. Taking into consideration the above,
climate physical risks are primarily related to the downstream portfolio of the Group.
• Biodiversity & ecosystems: The Group has identified risks related to Biodiversity and ecosystems as material in the long term,
considering the significant impact of biodiversity-related risks on the creditworthiness of its obligors, leading to credit losses for the
Bank. For example, companies unable to comply with biodiversity-related regulations, now and more increasingly in the future, may
face fines, litigation, or operational restrictions, reducing their financial stability, while companies reliant on ecosystem services, such
as agriculture, forestry, fisheries, etc. may face reduced productivity or higher operational costs due to biodiversity loss, affecting
their ability to meet financial obligations. Biodiversity and Ecosystems risks are primarily related to the downstream portfolio of the
Bank.
• Staffing and training issues: Risks related to the Group’s own workforce, particularly inadequate “training and skills development” is
assessed as material in the short-, medium-, and long-term. Such risks can reduce productivity and cause operational disruptions, as
Employees may lack the skills needed to adapt to evolving technologies and processes. Furthermore, insufficient training and
development may decrease employee engagement, heighten dissatisfaction, and drive higher turnover rates. Own workforce risks
are related to the Bank’s own operations.
• Disclosure and data protection issues, Fiduciary breaches, Unsuitable promotion practices, Product suitability issues/ Inadequate
disclosure of product terms, Disputes over advisory activity: Risks related to consumers and end-users, in particular “Privacy”,
“Access to quality information” and “Responsible marketing practices” are considered material in the short-, medium- and long-
term. Although the financial impact of these risks is not quantified directly in monetary terms, the rapid technological progress and
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57 | ANNUAL FINANCIAL REPORT
development in cybersecurity, which can lead to data breaches, highlights the importance of closely monitoring and adapting to the
evolving environment. Failure to do so could expose the Bank to substantial financial losses due to fines, legal fees, and
compensation costs, as well as damage to the Bank's reputation. In addition, inadequate access to quality information and
irresponsible marketing practices can erode consumer trust and also lead to regulatory penalties, further impacting the Bank's
financial stability. Although consumers and end-users’ risks affect the Bank’s clients, the root cause for risk manifestation lies on the
Bank’s own operations (most typically due to potential failures of internal controls established to prevent such risks).
• Corruption and bribery: Risks related to corruption and bribery are assessed as material in the short-, medium-, and long-term due
to possible reputational damage and material penalties imposed by regulatory authorities. This outcome is driven by the AML/CFT
risks associated with this topic, which have a material financial effect as these risks directly impact the institution’s financial stability,
reputation, and regulatory compliance. Failure to prevent financial crimes like money laundering and terrorist financing can result in
significant financial penalties and legal consequences. Additionally, it can damage the Bank’s reputation, erode Customer tru st, and
hinder the ability to attract and retain clients, ultimately affecting long-term growth and profitability. Risks related to corruption and
bribery risks are identified across the value chain, since they can arise from the Group’s own operations and through interactions
with third parties, intermediaries, and clients, in case of insufficient due diligence or weak controls.
Opportunities
The Group has identified material opportunities related to the downstream value chain under the following ESRS topics:
• Climate change mitigation and adaptation: The Group has identified material opportunities related to both Climate change
mitigation and Climate change adaptation. Opportunities in Climate change mitigation are considered material in the current year
and are expected to remain material across the short-, medium-, and long-term horizons, supported by current EU Taxonomy-
aligned and other sustainable financings and their potential growth. Climate change adaptation is assessed as a material opportunity
in the long term, reflecting the expected intensification of physical risks and the increasing demand for financing solutions that
enhance resilience and support adaptation measures.
• Protection and restoration of biodiversity and ecosystems: The Group has identified material long-term opportunities (i.e.,
sustainable financings in line with its Sustainable Finance Framework) related to the protection and restoration of biodiversity and
ecosystems. As transition risk related to biodiversity and ecosystems is expected to intensify for the Group’s counterparties, a
significant long-term growth is anticipated in financing opportunities that address these challenges.
• Transition to a circular economy: The Group has also identified material long-term opportunities (i.e., sustainable financings in line
with its Sustainable Finance Framework) related to the transition to a circular economy. Client engagement survey results hav e
indicated a rising interest in future investments that support circular economy initiatives. Combined with the strategic importance of
this topic, which consistently ranks among the top environmental priorities for corporates in Greece and across Europe, financing
solutions that support resource use and circular economy initiatives are expected to grow in the long term.
Connection of material impacts, risks and opportunities with strategy and business model
The identified Impacts, Risks, and Opportunities (IROs) under the Corporate Sustainability Reporting Directive (CSRD) aim at informing and
shaping the Group’s strategic priorities, driving financing performance and empowering risk governance. The Group str ategy is regularly
informed by the material IROs presented in Table 8, with the aim to mitigate negative impacts on Climate Stability, Habitats, and Resource
Intensity, while strengthening positive outcomes related to Diversity and Employee Health & Safety in future time horizons. In addition, ESG
strategy is informed by the material IROs, with the aim of enabling the Group to pursue material opportunities arising from environmental and
social matters and reinforcing its overall business resilience against the potential realisation of related riskAmidst global efforts to address
challenges, the Group considers the Sustainable Development Goals (SDGs) and the UNEP FI Principles on Responsible Banking, aiming for a
low-carbon future and leveraging digital innovations to empower its Clients and drive innovation in financing. Through concrete impact-linked
targets and actions, the Group demonstrates its commitment to sustainability.
In 2025 the Group continued to implement the ESG Workplan, which aims to integrate sustainability and climate risk criteria in the decision-
making processes, including strategy, risk management, lending, and operations. As a result, the Bank is directing c apital to finance its clients’
decarbonization efforts in alignment with the Sustainable Finance Framework’s eligible activities.
The Group recognizes that its impacts on the natural environment and people are closely and significantly related to its financial products and
services. The Group offers access to financial services through a wide range of high-quality financial products and services, including retail
banking, banking for medium-size and large enterprises, asset management and private banking, insurance products, investment banking,
brokerage and real estate Management. The Group’s most significant entity, Alpha Bank, a leading financial institution in Southeastern Europe,
has the ambition not only to cause no significant harm to the environment and society via its activities but also to contribute to the transition
of the Greek economy to a sustainable model, through the development of sustainable finance and associated products to support
investments in green projects.
The downstream segment of the value chain (portfolio) is particularly significant due to the inherently higher materiality of impacts created
through the Group’s products and services offered to its clients (lending portfolios) and through its investment a ctivities (own investments
portfolio). Nevertheless, material impacts are assessed across the entire value chain. Refer to ‘Material impacts, risks and opportunities’
section above.
Current financial effects of material risks
Regarding the current financial effects of the material risks the Group has identified the following:
• Climate Change: For 2025, the operational risk losses related to climate risk are very limited and thus, the current financial effect is
considered not material.
• Biodiversity and Ecosystems: For 2025, there are no operational risk losses related to biodiversity and ecosystems-related risks.
Therefore, the current financial effect from such risks is considered not material.
• Own Workforce: For 2025, the operational risk losses related to employee practices are very limited and thus, the current financial
effect is considered not material.
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58 | ANNUAL FINANCIAL REPORT
• Consumers and end-users: For 2025, the operational risk losses related to disputes over advisory activity, unsuitable promotion
practices, disclosure and data protection issues product suitability issues / inadequate disclosure of product terms and fiduciary
breaches (miscellaneous) are very limited and thus, the current financial effect is considered not material.
• Business conduct: For 2025, the operational risk losses related to corporate governance issues, culture & ethics, anti-bribery &
corruption and AML regulation and policy breaches are zero and thus, the current financial effect is considered not material.
Since Climate change and Biodiversity and ecosystems topics are not material in the short-term, no material adjustments within the next
annual reporting period to the carrying amounts of assets and liabilities reported in the related financial statements are expected. Social and
governance risks are effectively managed and mitigated, resulting in limited residual risk and thus no material adjustments in the Bank’s
balance sheet or P&L are expected.
Current financial effects of material opportunities
Regarding the current financial effects of the material opportunities the Group has identified the following:
• Climate Change: For 2025, the Group has identified climate change mitigation-related opportunities (i.e., sustainable financings in
line with its Sustainable Finance Framework) above Euro 2.1 billion, which are considered material based on the applicable
materiality threshold of circa Euro 1 billion. For climate change adaptation, the Group has not identified any relevant opportunities
and therefore, current financial effects are not considered material.
• Biodiversity and Ecosystems: For 2025, the Group has not identified opportunities related to Biodiversity & ecosystems and
therefore, current financial effects are not considered material.
• Circular economy: For 2025, no material opportunities related to the resource use & circular economy have been identified, as the
identified amount does not exceed the established materiality threshold of circa Euro 1 billion.
The Group anticipates significant growth of sustainable financing over the next year, which is expected to result in substantial adjustments to
the gross carrying amounts of assets reflected in the financial statements for the next annual reporting period.
Anticipated financial effects of material risks
• Climate Change: The Group, in order to estimate the anticipated financial effect for climate risk, examines climate change mitigation
(transition) and climate change adaptation (physical) risks separately leveraging on the outcome of the materiality assessment
performed.
o Climate change mitigation is identified as a material sub-topic in the medium and long-term, since the percentage of the
exposures with High and Medium likelihood of occurrence over the Group Total Assets exceed the established materiality
thresholds.
o Climate change adaptation is identified as a material topic in the medium and long-term considering that for some physical
risk factors (e.g., wildfire in case of the regional analysis and floods in case of sectoral analysis) the anticipated occurrence
is relatively high.
Table 9: Risks - Materiality outcome of ESRS E1. Climate Change
10
Anticipated Financial Effect – Risks
ESRS Sub-topics
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Climate Change mitigation
Immaterial
Material
Material
Climate Change Adaptation
Immaterial
Material
Material
• Biodiversity and Ecosystems: Biodiversity and Ecosystems is identified as a material topic in the long-term since the percentage of
the exposures over the Group Total Assets corresponding to High and Medium likelihood of occurrence categories exceed the
respective thresholds.
Table 10: Risks - Materiality outcome of ESRS E4. Biodiversity and Ecosystems
7
Anticipated Financial Effect – Risks
ESRS Topic
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Biodiversity and Ecosystems
Immaterial
Immaterial
Material
• Social Risks:
o Own Workforce: The anticipated financial effect from risks related to the Group’s own workforce, in particular “inadequate
training and skills development”, is assessed as material in the short-, medium- and long-term. Although these risks are
challenging to quantify, they are considered material due to their potential financial effects to the Group. They can
adversely affect the Group’s human capital by diminishing operational efficiency and contributing to elevated attrition
rates stemming from employee dissatisfaction.
Table 11: Risks - Material Sub-topics of ESRS S1. Own Workforce
Anticipated Financial Effect – Risks
ESRS Sub-topics
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Equal treatment and
opportunities for all
Material
Material
Material
10
The results presented in this table take into consideration the outcome of the materiality assessment performed by Alpha Bank S.A. and Alpha Bank Cyprus
Ltd, which are considered material entities in terms of financial materiality. It is noted that the outcome of the assessment of Alpha Bank Cyprus Ltd is
aligned with that of Alpha Bank SA. For the remaining entities of the Group, particularly those conducting an ESG Risk Materiality Assessment (i.e., Alpha
Leasing, Alpha Bank London and ABC Factors), the financial materiality assessment process included a review of whether any additional material topics are
identified as part of their ESG Risk Materiality Assessment process. In 2025 no such cases were identified.
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59 | ANNUAL FINANCIAL REPORT
o Consumers and end-users: The anticipated financial effect from risks related to consumers and end-users, in particular
“Privacy”, “Access to quality information” and “Responsible marketing practices” is considered material in the short-,
medium- and long-term. Although the financial effect of these risks is not quantified directly in monetary terms, taking
into consideration rapid technological progress and development in the area of cybersecurity which can lead to data
breaches, highlight the importance of closely monitoring and adapting to the evolving environment otherwise it could be
exposed to substantial financial losses due to fines, legal fees, and compensation costs, as well as reputational damage.
Table 12: Risks - Material Sub-topics of ESRS S4. Consumers and end-users
11
Anticipated Financial Effect – Risks
ESRS Sub-topics
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Information-related impacts
for consumers and/or end-
users
Material
Material
Material
Social inclusion of consumers
and/or end-users
Material
Material
Material
• Governance Risks:
o Corruption and bribery: The anticipated financial effect of risks related to corruption and bribery is assessed as material in the
short-, medium-, and long-term due to possible reputational damage and material penalties imposed by regulatory authorities.
This outcome is driven by the AML/CFT risks associated with this topic, which are challenging to quantify, but they are
considered material since they directly impact the institution’s financial stability, reputation, and regulatory compliance.
Table 13: Risks - Material Sub-topics of ESRS G1. Business Conduct
Anticipated Financial Effect – Risks
ESRS Sub-topics
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Corruption & Bribery
Material
Material
Material
Anticipated financial effects of material opportunities
• Climate change: For the short-term horizon the Group considers climate change mitigation related opportunities material, taking
into consideration the fact that sustainable financings towards climate change mitigation are, already, material (exceeding the
respective threshold) and the growth of sustainable financings in the following year, that according to Business Plan is estimated at c.
Euro 939 million, mainly stemming from Energy and Real Estate sectors in the Business portfolio (with some small amounts being
also located in Accommodation and Travel Agencies, Agriculture, Chemicals and Pharmaceuticals, Construction, Wholesale Trade and
Other sectors), while a small amount comes from Households (c. Euro 80 million). For the medium- and long-term horizons, although
the financial effect of these opportunities is not easily quantified directly in monetary terms, the Group considers climate change
mitigation material in both horizons and climate change adaptation in the long-term based on the Group's expectations for the
growth of climate-related sustainable financings in the future.
Table 14: Opportunities - Material Sub-topics of ESRS E1. Climate Change
Anticipated Financial Effect – Opportunities
ESRS Sub-topics
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Climate Change mitigation
Material
Material
Material
Climate Change Adaptation
Immaterial
Immaterial
Material
• Biodiversity and Ecosystems: The materiality assessment performed by the Bank indicates that opportunities (i.e., sustainable
financings) towards protection and restoration of biodiversity and ecosystems activities are considered material in the long-term
(2050) horizon, since the Bank anticipates such opportunities to exceed the threshold of circa Euro 1bn. As transition risk faced by
the Bank’s counterparties with regards to biodiversity & ecosystems are anticipated to intensify over time, financings aimed at this
topic are expected to grow in the longer term. Regarding the short- and medium-term horizon the Bank does not expect material
opportunities that exceed the established threshold based, also, on its Business Plan.
Table 15: Opportunities - Materiality outcome of ESRS E4. Biodiversity and Ecosystems
Anticipated Financial Effect – Opportunities
ESRS Topic
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Biodiversity and Ecosystems
Immaterial
Immaterial
Material
• Circular Economy: Opportunities (i.e., sustainable financings) related to the transition to a circular economy are considered material
in the long-term (2050) horizon. Based on the analysis of the Client Engagement survey results, there is an increased interest among
clients for potential future investments related to circular economy initiatives. Combined with the strategic importance of this
topic—being consistently ranked among the top environmental priorities for corporates in Greece and across Europe—this supports
its classification as a material long-term opportunity for the Bank. As sustainable practices and circular models become more
embedded in business operations, financing solutions that support resource use and circular economy initiatives are expected to
grow significantly over time.
11
The classification of Access to (Quality) Information & Responsible marketing practices as material is further reinforced by the results of the Compliance Risk
Assessment conducted by the Regulatory Compliance Division for Customer Conduct Risk, which has been evaluated as Medium-High in terms of inherent
risk assessment.
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Table 16: Opportunities - Materiality outcome of ESRS E5. Resource use and circular economy
Anticipated Financial Effect – Opportunities
ESRS Topic
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Resource use and circular
economy
Immaterial
Immaterial
Material
Resilience of strategy and business model towards addressing impacts risks and advancing opportunities
Group's strategy and business model demonstrate significant resilience in relation to climate change through a well-structured approach to
managing climate impacts and risks. The Group's comprehensive framework integrates these risks into its overall risk management processes,
addressing both physical risks, such as those arising from extreme weather events, and transition risks associated with the shift to a low-
carbon economy. A detailed materiality assessment has been conducted to evaluate the potential impacts of climate risks on financial
performance, operations, and key stakeholders. This approach aligns closely with global objectives, including the Paris Agreement, and is
supported by the Group’s commitment to achieving net-zero greenhouse gas emissions by 2050 through science-based targets.
Climate Change risks
Alpha Bank’s resilience analysis is based on the following factors in order to identify sectors sensitive to transition risk: Climate Policy Relevant
Sectors (CPRS) perimeter, Net Zero Banking Alliance (NZBA) and Long-Term Strategy for Greece for 2050 (LTS), emission intensities at sector
level and forward-looking Probability of Defaults (PDs) based on the ECB short-term disorderly transition scenario, the contribution of the
calculated (or estimated if not applicable) Scope 1 and 2 emissions of each sector in the Bank’s total Scope 1 and 2 emissions. In the context of
this analysis, more recent literature scenarios, strategic plans and roadmaps were used to qualitatively estimate the probability of occurrence
of each transition risk driver.
To further examine the impact under different time horizons, the Group has conducted a qualitative materiality assessment for transition risk
sub-types (market, technology, reputation, policy and legal), as proposed by the TCFD. This analysis identifies the climate-related transition
risks that materially affect each sector lying within the transition risk sensitive perimeter and under different time horizons.
Regarding physical risk, the Group performs a materiality assessment based on IPCC AR5 RCP 8.5 for 2026, 2030 and 2050 horizons. More
specifically, the Group utilizes the vulnerability analysis to identify potential significant hazards per subsector as well as across the different
geographic regions where real estate properties used as collateral extend.
For further information related to the resilience analysis of climate change risks please refer to [E1.SBM-3] ‘Material impacts, risks and
opportunities related to Climate Change and their interaction with strategy and business model'.
Biodiversity and ecosystems risks
The Group has performed a resilience analysis to assess biodiversity and ecosystem risks within its portfolio. The Group utilizes the ENCORE
(Exploring Natural Capital Opportunities, Risks and Exposure) Tool to examine the key negative impact of sectors (at NACE code level) of its Non-
Financial Corporate portfolio and a literature review to estimate the likelihood of occurrence of the respective nature-related risks, covering
short-, medium-, and long-term horizons.
For further information related to the resilience analysis of nature-related risks please refer to [E4-1] ‘Transition plan and consideration of
biodiversity and ecosystems in strategy and business model’.
Changes to the material impacts, risks and opportunities compared to the previous reporting period
Changes compared to 2024 refer to the following positive impacts related to:
• Contribution to livelihood of own workforce through the training and skills development (for the actual, short, mid and long-term
horizons)
• Contribution to health and safety of own workforce (for the actual, short, mid and long-term horizons).
In addition, the risk “Disputes over advisory activity” was assessed material, based on the outcome of the RCSA, under the ES RS sub-sub-topic
“Access to quality information” which had already been identified in the previous submission (2024).
No changes apply to opportunities, compared to previous reporting period.
Specification of impacts, risks and opportunities covered by ESRS Disclosure Requirements
Material impacts, risks and opportunities related to Climate stability, Biodiversity and Circularity, are covered by [ESRS E1] ‘Climate Change’,
[ESRS] ‘E4 Biodiversity and ecosystems’ and [E5] ‘Resource Use and Circular Economy’.
Moreover, material impacts and risks related to Livelihood, Equality and Justice of Employees, are covered by [ESRS S1] ‘Own Workforce’.
Material impacts, and risks related to Access to Housing and Finance of Customers, are covered by [ESRS S4] ‘Consumers and end-users’.
However, the impact related to Contribution to Healthy Economies, is not covered by an ESRS topical standard, therefore, additional entity-
specific disclosures have been included.
Finally, material impacts, and risks related to the Contribution to Transparency and the Rule of Law are covered by [ESRS G1] ‘Business
Conduct’.
[IRO-1] Description of the process to identify and assess material impacts, risks and opportunities
The Group’s double materiality assessment conducted in 2025
12
aims to encompass both the impact and financial materiality perspectives,
along with the interconnections between them, in accordance with the European Sustainability Reporting Standards (ESRS).
12
The Scoping exercise was performed based on the Group structure as of 30.06.2025 and was informed with the latest available information regarding the
Group structure in September and October 2025.
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The methodology incorporated tools and resources for impact identification and assessment, peer and ESG standards review, and leveraged
output from ongoing engagements with internal and external stakeholders.
For the impact materiality, responses were obtained for the majority of the Group entities and there was no business activity of the Group
entities that was not captured in the impact materiality analysis. Regarding the upstream value Alpha Bank S.A. suppliers’ data were leveraged
as a representative dataset for any assumptions regarding a limited number of entities, as the nature of activities did not differentiate from the
rest of the Group activities. Regarding the potential impacts in the downstream value chain, assumptions were made based on static
exposures and portfolio mix for the offering of products and services in future time horizons.
For the financial materiality, the methodology covers Alpha Bank SA and Alpha Bank Cyprus which are considered material considering the
classification as Relevant Legal Entities (RLEs) in the context of the Group’s recovery plan.
Process to identify, assess, prioritize and monitor impacts informed by due diligence
Impact Materiality
The impact materiality assessment considers all environmental, social and governance ESRS topics and follows a structured five-phase
approach:
Phase 1: Design the Impact Materiality Assessment Approach
Understand the Context (Internal and External)
In this phase, an overview of the Group’s activities and business relationships has been developed, along with the context in which these occur
and identifies its key affected stakeholders:
a) Entity perimeter definition:
In determining the perimeter for Impact Materiality, the full scope of business activities across all Group entities was taken into account.
However, micro entities were excluded from the impact materiality perimeter, due to the fact that no activities of different nature have
been identified and due to the small size and negligible impact. In addition, “Holding” and “Special purpose and holding” ent ities were
excluded on the basis that their impacts are reflected indirectly in the value chain through their related entities, and internal or
intragroup transactions do not trigger any additional impacts due to the nature of the activity (holding).
b) The business activities and relationships of the Group with the affected stakeholders were performed by examining the entities’
activities as well as their portfolio data and supply chain needs. It is noted that the understanding of business relationships and affected
stakeholders was achieved through the review on existing stakeholder mapping. Through this review, the Group identified its key affected
stakeholders. Specifically:
Own Operations:
Activity mapping for the Group entities is performed based on the economic activity description, sector (NACE), and location of
operations. The impact materiality process focuses on the entities operating in Greece, Cyprus, UK and the following Group activities:
Asset Management, Banks, Financing companies, Insurance, Investment Banking, Provision of Information technology services and
consulting, and Real Estate and Hotel.
Downstream Value Chain:
For downstream activities the results stem from the use of the Principles for Responsible Banking portfolio analysis for subsidiaries,
leveraging data related to their products and services, which describes the Group’s business relationship with its Custom ers. Alpha
Supporting Services S.A. and Alpha Finance A.E.P.E.Y. are excluded, due to the nature of their activities as they already trigger impacts at
own operations (no downstream/portfolio relevance).
Upstream Value Chain:
The mapping for upstream activities includes collecting information for major suppliers based on spending for purchased goods and
services per NACE of supplier. Alpha Bank S.A.’s major supply categories are identified, and confirmation has been provided b y the other
Group entities on similar supply chain activities. Responses from entities with business activities due to similar activities and locations of
operation to the other Group entities in scope, it is reasonable to assume that no additional impacts could be created
c) Other contextual information: research has been conducted on country/sector level sustainability-related priorities and Alpha Bank S.A.'s
external sustainability commitments. The aforementioned contextual information has been utilized as sources for potential impacts, risks
and opportunities in the future time horizons (please refer to Phases 2, 3).
Time horizons are selected for actual impacts (2025) and potential impacts (short term: 2026, mid-term: 2030, long-term: 2050). Stakeholders
have been engaged effectively in the subsequent phases 2 and 3 of the double materiality assessment by leveraging existing stakeholder
engagement output that occurred throughout the year, performing dedicated meetings with stakeholder representatives and output from a
wholesale Customer engagement survey. See [SBM-2] ‘Interests and views of stakeholders’ in more detail.
Phase 2: Identify Actual and Potential Impacts
a) Impact identification - actual impacts
Own operations:
The basis for the identification of material impacts created by the Group’s own operations has been the Group’s prior year ma terial
impacts (Sustainability Statement 2024) and impacts emerging from ESG Standards Review and Peer Review. Specifically, to ensure
completeness, the Bank has further examined whether the identified impacts accurately reflect the actual impacts created to people and
the environment.
Downstream: Impacts have been identified by using UNEP FI Portfolio impact Analysis Tools (i.e. Investment Portfolio Impact Analysis
Tool, Consumer Banking and Institutional Banking Identification Modules and Real Estate Impact Analysis Tool, for the respective
portfolios) and specifically by using sector-impact associations (as per the UNEP FI Sector-Impact Map), in accordance with the UNEP FI
Impact Protocol. Findings from the impact driven risks analysis using the ENCORE tool will be considered as an overlay for identifying and
assessing the negative environmental impacts in particular.
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Upstream: Similarly to the downstream segment, impact identification is based on the implementation of the UNEP FI Sector-Impact
Map. Specifically, to capture impacts generated in the upstream segment of the VC, the Sector-Impact Map has been utilized for selected
NACE sectors, which were determined based on the Bank’s supplier spending.
b) Impact identification - potential impacts
Potential impacts are identified through inherent analysis of shifts and transitions in the materiality of sustainability impact topics across
different time horizons. This analysis is based on desktop research on policies, regulations, sectoral trends, macroeconomic conditions of
sustainability themes, academic and scientific evidence, and other relevant sources. The analysis focuses on how the main sectors of the
Group’s portfolio prioritize the identified actual impacts in future time horizons. The resul ts serve as a proxy for cyber the identification of
the material impacts for the Group.
Phases 3 and 4: Assess and Prioritize Impacts
a) Impact assessment and prioritization - actual impacts
b) Own operations: For own operations, an overall “severity” scoring for negative impacts, and an overall “significance” scoring for positive
impacts, based on the results of the identification phase. The impacts have been evaluated and verified through consultation and
stakeholder engagement with HR and Compliance, and Governance and Sustainability- ESG Strategy Business Areas.
Downstream and upstream
13
: The materiality of actual impacts connected to the Group through its products and services and suppliers,
for downstream and upstream, respectively, has been assessed based on significance (positive) and severity (negative). The significance
(or severity for negative) of an impact has been evaluated from the viewpoint of the affected people or the environment. To this end, it
has been determined by the characteristics (criteria) of scope, scale and irremediability (for negative impacts only), taking into
consideration monetary figures related to portfolio and supply chain.
Subsequently, based on a top-down approach, significance and severity have been aggregated at the Group level, per impact and have
been prioritized based on quantitative thresholds
14
.
c) Impact assessment and prioritization - potential impacts
Regarding potential impacts, an inherent analysis (without considering mitigation actions or changes in the current portfolio) of
sustainability impact topics has been conducted. The scoring methodology has been applied as an aggregated conclusion of materiality
per impact topic across three-time horizons. Additionally, the likelihood criterion is based on desktop research and has been incorporated
into the analysis. It is noted that for own operations, the potential impacts have been evaluated and verified through consultation and
stakeholder engagement with the respective business areas HR and Compliance, and Governance and Sustainability- ESG Strategy.
Generally, the whole impact materiality assessment process of the Group, informed by the due diligence process, included consultation with
subject matter experts, as an additional source for impact identification, assessment and prioritization.
Phase 5: Report on the Process and Outcome
To map the material UNEP FI topics with the respective ESRS topics, sub-topics and sub-sub topics, the UNEP FI’s Topics Mapping from the
UNEP FI Interoperability Guide has been leveraged.
The reporting phase included the preparation of narratives for the description of the processes to identify and assess material impacts for
inclusion in the Sustainability Statement, along with the respective outcomes.
Process to identify, assess, prioritize and monitor risks and opportunities that have financial effects
Financial Materiality
Risks
Current Financial Effect
In order to assess the magnitude of the current financial effect of its material risks, the Group has evaluated if any operational risk losses have
been recognized during the current financial year.
Anticipated Financial Effect
Climate Change (ESRS E1):
The Group, in order to estimate the anticipated financial effect for climate risk, examines the anticipated financial effect separately for
transition and physical risks.
Climate change mitigation – Transition risk
More specifically, to evaluate the anticipated financial effect for climate change mitigation (transition risk), the Bank leverages on the outcome
of the materiality assessment performed that takes into consideration the following dimensions:
a) Likelihood of occurrence:
The Bank has identified the sensitive to transition risk perimeter by taking into consideration several factors such as the CPRS perimeter, the
NZBA and LTS for Greece for 2050, emission intensities and forward-looking PDs, contribution of calculated (or estimated if not applicable)
Scope 1 and 2 emissions as well as exclusion of sustainable loans related to climate change mitigation objective.
The transition risk score is derived from the qualitative materiality assessment for transition risk (climate change mitigation) sub-types
(market, technology, reputation, policy and legal) as proposed by the TCFD, that identifies the climate-related transition risks that materially
affect each sector lying within the transition risk sensitive perimeter and under different time horizons. This score is considered as a proxy for
the likelihood of occurrence of an anticipated financial effect for the Bank.
13
The Scoping exercise was performed based on the Group structure as of 30.06.2025 and was informed with the latest available information regarding the
Group structure in September and October 2025.
14
As per IG 1, par. 27, “ESRS 1 sets criteria for the materiality assessment but not specific thresholds to determine when a matter or information is material or
not. Therefore, the assessment requires the exercise of judgement. The undertaking needs to set thresholds based on ESRS 1 criteria as well as its own
specific facts and circumstances.”
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b) Potential Magnitude:
After recognizing the sectors lying within the sensitive perimeter that have High, Medium, or Low likelihood of occurrence, the Bank has
proceeded with the calculation of the percentage of the Bank’s exposures within the sensitive perimeter over Total Grou p Assets categorized
under High, Medium and Low likelihood of occurrence, across different time horizons and set thresholds for materiality.
Climate change adaptation - Physical risk
In addition, to evaluate the anticipated financial effect for climate change adaptation (physical risk), the Bank leverages on the outcome of the
materiality assessment performed that takes into consideration the following dimensions:
a) Likelihood of occurrence:
The vulnerability assessment outcome per sector and region. The Bank has laid down a methodology based on sensitivity and exposure
analysis (when separately assessed) to derive vulnerability to physical risk factors. Vulnerability analysis is performed to identify potential
significant hazards per subsector covered by the analysis for Business portfolio, as well as across the different geographic regions where real
estate properties used as collateral extend. The vulnerability assessment outcome is considered as a proxy for the likelihood of occurrence of
an anticipated financial effect for the Bank.
b) Potential Magnitude:
After recognizing the sectors and regions that have High, Medium, or Low likelihood of occurrence, the Bank has proceeded with the
calculation of the percentage of the Bank’s exposures over Total Group Assets categorized under High, Medium and Low likeliho od of
occurrence across the different time horizons and set thresholds for materiality (the materiality threshold has been set on B ank’s 'exposures
over Group Total Assets’ under High Likelihood of Occurrence). Given that multiple physical risks (both chro nic and acute) are separately
examined and then aggregated, with an averaging effect on the materiality results overlays are applied to account for the fact some physical
risks (e.g., flood) may individually have a high likelihood of occurrence.
It is noted that Alpha Bank Cyprus also performs a materiality assessment to evaluate the anticipated financial effects from climate-related
risks, which is taken into consideration to determine the overall materiality of such risks for the Group.
Further information related to the materiality assessment methodology for climate risks is provided under [E1.IRO-1] ‘Description of the
processes to identify and assess material climate-related impacts, risks and opportunities’.
Nature-Related risks (ESRS E2-E5):
The Bank utilizes the ENCORE (Exploring Natural Capital Opportunities, Risks and Exposure) Tool to examine the materiality of the anticipated
financial effect for nature-related risks.
a) Likelihood of Occurrence
For sectors with a key negative impact on each nature- related topic, a risk assessment is performed to estimate the likelihood of occurrence
of the respective nature-related risks, covering short-, medium-, and long-term horizons. The scale of the likelihood of occurrence is defined by
combining the outcome of the Likelihood and the Impact analysis which are performed at sector level.
• Likelihood: the probability of occurrence within a provided time horizon
• Impact analysis: the extent to which the impact, if occurred, would affect nature
b) Potential Magnitude:
To evaluate the anticipated magnitude of financial effect per nature-related ESRS topic, the Bank calculates the percentage of its exposures
classified as High, Medium, or Low Likelihood of Occurrence over the Total Group Assets, across the different time horizons set thresholds for
materiality.
It is noted that Alpha Bank Cyprus also performs a materiality assessment to evaluate the anticipated financial effects from nature-related
risks, which is taken into consideration to determine the overall materiality of such risks for the Group.
Further information related to the materiality assessment methodology for nature-related risks, is provided under [E4.IRO-1] ‘Description of
processes to identify and assess material biodiversity and ecosystem-related impacts, risks, dependencies and opportunities’.
Social Risks related to Own workforce and Consumers and end-users (ESRS S1 and S4):
To evaluate the anticipated financial effect of social risks, the Group has conducted a mapping of the respective ESRS sub-topics with the risk
types identified within the Operational Risk Taxonomy framework and the corresponding inherent risk assessment outcomes derived from the
RCSA. ESRS sub-sub-topics that are assessed as having a High or Medium High inherent risk are deemed material. For ESRS sub-sub-topics and
associated operational risks that encompass multiple RCSA risk events, a conservative approach has been utilized, taking into account the
highest observed risk assessment outcome. It is noted that the inherent risk assessment considers which is the impact for the Bank in case the
risk is manifested within the next year (short-term) without additional mitigation actions going forward. It is assumed that the same
conclusions are, also, applicable in the medium- and long-term horizons. Overlays on the outcome of the RCSA have been applied to ensure
that limitations of the assessment are addressed and drivers leading to the classification of the topic as material are the most relevant for the
Group.
Social Risks related to workers in the value chain and affected communities (ESRS S2-S3):
The Group’s financial materiality assessment concludes that [ESRS S2] ‘Workers in the Value Chain’ and [ESRS S3] ‘Affected Communities’ are
not material since the impact analysis conducted did not identify any significant impacts related to these topics, nor does the Group have
dependencies on such aspects. Additionally, the Group’s policies and processes ensure compliance with minimum regulatory requirements.
Governance Risks:
To evaluate the anticipated financial effect of governance risks, the Group conducted a mapping of the respective ESRS sub-topics with the risk
types identified within the Compliance Risk Assessment and the corresponding inherent risk assessment outcomes.
ESRS sub-sub-topics that are assessed as having a High or Medium High inherent risk are deemed material.
Further information related to the double materiality assessment methodology for Governance risks is provided under [G1.IRO-1] ‘Description
of the processes to identify and assess material business conduct impacts, risks and opportunities’.
Opportunities
Current Financial Effect
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In order to assess the magnitude of the current financial effect, the Group has evaluated if any material ESG-related opportunities (i.e., EU
Taxonomy aligned and other sustainable financings according to the Bank’s Sustainable Finance Framework) have been recognized during the
current financial year.
Anticipated Financial Effect
In the short-term horizon, the Group identifies material opportunities by leveraging the projected growth of sustainable financing, as outlined
in its Sustainable Finance Framework and reflected in its Business Plan. For the medium- and long-term horizons, the materiality assessment is
based on the Group’s expectations for the growth of sustainable financing in the future. This is supported by the anticipated increase in
relevant risks where applicable (e.g., physical risks are expected to intensify over time, leading to a rise in adaptation-related financings).
Regarding the monitoring process, the Group has integrated climate risks into its overall risk management framework. Specifically, the Group
has already incorporated in its Risk Appetite Framework (RAF) a set of quantitative indicators and qualitative commitments regarding climate
risks. In terms of quantitative indicators, the Bank has defined several C&E indicators designed to improve the sustainability of the portfolio
and mitigate potential exposure to risk and are incorporated in Risk Appetite Framework as supporting elements. Additionally, limits have
been established in part of the existing C&E indicators. The indicators cover the area of business planning and green financing, collateral
vulnerability to physical and transition risk, financial activity vulnerability to physical risk and sustainable investing.
Description of how connections of impacts and dependencies with risks and opportunities that may arise from those impacts and
dependencies have been considered
The relationship between risks/opportunities and impacts/dependencies is not considered simple/ one-dimensional. Instead, risks and
opportunities may arise from a combination of underlying factors, including impacts, dependencies, and other external factors such as
regulatory requirements and the associated obligations of the Group.
Generally, risks and opportunities related to climate change mitigation and biodiversity and ecosystems (also referred to as habitat and
species) are primarily linked to impacts in the downstream portfolio and the transition efforts of clients aimed at minimizing these negative
effects. In contrast, risks associated with climate change adaptation are predominantly tied to dependencies and damages from extreme
physical events. The training and skills development related risks are primarily linked to the Bank's dependency on human capital. Privacy risks
are mainly connected with external factors, including regulatory changes such as GDPR and cyber threats, which can undermine trust and
reputation and potentially result in significant financial losses. Risks related to access to quality information and responsible marketing
practices are primarily linked to external factors such as evolving regulatory requirements, industry standards, and societal expectations.
Failure to provide accurate, transparent, and acces sible information or to adhere to responsible marketing practices could damage the Group’s
reputation, erode Customer trust, and potentially result in regulatory penalties or financial losses. Business conduct-related risks are linked to
both impacts and dependencies and are strongly influenced by strict compliance requirements. Failure to meet these obligations adequately
could result in significant financial impacts for the Group.
Decision-making process and the related internal control procedures
The process is based on existing methodologies and capabilities, such as the ESG Risk Materiality Assessment for financial materiality, as well
as widely adopted tools for impact materiality like the UNEP FI Portfolio Impact Analysis Tool. Various alternative methodological assumptions
were carefully assessed and discussed to conclude to the more appropriate methodology to be followed for double materiality assessment
purposes.
A close collaboration between Business Areas of the Group (Governance and Sustainability and the Climate, ESG, and Enterprise Risk
Management, Human Resources, Compliance and Finance) was ensured to derive the final double materiality assessment outcome. Oversight
and frequent input from senior staff, along with regular Steering Committee meetings, were key to safeguarding the soundness of the analysis.
The meetings involved the participation of the Directors of the Business Areas involved (e.g. Governance and Sustainability, Climate, ESG, and
Enterprise Risk Management, Internal Audit, Data Privacy, HR, etc.). The Governance and Sustainability Business Area was responsible for
impact materiality and opportunities assessment. Climate, ESG, and Enterprise Risk Management Business Area were the primary responsible
for the financial materiality assessment of risks. Additionally, an external consultant provided support by contributing to h igh-level design
principles and assisting with or reviewing and challenging quantitative and qualitative analyses and key assumptions, review and benchmark of
analyses against relevant market practices, providing recommendations to the working group as needed.
The materiality assessment, along with the calculations and assumptions, has been subsequently reviewed and thoroughly examined at both
the working group level (involving all process stakeholders) and the Steering Committee level.
Integration of risk and impact assessment into the Group’s overall risk management process
The Group adopts a proactive approach to the management of ESG risks. Emphasis is placed on risks arising from climate change, which is a
key component of its Risk Management Strategy. Following the recommendations of the TCFD, the Group assesses current and upcoming
environmental policies, legal requirements and regulatory guidelines relating to climate and the environment, in order to record and efficiently
manage any transitional risks related to its activities. The Group has developed a comprehensive action plan, submitted to the European
Central Bank (ECB) in May 2021, in which it presented how the climate risk assessment would be incorporated in its operations and in the risk
management process. The implementation of the plan began in June 2021, continued throughout 2022 and was enhanced, taking into
consideration the feedback provided by the Single Supervisory Mechanism (SSM) in the context of the Climate Stress Test, conducted in
January 2022, and the Thematic Review of Climate-related and Environmental Risk Strategies, Governance and Risk Management Frameworks,
conducted in June 2022. Leveraging on the work already performed in 2022 the Group has proceeded with targeted implementations in
accordance with Group’s ESG plan commitments, which continues t o be applicable in 2025.
The Group acknowledges the relevance and potential impact of the risks stemming from climate and environmental related factors, and
especially climate change, and as part of its plan and in alignment with the respective external guidelines. It has elaborated further on the ESG
incorporation into the risk identification and materiality assessment processes and in the overall risk management framework, and is
committed to monitoring, assessing, and managing these risks going forward. More specifically, the following activities have been performed:
• The Group has enhanced its credit policy to incorporate the ESG obligor, transaction and overall, per transaction (combination of
obligor and transaction) assessment, into its credit approval process.
• The Bank has updated its Risk Inventory to provide a comprehensive overview of the enhancements and progress achieved in
climate and nature-related risks in the Bank's Risk Registry. The main climate-risk transmission channels in the area of risk
management include transition risk (e.g. the risk of any negative financial impact on the institution, stemming from the current or
from prospective impacts of the transition to an environmentally-sustainable economy on its counterparties or its invested assets),
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65 | ANNUAL FINANCIAL REPORT
physical risk (e.g. the risk of any negative financial impact on the institution, stemming from the current or prospective impacts of
the physical effects of environmental factors on its counterparties or its invested assets) and other social and nature-related risk
aspects. p.133 Pillar III Disclosures June 30, 2025
• The Group has updated its Materiality Assessment of ESG risks identifying the sectors that are most vulnerable to climate and
environmental-related risks. In alignment with the guidance across different sources (e.g. ECB, European Banking Authority (EBA),
European Commission), the Group considers Climate and Environmental risks as a theme, i.e., as a transversal risk, incorporating
such factors as drivers of existing financial and non-financial risk categories in its risk management framework
The abovementioned ESG Risk Materiality assessment process has been leveraged for the financial materiality assessment of risks in the
context of CSRD. Therefore, the foundations of the approach followed are common, while some differentiations are applied in the
methodology followed in order to accommodate the specificities of each assessment.
Furthermore, Risk and Control Self-Assessment (RCSA) and Compliance Risk Assessments, which are considered integral part of the Bank’s Risk
Management Framework, have been leveraged for the financial materiality assessment of social and governance risks.
More information regarding the identification and mitigation of risks associated with other environmental and social factors is provided under
[E1-2] ‘Policies related to climate change migaon and adaptaon’.
Description of how the process to identify, assess and manage opportunities is integrated into the undertaking’s overall mana gement
process where applicable
Alpha Bank Group uses its Sustainable Finance Framework and EU Taxonomy to identify ESG-related opportunities. These frameworks provide
a structured approach to classify and identify sustainable finance opportunities, ensuring that the Group’s opportunity management practices
are aligned with its overall management strategy.
More specifically, the Sustainable Finance Framework (“SFF” or “the framework”) can be defined as a guide that sets out a ser ies of
approaches and procedures required for classifying financing as sustainable. Specifically, the framework stipulates the decision and
classification process, that the Group implements, to categorize its financial products or services as sustainable (i.e., green, or social). The main
purpose of the framework is to enable the identification and categorization of sustainable activities and to lay out the criteria to characterize
specific loans as sustainable.
The Group’s actions focus on the increase in Sustainable Financings and the reduction of financings that may have a negative impact on the
environment and people’s health and wellbeing. In addition, policies and procedures are developed to reduce the opera tional environmental
footprint and to strengthen the commitments associated with this objective.
The Group’s strategic plan aims to address the risks and utilize new business opportunities to increase its positive effect o n society and the
environment, while effectively generating value for its stakeholders. In this respect, strategic commitments and targets are being updated with
the ultimate objective to effectively manage any ESG related issues and improve environmental and social impacts.
With the operationalization of the framework, information on lending transactions is being processed and stored internally along with any
relevant documentation, analyzed, and monitored by relevant areas of the Group.
The Bank is expected to regularly report its performance against its strategic plan and specifically its progress in meeting the sustainable
financing target. The Bank intends to disclose information in relation to the financings which are characterized as sustainable and to the extent
possible, a breakdown of the use of proceeds by eligible themes, in scope business areas, geographical location and refinancing versus new
financing. Reporting information will be made publicly available on an annual basis through its Sustainability Report or dedicated Sustainable
Finance report.
Integration into Overall Management Process
The process to identify, assess, and manage impacts, risks, and opportunities is fully integrated into Alpha Bank’s overall r isk management
process. This integration allows the Bank to evaluate our overall risk profile comprehensively, ensuring that all potential and actual impacts
and risks are identified, assessed, and managed effectively.
Description of how process to identify, assess and manage impacts, risks and opportunities has changed compared to prior reporting period
As part of our preparation for CSRD reporting, the Group has conducted a double materiality assessment (DMA) in conformance with the ESRS
standards. This marks a significant change from the previous materiality assessment methodology. Specifically:
Transition to Double Materiality: For a second consecutive year the Group has implemented a double materiality to capture both the inside-
out impacts of its operations on the environment and society, as well as the outside-in risks and opportunities that various ESG matters could
generate for the Group’s business.
Due Diligence: A more detailed exercise was performed in the content of the CSRD requirements, regarding thorough investigation of its
business activities and operations across geographical areas, business relationships, as well as policies, processes and actions in place for
achieving its strategic targets and long-term goals.
Last Modification Date: The process was last modified in 2024 to incorporate these enhancements and to align with the double materiality
principles outlined in the ESRS. Regarding impact materiality assessment completed in 2025, the Group utilized, in addition to the UNEP FI
resources, the ENCORE tool and enhanced the stakeholder engagement process for materiality purposes compared to the previous reporting
period.
Future Revision Dates: Future revisions of the materiality assessment have not been planned yet however all three short, medium, and long-
term time horizons shall be considered.
E1.IRO-1 Description of the processes to identify and assess material climate-related impacts, risks and opportunities
Impact
Impact materiality analysis identified that climate-related impact was deemed material as a result of the Group’s activity in the following
sectors (table includes the top contributing sectors, as a result of the Group’s Banking sector activity):
Table 17 Top contributing sectors for climate-related impact
a/a
Sectors
1
50 Water transport
2
35 Electricity, gas, steam and air conditioning supply
3
68 Real estate activities
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a/a
Sectors
4
19 Manufacture of coke and refined petroleum products
5
24 Manufacture of basic metals
6
41 Construction of buildings
7
42 Civil engineering
8
51 Air transport
Material negative impact to climate stability though GHG emissions is resulting from the Group’s exposure to a number of sect ors, such as
water transport, electricity/gas/steam supply, real estate activities, and more. The impact materiality analysis was performed using the UNEP
FI Impact Analysis Tools and resources. Through these, the Group's downstream impacts could be identified by utilising the Gr oup’s financing
to specific client sectors; for example, for banking services, the exposure of loans per NACE code was used for corporate clients. For more
information please refer to the section [IRO-1] ‘Description of the process to identify and assess material impacts, risks and opportunities’,
regarding own operations, negative impact is owing to energy consumption in the Group’s buildings.
Risks
Definition & Identification
Climate-related risks are the financial risks posed by the exposure of institutions to counterparties that may potentially contribute to or be
affected by climate change. This could, for example, take the form of physical damage caused by extreme weather events or a decline in the
asset value of a counterparty that operates in carbon-intensive sectors subject to taxation on CO
2
.
• Physical: Physical risks are the risks of any negative financial impact on the institution stemming from the current or prospective
impacts of the physical effects of environmental factors on its counterparties or invested assets. They are typically defined as risks
which arise from the physical effects of climate change and environmental degradation and can be categorized as following:
o Acute: which arise from particular/extreme events, especially weather-related events such as droughts, storms, floods,
fires or heatwaves, or other environmental hazards that may damage production facilities and disrupt value chains.
o Chronic: which arise from longer-term trends (progressive shifts in climate and weather patterns or a gradual loss of
ecosystem services), such as temperature changes, rising sea levels, reduced water availability, biodiversity loss and
changes in land and soil productivity.
• Transition: Transition risks are the risks of any negative financial impact on the institution stemming from the current or prospective
impacts of the transition to an environmentally sustainable economy on its counterparties or invested assets, including:
o climate and environment related policy changes, for example, as a result of energy efficiency requirements, carbon-pricing
mechanisms that increase the price of fossil fuels, or policies to encourage a sustainable use of environmental resources;
o technological changes, for example, if a technology with a less damaging impact on the climate or the environment
replaces a technology that is more damaging, hence making it obsolete or uncompetitive;
o behavioral changes, for example, if the choices of consumers and investors shift towards products and services that are
more sustainable; or if it becomes more difficult to attract and retain Customers, Employees, business partners and
investors when a counterparty has a reputation for damaging the climate and the environment.
• Liability: Liability risk in the context of ESG factors relates to the risk stemming from people or businesses seeking compensation for
losses they may have incurred due to ESG factors, e.g., when institutions’ counterparties are held accountable for the negative
impact, they have on ESG factors through their activities.
15
In alignment with the relevant external guidance across different sources
16
, the Group has incorporated ESG factors as drivers of existing
financial and non-financial risk categories (e.g. credit risk, operational risk, market risk, liquidity risk etc.) in its risk management framework.
The table below provides an indicative mapping of risk drivers to some of the key transmission channels, along with their potential financial
impact on Bank’s risk types:
Table 18 Indicative impact of Climate related risk drivers
Indicative impact of Climate related risk drivers
Risk Type
Transition
Physical
Credit risk
- Impact on credit risk parameters (PD, LGD, EAD) as
a result of transition risk events affecting
counterparties’ ability to service debt (e.g.
- Impact on credit risk parameters (PD, LGD, EAD)
from physical risk events in vulnerable sectors or
geographies (e.g. through lower collateral
15
Liability risks are sometimes considered either physical or transition risks. They could, however, also be considered a separate risk category as they may not
only arise from
16
Some indicative regulatory and other references are:
i) In the 2020 ECB Guide on climate-related and environmental risks: “Institutions are expected to incorporate climate related and
environmental risks as drivers of existing risk categories into their risk management framework.” and “Climate-related and environmental
risks may, in fact, be drivers of several different risk categories and subcategories of existing risk categories simultaneously.”
ii) In the 2021 EBA Report on management and supervision of ESG risks for credit institutions and investment firms: “The EBA recommends
that institutions manage ESG risks as drivers of financial risks, in a manner consistent with the risk appetite, and as reflected in both the
ICAAP and ILAAP frameworks.” In the 2021 European commission final study, “Development of tools and mechanisms for the integration of
environmental, social and governance (ESG) factors into the EU banking prudential framework and into banks' business strategies and
investment policies”: “The majority of banks mentioned that this requires a clear mapping of ESG risks as drivers of existing risk types,
rather than treatment as a stand-alone risk type”, “Most banks that include ESG risks in their RAF fall under the second category, meaning
they consider ESG risk as a transversal risk driver.” and “Participants acknowledged the impact ESG risks can have on financial and non-
financial risks, as opposed to considering ESG risk as a standalone risk type.” In the Climate Financial Risk Forum Guide 2020, “Risk
Management Chapter”: “Good practice is to treat climate risk as a cross-cutting risk type that manifests through most of the established
principal / standalone risk types.”
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Indicative impact of Climate related risk drivers
Risk Type
Transition
Physical
increased PD for companies sensitive to transition
risk factors such as policy, regulatory or market-
driven changes; impact on collateral valuations due
to shifts in asset preferences or devaluation of high-
emission assets)
valuations in real estate portfolios due to e.g., flood
or wildfire)
Market risk
- Volatility and decline in asset values and risk
returns (corporate/sovereign bonds, equities) from
transition risk drivers leading to repricing of
securities and derivatives (e.g. carbon price shocks,
policy tightening, or sectoral reallocation of capital)
- Volatility and decline in asset values and risk
returns from physical risk events leading to
repricing of securities and derivatives
Liquidity risk
o Volatility and reduction in values and risk returns
of financial assets (e.g. corporate/sovereign bonds,
equity) from transition risk events which may
reduce the value of high-quality liquid assets,
thereby affecting the liquidity buffer, due to
transition-driven repricing; potential reduction in
investor appetite; increased funding costs due to
perceived sustainability risk, reduced ability to
access stable sources of funding, to raise funds or
liquidate assets
- Volatility and reduction in values and risk returns of
financial assets (e.g. corporate/sovereign bonds,
equity) from physical risk events which may reduce
the in value of high-quality liquid assets, thereby
affecting the liquidity buffer, due to physical
damage or repricing; potential funding pressure
from counterparties (e.g. deposit and credit lines
drawdowns), reduced ability to access stable
sources of funding, to raise funds or liquidate assets
Operational risk
- Fines or losses due to non-compliance with
environmental standards, greenwashing or failure
to meet disclosure requirements, leading to
conduct risk
- Disruption to operations or critical infrastructure
(branches, data centers, energy supply) due to
physical risk events (e.g. extreme weather events)
Business and Strategic
risk
- Failure to integrate ESG and climate considerations
in business strategy (e.g., potential shift in
consumer preferences, behavioral/ demand
patterns, market sentiment), leading to loss of
competitiveness, misalignment with investor
expectations
- Failure to account for the occurrence of extended
physical risk events impacting financed activities
/sectors more vulnerable to such risks and
consequently the Bank’s business model
Reputational risk
- Negative public perception or investor reaction due
to association with environmentally harmful
activities and/or counterparties or perceived lack of
credible transition strategy, potentially affecting
valuation and stakeholder trust. Continually rising
stakeholder expectations in the area of climate risk
could lead to reputational risk, if the Bank does not
deliver fully on its position
Materiality Assessment Methodology
Current Financial Effect
In order to assess the current financial effect of climate risks, the Bank has evaluated if any material climate-related operational risk losses
(referring to both climate change mitigation and climate change adaptation) have been recognized during the current financial year.
Anticipated Financial Effect – Transition Risk
For financial materiality purposes, Alpha Bank S.A. defines the reference time horizons in alignment with CSRD guidance as described in [BP-2]
‘Disclosures in relation to specific circumstances’. These horizons were chosen to also align with scientific pat hways that limit warming to
1.5°C. This requires halving global GHG emissions by 2030 and approaching zero by 2050. These time horizons are also in line with the Greek
Climate Law that has set a target for net zero by 2050, and an interim target of reducing GHG emissions by 55% in 2030 compared to 1990
emissions.
As a first step, the Bank has recognized the sectors that are sensitive to transition risk (climate change mitigation), by taking into consideration
the following factors:
• Climate Policy Relevant Sectors (CPRS) perimeter,
• Sectors sensitive to transition risk according to Net Zero Banking Alliance (NZBA) and Long-Term Strategy for Greece for 2050 (LTS),
• The emission intensities at sector level and forward-looking Probability of Defaults (PDs) based on the short-term disorderly
transition scenario that ECB published as part of the 2022 ECB climate stress test exercise,
• The contribution of the calculated (or estimated if not applicable) Scope 1 and 2 emissions of each sector in the Bank’s tota l Scope 1
and 2 emissions,
• Exclusion of: i) RES loans, ii) dedicated-purpose sustainable loans that are aligned with EU Taxonomy (and substantially contribute to
Climate Change Mitigation (CCM) objective) and iii) other loans that are sustainable according to the Bank's Sustainable Finance
Framework, provided that they are linked to and affect Climate Change Mitigation (CCM) objective.
In addition to the above, the Bank has conducted a top-down qualitative materiality assessment for transition risk sub-types (market,
technology, reputation, policy and legal) as proposed by the TCFD, in order to identify the climate-related transition risks that materially affect
each sector. Each transition risk sub-type is comprised of risk drivers, such as:
• Policy and legal: policy developments (carbon pricing mechanisms, reporting obligations, policy mandates) that attempt to constrain
actions that contribute to the adverse effects of climate change or policy developments that seek to promote adaptation to climate
change, as well as climate-related litigation claims.
• Market: all shifts in supply and demand for certain commodities, products, and services. Capital markets are well-versed in
identifying and assessing market risks. However, climate change will have unique implications in the supply and demand of certain
commodities, products, and services.
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• Reputation: all risks tied to changing Customer or community perceptions of an organization’s contribution to or detraction f rom the
transition to a lower-carbon economy.
• Technology: all risks associated with technological improvements or innovations that support the transition to a lower-carbon,
energy-efficient economic system. Financial risks may arise if no new investments are made in new technologies that contribute to
climate-related adaptation and risk mitigation.
Following the assessment for transition risk sub-types, a Total Average transition risk score per sector and for all the time horizons was
calculated through the examination of recent literature scenarios, strategic plans and roadmaps. More specifically:
• IEA, 2021, Net Zero by 2050 “A roadmap for the global energy sector”
• Ministry of Energy and Environment, 2023, National Plan for Energy and Climate (Draft version)
• Ministry of Energy and Environment, 2019, National Plan for Energy and Climate
• National Inventory of Greece Report 2023
• UN Environment Program, Sectoral Risk Briefings: Insights for Financial Institutions, 2024
• Ministry of Energy and Environment, 2024, National Plan for Energy and Climate
• UNEP FI – Climate Risks in the Power Generation Sector, 2024
• UNEP FI – Climate Risks in the Metals and Mining Sector, 2024
• UNEP FI – Climate Risks in the Transportation Sector, 2024
• UNEP FI – Climate Risks in the Industrials Sector, 2023
• European Cement Association, 2021
• Science-based decarbonization pathways for the European Aluminium Industry – European Aluminium
• European Commission – Reducing emissions from the shipping sector
This score, representing the combination of impact and likelihood, serves as a proxy for the likelihood of occurrence of the Bank’s anticipated
financial effect component.
Likelihood of occurrence
The Bank has undertaken a qualitative materiality assessment for transition risk sub-types to identify the climate-related transition risks that
materially impact each sector within the transition risk-sensitive perimeter across different time horizons. The scale of the transition risk is
defined by combining the outcome of the Likelihood and the Impact analysis which are performed at sector level:
• Likelihood: the probability of occurrence within a provided time horizon
• Impact analysis: the extent to which the impact, if occurred, would affect the business
Following the assessment for transition risk sub-types, a Total Average transition risk score per sector and for all the time horizons is
calculated. This score is considered as a proxy for the likelihood of occurrence of an anticipated financial effect for the Bank.
Anticipated Magnitude of Financial Effect
In order to evaluate the potential magnitude of financial effects for transition risk, the Bank has calculated the percentage of the Bank’s
exposures lying within the Sensitive perimeter over Total Group Assets categorized under High, Medium and Low likelihood of occurrence
categories across different time horizons.
The following materiality thresholds (that should apply simultaneously) are considered, in order to characterize climate change mitigation risk
as material:
• at least 5% of exposures within the Sensitive perimeter over Group Total Assets under High likelihood of occurrence, and
• at least 10% of exposures within the Sensitive perimeter over Group Total Assets under a combination of High and Medium
likelihood of occurrence.
It is noted that Alpha Bank Cyprus also performs a materiality assessment to evaluate the anticipated financial effects from climate transition
risks, which is taken into consideration to determine the overall materiality of such risks for the Group. The methodology applied is
conceptually aligned with that of Alpha Bank S.A., taking also into account country-related specificities. In particular, Alpha Bank Cyprus
assessed the transition risk impact on its credit risk through the determination of the Wholesale portfolio clients that are allocated in NACE
sectors with high transition risk. For this purpose, the Climate Policy Relevant Sectors (CPRS) approach used by the European Banking
Authority (EBA) was applied. Also, scientific research is used for the identification of the transition risk sub- types that can have a financial
impact on the entity. The process involves a detailed analysis of several risks and their potential impacts on several high transition sectors
within the CPRS framework, marking which combination of risks and impacts are considered relevant. The analysis concluded on 13 individual
risks. The methodology followed, was based on a multi-criteria assessment based on the following:
• Expected Impact: potential effect on the bank if the risk materializes (in short, medium-, and long-term) and
• Likelihood: the likelihood with which a consequence may materialize, and the level of mitigating actions to be taken by the Group to
counter the risk or the availability of time for mitigating actions to be taken (in short-, medium-, and long-term).
Anticipated Financial Effect – Physical risk
As already mentioned in [IRO-1] Descripon of the process to idenfy and assess material impacts, risks and opportunies, the Group performs
a vulnerability assessment (at both sectoral and regional level) to identify potential significant hazards per sector covered by the analysis for
Business portfolio, as well as across the different geographic regions where real estate properties used as collateral are located.
a) Sectoral analysis - Vulnerability analysis of Business Portfolio on Physical climate risk
Sensitivity Analysis
Regarding the sectoral analysis conducted at NACE code level, the sensitivity analysis is focused on the sensitivity of the top subsectors, for the
27 climate hazards.
Table 19 Categorization of Climate hazards
Chronic Climate Risks
Acute Climate Risks
Changing temperature (air, freshwater, marine water)
Heatwaves
Temperature variability
Coldwaves/frost
Heat stress
Wildfire
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Chronic Climate Risks
Acute Climate Risks
Permafrost thawing
Cyclone, hurricane, typhoon
Changing wind patterns
Storm (blizzards, dust, sandstorms)
Changing precipitation patterns and types (rain, hail, snow/ice)
Droughts
Precipitation or hydrological variability
Tornado
Sea level rise
Heavy precipitation (rain, hail, snow/ice)
Water stress
Floods
Saline intrusion
Avalanches
Soil erosion
Landslide
Coastal erosion
Subsidence
Soil degradation
-
Solifluction
-
Ocean acidification
-
The sensitivity is assessed for each sub-sector per climate hazard using a 3-level score of ‘High’, ‘Medium’ or ‘Low’:
• High sensitivity: the climate hazard may have a significant impact
• Medium sensitivity: the climate hazard may have a moderate impact
• Low sensitivity: the climate hazard has no (or an insignificant) impact
The sensitivity has been assessed in three different time-horizons in alignment with the ESRS recommendations. These horizons were selected
both because they reflect scientific pathways and because they are consistent with the Energy and Climate National Plan and the Greek
Climate Law. In addition, the chosen time horizons are aligned with the EBA Guidelines on the management of ESG risks.
Exposure Analysis
The analysis resulted in the assessment of the exposure to future climate risks in country level using the maximum value in the geographic unit
under assessment (country or climate zone) for the three-time horizons (2026, 2030, 2050).
Vulnerability Analysis
The vulnerability analysis is derived by combining the outcome of the sensitivity analysis and the exposure analysis. Based on the
methodology, the vulnerability equals the sensitivity of a sector to a climate hazard times the exposure of that hazard to the location of the
sector. The 3-level scores have been used to assess both the sensitivity and the exposure, which, when combined, form a 9-level score that can
be mapped to a 3-level vulnerability score (High – Medium – Low). The vulnerability assessment outcome is considered as a proxy for the
likelihood of occurrence of an anticipated financial effect for the Bank.
b) Regional analysis - Vulnerability analysis of Real Estate properties on Physical climate risk
It is worth noting that some of the loan exposures of the may be covered by both the approach applied at NACE sector level (covered in
previous section) and the approach described here. The previous approach examines the activity/sector of borrowers and their degree of
vulnerability to physical risk, while this approach examines the vulnerability of real estate property collaterals that may exist and, to that
extent, the potential vulnerability of loan exposures is linked to these collaterals. Therefore, th e drivers or “transmission mechanisms” of
physical risks are different between these two cases.
The analysis developed for all climate physical risks, which are considered the most relevant to affect the structural characteristics of real
estate properties in Greece is based on relevant literature. The selected climate physical risks are:
• Chronic: sea level rise, soil & coastal erosion
• Acute: wildfire, cyclone/ hurricane/ typhoon/ storm/ tornado, floods
To achieve a higher granularity level in the exposure analysis regarding real estate properties portfolio, a location-specific risk analysis has
been conducted, using geospatial mapping and local geographical characteristics based on identified NUTS 3 levels. In this way, the Group can
assess materiality to different hazards in more detail in terms of location of collaterals. The final assessment outcome is presented in terms of
High/Medium/Low exposure levels, using relevant hazard metrics averaged to provide the results resolution of location data of the Group
under the three time horizons (short – 2026 / medium 2030 / long 2050). For each NUTS 3 level region, a comprehensive grid of points is
plotted on the map to ensure detailed coverage of each different prefecture. The physical risk level presented is an average derived from these
specific locations (with averaging over several nearest neighbor grid points), for each NUTS 3 level, ensuring a comprehensive understanding of
risks at a localized level. However, variations from the reported average risk level may occur when compared to the individual grid points
within a NUTS 3 level region.
More specifically, for the estimation of exposure to existing climate conditions, available historical data are used for the specific geographical
regions falling under the scope of the current analysis. For the estimation of exposure to future conditions, climate simulation models and
climate projections were considered for the adverse scenario of evolution of greenhouse gas emissions RCP8.5, with horizons of 2030 and
2050.
RCP8.5 projects the reasonable worst-case scenario and is widely used for climate risk assessment and stress-testing. RCP8.5 was specifically
selected as a high-end baseline scenario and was not intended to be portrayed as the most likely “business as usual” no-policy outcome. It is
important to note that climate variables’ values and impacts will only strongly differ with other scenarios in the long-term (2070-2100), while
being close to others up to 2050. Different time horizons have been defined by means of 30-year or 20-year timeframes following literature
best practices. The assessment of the exposure level provides a detailed analysis of physical climate risks at a corporate level. This is based on
a common clear and defined system for all climate parameters, accepted by the scientific community, that takes into account changes in
climate parameters in different chronological periods and corresponds to percentage changes in corresponding exposure categories.
Climate Analysis
Inputs are composed of experiments under the CORDEX initiative, which combines global and regional climate models with a horizontal spatial
resolution of 11 km. For the current conditions, the timeframe climate (1981-2010) was considered, whereas two different timeframes (2030
and 2050) were used for the analysis of future conditions. For each climate risk, indicators are provided to measure exposure, based on the
climate scenarios of the evolution of GHG gas emissions (RCP 8.5), as determined by the IPCC and the scientific community.
Selection of Climate Indicators
Physical climate risks have been analyzed using the following climate indicators. Where datasets were not available, dynamic maps and
variables were used to estimate the local exposure. An example of this is the sea level rise indicator, for which some locations are not covered.
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In this case, the external source of NASA - IPCC AR
6
Sea Level Projection Tool
17
is used, in order to complete the exposure assessment. For the
flood risk, the retention of the worst-case scenario for either pluvial or fluvial floods in each NUTS 3 region, alternating between the two
indicators each time, is ensured.
Table 20 Climate indicators used for the exposure analysis
Acute
Hazard
Indicator description
Unit
Wildfire
Annual average FFDI for days where FFDI > 10
index
Cyclone, hurricane, typhoon, storm and tornado
Annual maximum of daily wind speed
m/s
Flood (fluvial)
Average fluvial flooding elevation related to a 100-year frequency event
m
Flood (pluvial)
Average pluvial flooding elevation related to a 100-year frequency event
m
Chronic
Sea level rise
Mean local sea level rise compared to the reference period baseline
cm
Soil erosion
Annual average of soil erosion
t/ha/year
Geospatial Mapping & Averaging from Grid Points to NUTS3 Level
Greek territory is divided in four climate zones based on the temperature conditions that prevail in each prefecture. According to the current
building energy efficiency regulation, the country is divided into four climate zones.
Climate data of the RCA4 results were retrieved at a horizontal resolution of ~11 km for the Greek domain. The domain consists of
approximately 75 x 82 grid cells. NUTS 3 level results are an outcome of an aggregated approach, by taking the average of the corresponding
grid-cell points belonging in this NUTS 3.
For each indicator and each point of the grid, the value displayed is computed by averaging the projections of several climate models for a
given combination of {geography x scenario x horizon} and corresponds as such to the “mean” value of the indicator f or the given combination.
The value displayed for each indicator and grid point is computed by averaging the projections specifically for the RCP 8.5 scenario and the
horizons 2030 and 2050. Exposure fields are defined for each combination of indicator, RCP 8.5 scenario, time horizons 2030 and 2050, and
climate type, based on predefined global thresholds derived from scientific literature for assessing exposure levels (low, medium, high).
Regarding the definition of the thresholds, whenever possible, absolute thresholds across all climate types have been derived from recognized
scale as presented in the following table. For instance, flooding thresholds defined are based on World Bank classification, while water stress
thresholds directly derive from WRI classification.
Table 21 Sources for exposure thresholds definition per climate risk
Climate risk
Source
Wildfire
Using alternative soil moisture estimates in the McArthur Forest Fire Danger Index
18
Cyclone, hurricane, typhoon, storm and tornado
Quantifying the Occurrence of Multi-Hazards Due to Climate Change
19
Max value of Flood (fluvial – pluvial)
AMBIENTAL GlobalFloodMap dataset, 30m resolution resampled
20
Sea level rise
NASA - IPCC AR6 Sea Level Projection Tool
21
Global and European sea level rise
22
Soil erosion
European Soil Data Centre (ESDAC)
23
Likelihood of occurrence
Based on the Vulnerability assessment (at both sectoral and regional level) as described above, the vulnerability assessment outcome is
considered as a proxy for the likelihood of occurrence of an anticipated financial effect for the Bank.
Potential Magnitude of Financial Effects
Following the aforementioned vulnerability assessment, the Bank has identified sectors and regions categorized under High, Medium, and Low
Likelihood of Occurrence. Subsequently, the Bank has calculated the percentage of its exposures classified as High, Medium, or Low Likelihood
of Occurrence over the Total Group Assets, considering regional and sectoral analyses over different time horizons.
A materiality threshold has been set, taking into consideration Bank’s 'exposures over Group Total Assets’ lying under High Likelihood of
Occurrence category (set at 10% of the Bank’s 'exposures over Group Total Assets’ under High Likelihood of Occurrence).
Given that multiple physical risks (both chronic and acute) are separately examined and then aggregated, with an averaging effect on the
materiality results overlays are applied to account for the fact some physical risks (e.g., flood) may individually have a high likelihood of
occurrence. This conclusion is further supported by the fact that the materiality assessment incorporates the worst-case outcome for each
physical risk type before averaging across the Acute, Chronic, and both Chronic and Acute buckets. By using the highest-severity result for each
category, the assessment ensures that the potential impact of significant hazards is fully captured, even if other risks dilute the aggregated
outcome.
It is noted that Alpha Bank Cyprus also performs a materiality assessment to evaluate the anticipated financial effects from climate physical
risks, which is taken into consideration to determine the overall materiality of such risks for the Group. The methodology applied is
conceptually aligned with that of Alpha Bank S.A., taking also into account country-related specificities, and includes the following elements:
• Sectoral Analysis: The Bank performs a materiality assessment for physical risks by identifying relevant climate impact categories for
Cyprus using authored resources. Each impact category is then mapped to the sectors expected to be affected. The assessment for
identifying the level of risk is based on: i. Vulnerability: Assessed the likelihood and severity of the impacts associated with the hazards
identified as relevant for Cyprus, ii. Urgency: Assessed the urgency for the bank to take actions and iii. Impact Assessment: Assessed the
exposure of the Bank to each sector.
17
NASA, IPCC AR6 Sea Level Projection Tool
18
Using alternative soil moisture estimates in the McArthur Forest Fire Danger Index, 2017
19
Quantifying the Occurrence of Multi-Hazards Due to Climate Change, 2022
20
Flood Exposure and Poverty in 189 Countries
21
Sea Level Projection Tool, Nasa
22
Global and European sea level rise, 2024
23
Global Soil Erosion
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• Geospatial Analysis: In addition, using geospatial analysis, all collateral properties in Cyprus were assessed for wildfire, flood, landslide
and land subsidence risks. Likelihood and severity were combined under a damage function, to derive the materiality of each risk.
Opportunities
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material opportunities related to climate change mitigation and
climate change adaptation (i.e., EU Taxonomy aligned and other sustainable financings according to the Bank’s Sustainable Finance
Framework) have been recognized during the current financial year. A threshold of circa Euro 1 billion has been set in order to consider an
opportunity as material.
Anticipated Financial Effect
The materiality assessment performed by the Bank indicates that there are material opportunities related to climate change mitigation in the
short-, medium- and long-term. Regarding the short-term horizon the Bank expects increase of the sustainable financings towards climate
change mitigation objective (thus they will continue, exceeding the threshold of circa Euro 1bn) within the Business Plan horizon. Accordingly,
in the medium and long-term horizon the expectation is that this type of financing will continue increasing. Climate change adaptation is
considered a material opportunity only in the long-term horizon. As physical risks are anticipated to intensify over time, financings aimed at
climate change adaptation are expected to grow in the longer term, surpassing the materiality threshold of circa Euro 1 bn. Regarding the
short-term and medium-term horizons the Bank does not expect material opportunities – that exceed the relevant threshold considering also
its Business Plan.
The average maturity of the Bank’s NFC portfolio is approximately five years and therefore the majority of the Bank’s NFC por tfolio (c. 65%)
has a residual maturity equal or below five years, while the average maturity of the Bank’s real estate portfolio i s c. 14 years, with the majority
of the Bank’s real estate portfolio (c. 58%) having a residual maturity between one and 16 years.
Identification of assets and business activities that are incompatible with or need significant efforts to be compatible with a transition to a
climate-neutral economy
The Group does not have any operational or financed locked-in emissions, or any other assets or activities that could jeopardize the
achievement of its net zero target.
Compatibility of climate scenarios with climate-related assumptions made in the financial statements
As part of its financial materiality assessment, Alpha Bank utilizes widely recognized science-based decarbonization scenarios (e.g., IEA NZE)
and other climate scenarios to evaluate the likelihood of transition risks, quantify the anticipated financial effects of climate risk, and derive
the financial materiality outcome. In the context of its decarbonization strategy, Alpha Bank has incorporated decarbonization targets in
specific sectors (Cement, Power generation, Oil and Gas, Iron and Steel), leveraging on the IEA NZE scenario, which is in alignment with the
scenarios utilized for DMA purposes. In addition, the scenarios utilized in the context of the financial materiality assessment of climate physical
risks reflect the resilience analysis performed by the Bank to estimate the impact of climate physical risks, in the context of ICAAP or other
similar processes or one-off exercises. Please refer to [E1-1] “Transition plan for climate change mitigation for more information”.
[E2.IRO-1] Description of the processes to identify and assess material pollution-related impacts, risks and opportunities
Impact
The process followed regarding pollution-related impacts is described in the subsection “Process to identify, assess, prioritize and monitor
impacts informed by due diligence”.
The Impact materiality analysis has not identified any Pollution impact as material to the Group’s downstream activities.
No material impacts to Pollution of water, soil and air have been concluded deriving from the Group’s products/services (down stream value
chain), as the Group’s portfolio did not indicate material association with sectors contributing significantly to poll ution. Furthermore, currently
there is no projection of significant changes to the mix of portfolio indicating a material impact to Pollution for the future time horizons.
Risks
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material pollution-related operational risk losses have been
recognized during the current financial year. For 2025, no pollution-related operational losses have been recognized.
Anticipated Financial Effect
The materiality assessment performed by the Bank for Pollution follows the same methodology with Biodiversity and ecosystems, and is
explicitly described [E4.IRO-1] Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks,
dependencies and opportunities. The results of this assessment are presented in the following table:
Table 22 Anticipated Financial Effect – Risks (Pollution)
Anticipated Financial Effect - Risks
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Pollution
Not material
Not material
Not material
Opportunities
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material pollution-related opportunities have been recognized
during the current financial year. For 2025, no pollution-related opportunities were identified.
Anticipated Financial Effect
The materiality assessment performed by the Bank indicates that there are no material opportunities related to pollution (i.e., sustainable
financings towards pollution prevention and control related activities in line with the Bank’s Sustainable Finance Framework) in the short-
(2026), medium-(2030) and long-term (2050) horizons.
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Table 23 Anticipated Financial Effect – Opportunities (Pollution)
Anticipated Financial Effect - Opportunities
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Pollution
Not material
Not material
Not material
[E3.IRO-1] Description of the processes to identify and assess material water and marine resources-related impacts, risks and
opportunities
Impact
The process followed regarding water and marine resources-related impacts is described in the subsection “Process to identify, assess,
prioritize and monitor impacts informed by due diligence”.
The Impact materiality analysis has not identified any Water and marine resources impact as material to the Group’s downstream activities.
No material impacts to Water and Marine Resources have been concluded deriving from the Group’s products/services (downstream value
chain), as the Group’s portfolio did not indicate material association with sectors contributing significantly to water. Fur thermore, currently
there is no projection of significant changes to the mix of portfolio indicating a material impact to Water and Marine Resources for the future
time horizons.
Risks
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material water and marine resources-related operational risk
losses have been recognized during the current financial year. For 2025, no water and marine resources-related operational losses have been
recognized.
Anticipated Financial Effect
The materiality assessment performed by the Bank for Water and marine resources follows the same methodology as Biodiversity and
ecosystems, which is explicitly described under [E4.IRO-1] ‘Description of processes to identify and assess material biodiversity and ecosystem-
related impacts, risks, dependencies and opportunities’. The results of this assessment are presented in the following table:
Table 24 Anticipated Magnitude of Financial Effect – Risks (Water and Marine Resources)
Anticipated Financial Effect - Risks
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Water and Marine Resources
Not material
Not material
Not material
Opportunities
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material water and marine resources -related opportunities have
been recognized during the current financial year. For 2025, no water and marine resources -related opportunities were identified.
Anticipated Financial Effect
The materiality assessment performed by the Bank indicates that there are no material opportunities related to water and marine resources
(i.e., sustainable financings towards activities related to the sustainable use and protection of water and marine resources are in line with the
Bank’s Sustainable Finance Framework) in the short- (2026), medium-(2030) and long-term (2050) horizons.
Table 25 Anticipated Magnitude of Financial Effect – Opportunities (Water and Marine Resources)
Anticipated Financial Effect - Opportunities
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Water and Marine Resources
Not material
Not material
Not material
[E4.IRO-1] Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks,
dependencies and opportunities
Impacts
The process followed regarding biodiversity and ecosystem-related impacts is described in the subsection “Process to identify, assess,
prioritize and monitor impacts informed by due diligence”.
Impact materiality analysis identified that impact on Habitat was deemed material as a result of the Group’s downstream activ ities. The
following table lists the top 10 sectors (2 digits NACE codes) with the highest negative impacts on Habitats as this derived from Group’s
downstream portfolio analysis:
Table 26 Top 10 sectors with highest negative impacts on Habitats (Biodiversity & ecosystems)
a/a
Sectors
1
50 Water transport
2
35 Electricity, gas, steam and air conditioning supply
3
68 Real estate activities
4
52 Warehousing and support activities for transportation
5
41 Construction of buildings
6
42 Civil engineering
7
24 Manufacture of basic metals
8
51 Air transport
9
01 Crop and animal production, hunting and related service activities
10
46 Wholesale trade, except of motor vehicles and motorcycles
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Impact materiality analysis identified that negative impact on Habitat is material as a result of the Group’s downstream acti vities. No material
impact from own operations was identified, as the Group’s own activity takes place in building stock located in urban environment. For more
information please see subsection “Process to identify, assess, prioritize and monitor impacts informed by due diligence”.
Risks
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material Biodiversity and ecosystems-related operational risk
losses have been recognized during the current financial year.
Anticipated Financial Effects
Impact Analysis
The Bank has utilized the ENCORE Tool to examine the materiality of the anticipated financial effect for nature-related risks.
Based on this tool, the Bank assessed the negative impact of its portfolio per sector for the following pressures: Disturbances (e g noise, light),
Area of freshwater use, Emissions of GHG, Area of seabed use, Emissions of non-GHG air pollutants, Other biotic resource extraction (e g fish,
timber), Other abiotic resource extraction, Emissions of toxic soil and water pollutants, Emissions of nutrient soil and water pollutants,
Generation and release of solid waste, Area of land use, Volume of water use, Introduction of invasive species).
For the purposes of the analysis, ESRS Topics and their scores are subsequently aggregated following a conservative assessment approach (i.e.,
an ESRS topic was assigned a Very High (VH) score if at least one of its associated pressures received a Very High (VH) rating).
Likelihood of Occurrence
For sectors with High (H) or Very High (VH) rating in ENCORE, a risk assessment is performed to estimate the transition risk of the respective
nature-related risks (including Biodiversity & ecosystems), covering short-, medium-, and long-term horizons. The scale of the transition risk is
defined by combining the outcome of the Likelihood and the Impact, which are performed at sector level.
This score is considered as a proxy for the likelihood of occurrence of an anticipated financial effect.
• Likelihood: the probability of occurrence within a provided time horizon
A risk assessment is performed using a literature review, through which each nature-related topic (including Biodiversity and
ecosystems) and each sector is assigned a score (Low, Medium, High) across different time horizons (short-, medium-, long- term)
based on existing and future legislation, regulations, market pressures, technology advancements/innovation, and reputational risks.
These factors may affect the financial performance and credit capabilities of companies in affected sectors that lag in the transition,
posing a risk for the Bank relative to its exposure to these sectors. A three-level scale was adopted:
o Low: There are no specific regulations or policies affecting this sector.
o Medium: There are specific regulations or policies affecting this sector, but there is no defined or pressing time-horizon.
o High: There are strict regulations and/or policies in place, with specific time-horizons.
• Impact: the extent to which the impact, if occurred, would affect nature
To estimate the impact score of the nature-related topics (including Biodiversity and ecosystems), a methodology which leverages
both Exiobase and ReCiPe, is used to quantify commodity-level impacts across each pressure category. The commodities are mapped
to their corresponding NACE level-4 categories, and ReCiPe’s pressure categories are aligned with those of ENCORE. Finally, the
impact score per 1-digit NACE code (Low, Medium, High) is calculated for each ESRS topic (including Biodiversity and ecosystems) by
aggregating the corresponding ENCORE pressures, following a conservative approach.
Anticipated Magnitude of Financial Effects
After identifying the sectors within perimeter with key negative impact and categorizing them under High, Medium, and Low Likelihood of
Occurrence, the Bank calculated the percentage of its exposures classified as High, Medium, or Low Likelihood of Occurrence over the Total
Group Assets, across the different time horizons.
The following materiality thresholds (that should apply simultaneously) are considered, in order to characterize Biodiversity and Ecosystems as
material:
• at least 5% of the exposures in sectors within perimeter with key negative impact per nature-related topic (including Biodiversity)
over the Group Total Assets under the category of high likelihood of occurrence, and
• at least 10% of the exposures in sectors within perimeter with key negative impact per nature-related topic (including Biodiversity)
over the Group Total Assets under the combined amount of high and medium likelihood of occurrence.
Dependency Analysis
The Bank proceeds with the dependency analysis, adhering to EBA’s Consultation paper on Guidelines for managing ESG risks, wh ich states
that “Large institutions should develop methods to identify sectors that are highly dependent on, or have significant im pact on, ecosystem
services.” More specifically, in addition to the previously described Impact analysis, the Bank evaluates the environmental d ependencies of its
business portfolio on natural and ecosystem services.
For this purpose, the bank utilizes the tool, which is designed to also assist with evaluating nature-related risks by providing insights into the
dependencies on natural resources. For each ecosystem service and economic activity combination, literature reviews were conducted using
scientific journals, peer-reviewed papers, key document searches, and grey literature. Industry experts from various economic sectors
reviewed the identified dependency links, resulting in a complete evaluation of which of the 25 ecosystem services are essential for the
production of each of the 271 economic activities. As a result, a materiality rating was assigned for each identified dependency link between
an economic activity and an ecosystem service. When no connection was established, the combination of the economic activity and ecosystem
service was marked either as N/A (Not Applicable) or, in cases of insufficient data, as ND (No Data). The materiality rating varies based on the
following:
• the significance of the loss of functionality in the production process if the ecosystem service is disrupted, and
• the significance of the financial loss due to the loss of functionality in the production process.
In this context the Bank acknowledges the 25 ecosystem services set out in the ENCORE tool and assesses the economic sectors’ potential
dependency on these ecosystem services, by using existing classifications of ecosystem services and economic sectors.
Dependency to an ecosystem service (such as Water purification, Soil quality regulation), is assessed in terms of materiality, by examining the
exposures’ distribution to High and Very High scores. The analysis depicts that a significant percentage of its obligors are dependent on some
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ecosystem services including “Visual Amenity services”, “Recreation-related services”, “Water purification” and “Flood mitigation services”.
Even though material dependencies to ecosystem services do not reflect material risks on their own, the analysis is well aligned to the
materiality conclusions drawn by the Bank, in particular with respect to Physical Climate risk and Biodiversity risks (mentioned in impact
analysis above).
It is noted that Alpha Bank Cyprus also performs a materiality assessment to evaluate the anticipated financial effects from nature-related
risks, which is taken into consideration to determine the overall materiality of such risks for the Group. The methodology applied is
conceptually aligned with that of Alpha Bank S.A., taking also into account country-related specificities. Utilizing datasets from the United
Nations Environment Program (ENCORE), more than 6700 Ecosystem services dependencies of economic activities were considered in the
assessment. The analysis consolidated findings in 21 risks that pose a High or a Very High risk to the industries that the Alpha Bank Cyprus is
exposed to. These risks were then mapped to the equivalent NACE codes of each industry/ies that are relevant to its loan portfolio. The
materiality of the 21 identified risks was assessed using the following criteria:
• Anticipated Financial Effect: The current magnitude of Financial Effect was calculated using the Bank’s portfolio exposure to each
sector,
• Likelihood: The likelihood of a risk occurring was defined utilizing local context and business judgement
• Urgency: The urgency of the risk was defined as High or Very High depending on the classification by the United Nations Environment
Program.
The methodology and the tool utilized for the materiality assessment of biodiversity and ecosystems (ENCORE tool) are inherently systemic,
taking into consideration that it is applied across NACE sectors and nature-related topics. Similarly, the transition risk analysis that is
performed for each nature-related topic and for each sector is also considered systemic, as it incorporates key environmental regulations or
policies which reflect the EU’s commitment to environmental protection and sustainable devel opment.
Opportunities
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material biodiversity and ecosystem related opportunities have
been recognized during the current financial year.
Anticipated Financial Effect
The materiality assessment performed by the Bank indicates that opportunities (i.e., sustainable financings in line with the Bank’s Sustainable
Finance Framework) towards activities related to the protection and restoration of biodiversity and ecosystems activities are considered
material in the long-term (>2030) horizon, since the Bank anticipates such opportunities to exceed the threshold of circa Euro 1 bn. As
transition risk faced by the Bank’s counterparties with regards to biodiversity & ecosystems are anticipated to intensify over time, financings
aimed at this topic are expected to grow in the longer term. Regarding the short- and medium-term horizon the Bank does not expect material
opportunities that exceed the established threshold based, also, on its Business Plan.
[E5.IRO-1] Description of the processes to identify and assess material resource use and circular economy-related impacts,
risks and opportunities
Impacts
The process followed regarding resource use and circular economy-related impacts is described in the subsection “Process to identify, assess,
prioritize and monitor impacts informed by due diligence”.
Impact materiality analysis identified that Resources impact was deemed material as a result of the Group’s downstream activi ties. The
following table lists the top 10 sectors (2 digits NACE codes) with the highest negative impacts on Resources as this derived from Group’s
downstream portfolio analysis:
Table 27 Top 10 Sectors with highest negative impacts on Resource Intensity
a/a
Sectors
1
50 Water Transport
2
35 Electricity, gas, steam and air conditioning supply
3
68 Real estate activities
4
10 Manufacture of food products
5
24 Manufacture of basic metals
6
19 Manufacture of coke and refined petroleum products
7
42 Civil Engineering
8
27 Manufacture of electrical equipment
9
41 Construction of buildings
10
51 Air transport
Impact materiality analysis identified that Resource Intensity impact is material as a result of the Group’s downstream activities. No material
impact to Resource Intensity from own operations was identified, as the Group’s own activity is not resource int ensive. No material impact to
resource sourcing in the upstream value chain was identified either, due to the lower overall materiality of the upstream segment for the
banking sector (compared to downstream). For more information please see subsection “Pro cess to identify, assess, prioritize and monitor
impacts informed by due diligence.
Risks
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material circular economy-related operational risk losses have
been recognized during the current financial year.
Anticipated Financial Effect
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The materiality assessment performed by the Bank for Circular economy follows the same methodology with biodiversity and ecosystems
explicitly described under [E4.IRO-1] Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks,
dependencies and opportunities. The results of this assessment are presented in the following table:
Table 28 Anticipated Financial Effect – Risks (Circular Economy)
Anticipated Financial Effect - Risks
Short-Term (2026)
Medium-Term (2030)
Long-Term (2050)
Circular Economy
Not material
Not material
Not material
Opportunities
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material opportunities related to circular economy have been
identified during the current financial year. For 2025, no material circular economy-related opportunities were identified, since they do not
exceed the threshold of Euro 1 billion that has been set.
Anticipated Financial Effect
The materiality assessment performed indicates that opportunities related to circular economy (i.e., material sustainable financings towards
transition to circular economy related activities) are considered material in the long-term (>2030) horizon, while for the short- and medium-
term horizon the Bank does not expect material opportunities based, also, on its business plan.
[G1.IRO-1] Description of the processes to identify and assess material business conduct-related impacts, risks and
opportunities
Impacts
The process followed regarding business conduct-related impacts is described in the subsection “Process to identify, assess, prioritize and
monitor impacts informed by due diligence”.
Risks
Current Financial Effect
In order to assess the current financial effect, the Bank has evaluated if any material business conduct-related operational risk losses have
been recognized during the current financial year.
Anticipated Financial Effect
To evaluate the anticipated financial effect of business conduct related risks, the Bank conducted a mapping of the respective ESRS sub-topics
with the risk types identified within the Compliance Risk Assessment and the corresponding inherent risk assessment outcomes. A four-level
scale (Low, Medium Low, Medium High, High) is utilized in the context of the Compliance Risk Assessment. The following dimensions are
considered to derive the inherent risk assessment outcome:
• Impact: the potential effect on the entity’s objectives should the risk be manifested (Magnitude of financial effects).
• Likelihood: the possibility that the risk will manifest over a pre-defined period of time (Likelihood of occurrence).
ESRS sub-sub-topics that are assessed as having a High or Medium High inherent risk are deemed material. It is noted that the inherent risk
assessment considers which is the impact for the Bank in case the risk is manifested within the next year (short-term) without additional
mitigation actions going forward. It is assumed that the same conclusions are, also, applicable in the medium- and long-term horizons.
[IRO-2] Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement
Table 29 Table of all the datapoints deriving from other EU legislation
Disclosure Requirement and
related datapoint
SFDR Reference
Pillar 3 Reference
Benchmark Regulation
reference
EU Climate Law
Reference
Location in the
sustainability
statement/ Not
Material
ESRS 2 GOV-1
Board's gender diversity
paragraph 21 (d)
Indicator number 13 of
Table #1 of Annex 1
Commission Delegated
Regulation (EU)
2020/1816 ( 27 ) , Annex
II
[GOV-1] The role of the
administrative,
management and
supervisory bodies
ESRS 2 GOV-1
Percentage of board members
who are independent
paragraph 21 (e)
Delegated Regulation
(EU) 2020/1816, Annex
II
[GOV-1] The role of the
administrative,
management and
supervisory bodies
ESRS 2 GOV-4
Statement on due diligence
paragraph 30
Indicator number 10
Table #3 of Annex 1
[GOV-4] Statement on
due diligence
ESRS 2 SBM-1
Involvement in activities
related to fossil fuel activities
paragraph 40 (d) i
Indicators number 4
Table #1 of Annex 1
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
( 28 ) Table 1: Qualitative
information on
Environmental risk and
Table 2: Qualitative
information on Social risk
Delegated Regulation
(EU) 2020/1816, Annex
II
[SBM-1] Strategy,
business model and
value chain
ESRS 2 SBM-1
Involvement in activities
related to chemical production
paragraph 40 (d) ii
Indicator number 9
Table #2 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex
II
[SBM-1] Strategy,
business model and
value chain
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ESRS 2 SBM-1
Involvement in activities
related to controversial
weapons paragraph 40 (d) iii
Indicator number 14
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1818 ( 29 ) ,
Article 12(1) Delegated
Regulation (EU)
2020/1816, Annex II
[SBM-1] Strategy,
business model and
value chain
ESRS 2 SBM-1
Involvement in activities
related to cultivation and
production of tobacco
paragraph 40 (d) iv
Delegated Regulation
(EU) 2020/1818, Article
12(1) Delegated
Regulation (EU)
2020/1816, Annex II
[SBM-1] Strategy,
business model and
value chain
ESRS E1-1
Transition plan to reach climate
neutrality by 2050 paragraph
14
Regulation (EU)
2021/1119, Article 2(1)
[E1-1] Transition plan for
climate change
mitigation
ESRS E1-1
Undertakings excluded from
Paris-aligned Benchmarks
paragraph 16 (g)
Article 449a
Regulation (EU) No
575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template
1: Banking book-Climate
Change transition risk:
Credit quality of exposures
by sector, emissions and
residual maturity
Delegated Regulation
(EU) 2020/1818,
Article12.1 (d) to (g),
and Article 12.2
[E1-1] Transition plan for
climate change
mitigation
ESRS E1-4
GHG emission reduction
targets paragraph 34
Indicator number 4
Table #2 of Annex 1
Article 449a
Regulation (EU) No
575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template
3: Banking book – Climate
change transition risk:
alignment metrics
Delegated Regulation
(EU) 2020/1818, Article
6
[E1-4] Targets related to
climate change
mitigation and
adaptation
ESRS E1-5
Energy consumption from fossil
sources disaggregated by
sources (only high climate
impact sectors) paragraph 38
Indicator number 5
Table #1 and Indicator n.
5 Table #2 of Annex 1
[E1-5] Energy
consumption and mix
ESRS E1-5 Energy consumption
and mix paragraph 37
Indicator number 5
Table #1 of Annex 1
[E1-5] Energy
consumption and mix
ESRS E1-5
Energy intensity associated
with activities in high climate
impact sectors paragraphs 40
to 43
Indicator number 6
Table #1 of Annex 1
[E1-5] Energy
consumption and mix
ESRS E1-6
Gross Scope 1, 2, 3 and Total
GHG emissions paragraph 44
Indicators number 1 and
2 Table #1 of Annex 1
Article 449a; Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 1: Banking book –
Climate change transition
risk: Credit quality of
exposures by sector,
emissions and residual
maturity
Delegated Regulation
(EU) 2020/1818, Article
5(1), 6 and 8(1)
[E1-6] Gross Scopes 1, 2,
3 and Total GHG
emissions
ESRS E1-6
Gross GHG emissions intensity
paragraphs 53 to 55
Indicators number 3
Table #1 of Annex 1
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 3: Banking book –
Climate change transition
risk: alignment metrics
Delegated Regulation
(EU) 2020/1818, Article
8(1)
[E1-6] Gross Scopes 1, 2,
3 and Total GHG
emissions
ESRS E1-7
GHG removals and carbon
credits paragraph 56
Regulation (EU)
2021/1119, Article 2(1)
Not material
ESRS E1-9
Exposure of the benchmark
portfolio to climate-related
physical risks paragraph 66
Delegated Regulation
(EU) 2020/1818, Annex
II Delegated Regulation
(EU) 2020/1816, Annex
II
N/A (Utilization of the
Phase-In provision)
ESRS E1-9
Disaggregation of monetary
amounts by acute and chronic
physical risk paragraph 66 (a)
ESRS E1-9
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
paragraphs 46 and 47;
Template 5: Banking book -
N/A (Utilization of the
Phase-In provision)
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Location of significant assets at
material physical risk
paragraph 66 (c).
Climate change physical
risk: Exposures subject to
physical risk.
ESRS E1-9 Breakdown of the
carrying value of its real estate
assets by energy-efficiency
classes paragraph 67 (c).
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
paragraph 34; Template
2:Banking book -Climate
change transition risk:
Loans collateralized by
immovable property -
Energy efficiency of the
collateral
[E1-9] Anticipated
financial effects from
material physical and
transition risks and
potential climate-
related opportunities
ESRS E1-9
Degree of exposure of the
portfolio to climate- related
opportunities paragraph 69
Delegated Regulation
(EU) 2020/1818, Annex
II
N/A (Utilization of the
Phase-In provision)
ESRS E2-4
Amount of each pollutant listed
in Annex II of the E-PRTR
Regulation (European Pollutant
Release and Transfer Register)
emitted to air, water and soil,
paragraph 28
Indicator number 8
Table #1 of Annex 1
Indicator number 2
Table #2 of Annex 1
Indicator number 1
Table #2 of Annex 1
Indicator number 3
Table #2 of Annex 1
Not material
ESRS E3-1
Water and marine resources
paragraph 9
Indicator number 7
Table #2 of Annex 1
Not material
ESRS E3-1
Dedicated policy paragraph 13
Indicator number 8
Table 2 of Annex 1
Not material
ESRS E3-1
Sustainable oceans and seas
paragraph 14
Indicator number 12
Table #2 of Annex 1
Not material
ESRS E3-4
Total water recycled and
reused paragraph 28 (c)
Indicator number 6.2
Table #2 of Annex 1
Not material
ESRS E3-4
Total water consumption in
m 3 per net revenue on own
operations paragraph 29
Indicator number 6.1
Table #2 of Annex 1
Not material
ESRS 2- SBM-3 - E4 paragraph
16 (a) i
Indicator number 7
Table #1 of Annex 1
[SBM-3] Material
impacts, risks and
opportunities and their
interaction with strategy
and business model
ESRS 2- SBM-3 - E4 paragraph
16 (b)
Indicator number 10
Table #2 of Annex 1
[SBM-3] Material
impacts, risks and
opportunities and their
interaction with strategy
and business model
ESRS 2- SBM 3 - E4 paragraph
16 (c)
Indicator number 14
Table #2 of Annex 1
[SBM-3] Material
impacts, risks and
opportunities and their
interaction with strategy
and business model
ESRS E4-2
Sustainable land / agriculture
practices or policies paragraph
24 (b)
Indicator number 11
Table #2 of Annex 1
[E4-2] Policies related to
biodiversity and
ecosystems
ESRS E4-2
Sustainable oceans / seas
practices or policies paragraph
24 (c)
Indicator number 12
Table #2 of Annex 1
[E4-2] Policies related to
biodiversity and
ecosystems
ESRS E4-2
Policies to address
deforestation paragraph 24 (d)
Indicator number 15
Table #2 of Annex 1
[E4-2] Policies related to
biodiversity and
ecosystems
ESRS E5-5
Non-recycled waste paragraph
37 (d)
Indicator number 13
Table #2 of Annex 1
Not material
ESRS E5-5
Indicator number 9
Table #1 of Annex 1
Not material
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Hazardous waste and
radioactive waste paragraph 39
ESRS 2- SBM-3 - S1
Risk of incidents of forced labor
paragraph 14 (f)
Indicator number 13
Table #3 of Annex I
[SBM-3] Material
impacts, risks and
opportunities and their
interaction with strategy
and business model
ESRS 2- SBM-3 - S1
Risk of incidents of child labor
paragraph 14 (g)
Indicator number 12
Table #3 of Annex I
[SBM-3] Material
impacts, risks and
opportunities and their
interaction with strategy
and business model
ESRS S1-1
Human rights policy
commitments paragraph 20
Indicator number 9
Table #3 and Indicator
number 11 Table #1 of
Annex I
[S1-1] Policies related to
own workforce
ESRS S1-1
Due diligence policies on issues
addressed by the fundamental
International Labor
Organisation Conventions 1 to
8, paragraph 21
Delegated Regulation
(EU) 2020/1816, Annex
II
[S1-1] Policies related to
own workforce
ESRS S1-1
processes and measures for
preventing trafficking in human
beings paragraph 22
Indicator number 11
Table #3 of Annex I
[S1-1] Policies related to
own workforce
ESRS S1-1
workplace accident prevention
policy or management system
paragraph 23
Indicator number 1
Table #3 of Annex I
[S1-1] Policies related to
own workforce
ESRS S1-3
grievance/complaints handling
mechanisms paragraph 32 (c)
Indicator number 5
Table #3 of Annex I
[S1-3] Processes to
remediate negative
impacts and channels
for own workforce to
raise concerns
ESRS S1-14
Number of fatalities and
number and rate of work-
related accidents paragraph 88
(b) and (c)
Indicator number 2
Table #3 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex
II
[S1-14] – Health and
Safety Management
System
ESRS S1-14
Number of days lost to injuries,
accidents, fatalities or illness
paragraph 88 (e)
Indicator number 3
Table #3 of Annex I
[S1-14] – Health and
Safety Management
System
ESRS S1-16
Unadjusted gender pay gap
paragraph 97 (a)
Indicator number 12
Table #1 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex
II
Not material
ESRS S1-16
Excessive CEO pay ratio
paragraph 97 (b)
Indicator number 8
Table #3 of Annex I
Not material
ESRS S1-17
Incidents of discrimination
paragraph 103 (a)
Indicator number 7
Table #3 of Annex I
[S1-17] Incidents,
complaints and severe
human rights impacts
ESRS S1-17 Non-respect of
UNGPs on Business and Human
Rights and OECD Guidelines
paragraph 104 (a)
Indicator number 10
Table #1 and Indicator n.
14 Table #3 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex
II Delegated Regulation
(EU) 2020/1818 Art 12
(1)
[S1-17] Incidents,
complaints and severe
human rights impacts
ESRS 2- SBM-3 – S2
Significant risk of child labor or
forced labor in the value chain
paragraph 11 (b)
Indicators number 12
and n. 13 Table #3 of
Annex I
Not material
ESRS S2-1
Human rights policy
commitments paragraph 17
Indicator number 9
Table #3 and Indicator
n. 11 Table #1 of Annex
1
Not material
ESRS S2-1 Policies related to
value chain workers paragraph
18
Indicator number 11 and
n. 4 Table #3 of Annex 1
Not material
ESRS S2-1 Policies related to
value chain workers paragraph
18
Indicator number 11 and
n. 4 Table #3 of Annex 1
Not material
ESRS S2-1 Non-respect of
UNGPs on Business and Human
Indicator number 10
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Not material
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
79 | ANNUAL FINANCIAL REPORT
Rights principles and OECD
guidelines paragraph 19
Regulation
(EU) 2020/1818, Art 12
(1)
ESRS S2-1
Due diligence policies on issues
addressed by the fundamental
International Labor
Organisation Conventions 1 to
8, paragraph 19
Delegated Regulation
(EU) 2020/1816,
Annex II
Not material
ESRS S2-4
Human rights issues and
incidents connected to its
upstream and downstream
value chain paragraph 36
Indicator number 14
Table #3 of Annex 1
Not material
ESRS S3-1
Human rights policy
commitments paragraph 16
Indicator number 9
Table #3 of Annex 1 and
Indicator number 11
Table #1 of Annex 1
Not material
ESRS S3-1
non-respect of UNGPs on
Business and Human Rights,
ILO principles or OECD
guidelines paragraph 17
Indicator number 10
Table #1 Annex 1
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation
(EU) 2020/1818, Art 12
(1)
Not material
ESRS S3-4
Human rights issues and
incidents paragraph 36
Indicator number 14
Table #3 of Annex 1
Not material
ESRS S4-1 Policies related to
Customers paragraph 16
Indicator number 9
Table #3 and Indicator
number 11 Table #1 of
Annex 1
[S4-1] Policies related to
Customers
ESRS S4-1
Non-respect of UNGPs on
Business and Human Rights
and OECD guidelines paragraph
17
Indicator number 10
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex
II Delegated Regulation
(EU) 2020/1818, Art 12
(1)
[S4-1] Policies related to
Customers
ESRS S4-4
Human rights issues and
incidents paragraph 35
Indicator number 14
Table #3 of Annex 1
[S4-4] Taking action on
material impacts on
consumers and end-
users, and approaches
to managing material
risks and pursuing
material opportunities
related to consumers
and end-users, and
effectiveness of those
actions
ESRS G1-1
United Nations Convention
against Corruption paragraph
10 (b)
Indicator number 15
Table #3 of Annex 1
[G1-1] Business conduct
policies and corporate
culture
ESRS G1-1
Protection of whistle- blowers
paragraph 10 (d)
Indicator number 6
Table #3 of Annex 1
[G1-1] Business conduct
policies and corporate
culture
ESRS G1-4
Fines for violation of anti-
corruption and anti-bribery
laws paragraph 24 (a)
Indicator number 17
Table #3 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex
II)
[G1-4] Incidents of
corruption or bribery
ESRS G1-4
Standards of anti- corruption
and anti- bribery paragraph 24
(b)
Indicator number 16
Table #3 of Annex 1
[G1-4] Incidents of
corruption or bribery
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80 | ANNUAL FINANCIAL REPORT
ENVIRONMENTAL INFORMATION
EU TAXONOMY
Disclosures pursuant to Article 8 of Regulation 2020/852 (“EU Taxonomy Regulation”)
EU Taxonomy Regulation was created to meet the need for a common system for the classification of environmentally sustainable economic
activities. It forms an integral part of the European Green Deal, as well as of the EU Action Plan on Sustainable Finance.
The EU Taxonomy Regulation is effective since July 12th, 2020, and establishes the following six environmental objectives:
1. Climate change mitigation (CCM);
2. Climate change adaptation (CCA);
3. Sustainable use and protection of water and marine resources;
4. Transition to a circular economy;
5. Pollution prevention and control; and
6. Protection and restoration of biodiversity and ecosystems.
On June 4
th
, 2021, Commission Delegated Regulation 2021/2139 (commonly known as the "Climate Delegated Act") was adopted, establishing
the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to
climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any
of the other environmental objectives. The Climate Delegated act is effective as from January 1st, 2022.
Additionally, the EU Commission adopted Delegated Regulation (EU) 2021/2178 of 6 July 2021 (hereinafter "Disclosures Delegated Act"), which
supplements Article 8 of the EU Taxonomy Regulation and outlines the required content and format for information disclosure by companies
under Articles 19a or 29a of Directive 2013/34/EU. It also details the methodology for fulfilling the disclosure requirements related to
environmentally sustainable economic activities.
On July 15
th
, 2022, a Complementary Climate Delegated Act (EU) 2022/1214 was published in the Official Journal of the EU, expanding the
Taxonomy framework to include specific nuclear and gas energy activities under strict conditions (hereinafter “Complementary Climate
Delegated Act”).
In 2023, two new Delegated Acts issued by the European Commission were adopted:
1. The Delegated Act 2023/2485 which includes technical screening criteria of new activities for the substantial contribution to the first
two environmental objectives (CCM and CCA), and
2. The Delegated Act 2023/2486 which includes technical screening criteria of new activities for the substantial contribution to the
remaining four environmental objectives.
According to the EU Taxonomy Regulation, an economic activity is considered “eligible” if it is included in the abovementioned Delegated Acts,
while it is considered “sustainable” or “EU Taxonomy aligned” when it complies with all the following criteria: i) it contributes substantially to
one or more of the environmental objectives described above; ii) does not significantly harm (DNSH) any of these environmental objectives; iii)
it is carried out in compliance with the minimum safeguards.
On January 8
th
, 2026, Commission Delegated Regulation (EU) 2026/73 of 4 July 2025 (hereinafter “Delegated Regulation (EU) 2026/73”), was
published in the Official Journal of the European Union, amending the Disclosures Delegated Act as regards the simplification of the content
and presentation of information to be disclosed concerning environmentally sustainable activities and the Climate Delegated Act and
Delegated Regulation (EU) 2023/2486 as regards simplification of certain technical screening criteria for determining whether economic
activities cause no significant harm to environmental objectives. Delegated Regulation (EU) 2026/73 aims to reduce administrative burdens
and to simplify reporting obligations. According to paragraph 23 of the Delegated Regulation (EU) 2026/73, undertakings can apply the
Disclosures Delegated Act, Climate Delegated Act, and Delegated Regulation (EU) 2023/2486 as applicable on 31 December 2025 for the
financial year of 2025, to avoid undue costs of compliance with the amendments laid down in the Regulation. Therefore, for the financial year
of 2025, the Group has prepared its EU Taxonomy disclosures in accordance with the EU Taxonomy disclosure requirements applicable as of 31
December 2025, prior to the application of the simplified disclosure framework introduced by the Delegated Regulation (EU) 2026/73.
It is also noted that, in accordance with Article 10(5) of the Disclosures Delegated Act, as amended by Article 1(8) of the Delegated Regulation
(EU) 2026/73, the application of the reporting requirements related to the Fees and Commissions income KPI (Section 1.2.3 of Annex V) and
the Trading Book KPI (Section 1.2.4 of Annex V) has been postponed until 1 January 2028. Accordingly, these KPIs are not required to be
disclosed for the 2025 financial year.
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81 | ANNUAL FINANCIAL REPORT
Table 30 Summary of KPIs to be disclosed by credit institutions under Article 8 of the EU Taxonomy Regulation
The table below provides an overview of the key EU Taxonomy-related ratios as of 31.12.2025, while Appendix “EU Taxonomy Reporting
Templates” includes the relevant disclosure templates, as per the EU taxonomy disclosure requirements.
Total
environmentally
sustainable assets
(Turnover)
Total
environmentally
sustainable assets
(CapEx)
Turnover KPI
***
CapEx
KPI ****
% coverage
(over total
assets) **
% of assets
excluded from
the numerator of
the GAR (Arcle
7(2) and (3) and
Secon 1.1.2. of
Annex V)
% of assets
excluded from the
denominator of
the GAR (Arcle
7(1) and Secon
1.2.4 of Annex V)
Main KPI
Green asset
rao (GAR)
stock
1,247
1,778
2.13%
3.04%
76.77%
49.45%
23.23%
Total
environmentally
sustainable assets
(Turnover)
Total
environmentally
sustainable assets
(CapEx)
Turnover KPI
CapEx
KPI
% coverage
(over total
assets)
% of assets
excluded from
the numerator of
the GAR (Arcle
7(2) and (3) and
Secon 1.1.2. of
Annex V)
% of assets
excluded from the
denominator of
the GAR (Arcle
7(1) and Secon
1.2.4 of Annex V)
Addional
KPIs
GAR (ow)
365
657
9.27%
16.66%
Trading book*
N/A
N/A
N/A
N/A
Financial
guarantees
243
518
9.98%
21%
Assets under
management
361
819
2.23%
5%
Fees and
commissions
income*
N/A
N/A
N/A
N/A
* Fees and commissions income from services and Trading Book KPIs
** % of assets covered by the KPI over Groups´ total assets
*** based on the Turnover KPI of the counterparty
**** based on the CapEx KPI of the counterparty, except for lending acvies where for general lending Turnover KPI is used
Implementation in business strategy and engagement with clients and counterparties
The Group seeks to increase its positive effect on society and the environment, utilizing new business opportunities and generating value for
all stakeholders. Through its Sustainable Finance Framework (SFF), the Group supports lending activities as well as other funding instruments
with clear environmental and social credentials in alignment with the EU Taxonomy regulation and with the principles established by the
International Capital Market Association.
Approach for Taxonomy eligibility and alignment assessment
The information presented follows the requirements described in Article 7 and Article 10 of the Disclosures Delegated Act. The information
relating to Taxonomy is prepared following the prudential approach and consolidation of Alpha Bank Group, in accordance with the applicable
laws.
The taxonomy eligibility assessment shows the proportion of the Group’s assets financed and invested in taxonomy - eligible economic
activities as a proportion of total covered assets. The taxonomy alignment assessment, and specifically the GAR ratio, shows the proportion of
the Group’s assets financed and invested in taxonomy - aligned economic activities as a proportion of total covered assets. The numerator
covers the loans and advances, debt securities, equities and repossessed collaterals, financing taxonomy - aligned economic activities based on
the relevant turnover and CapEx KPIs.
The following categories of exposures have been excluded from the calculation of the GAR ratio as necessary:
• exposures to central governments, central banks, and supranational issuers (excluded from both the numerator and denominator of
KPIs);
• exposure in trading portfolio securities (excluded from both the numerator and denominator of KPIs);
• exposures in derivatives excluded from the numerator of KPIs;
• exposures to entities that are not obliged to publish sustainability information pursuant to Article 19a or Article 29a of Directive (EU)
2013/34 excluded from the numerator of KPIs;
• On demand interbank loans excluded from the numerator of KPIs;
• Cash and cash-related assets excluded from the numerator of KPIs;
• Other categories of assets (e.g. Goodwill, commodities etc.) excluded from the numerator of KPIs;
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
82 | ANNUAL FINANCIAL REPORT
For its wholesale banking portfolio, for financings with unknown use of proceeds, the assessment of Taxonomy eligibility and alignment is
performed using the Taxonomy KPIs disclosed by CSRD counterparties - in terms of turnover and capital expenditure - as reported in their
latest annual reports. The counterparties that are not in scope of CSRD, and hence not required to report Taxonomy information, are not
included in the assessment for taxonomy-eligibility and alignment.
For dedicated purpose financing, which is defined as exposures that have the purpose of financing specific identified activit ies, (‘known use of
proceeds’), alignment with the EU Taxonomy is assessed on the basis of the financed activity.
KPIs for off-balance sheet exposures include financial guarantees granted by the credit institution to financial and non-financial undertakings
(FinGuar KPI) and assets under management (AuM KPI).
According to Complementary Climate Delegated Act (ANNEX XII), credit institutions shall disclose their exposure to economic activities related
to fossil gas and nuclear energy. Exposures relevant to taxonomy-aligned economic activities of nuclear energy and fossil gas are included in
the numerator and denominator of their KPIs, and exposures relevant to taxonomy-non-eligible nuclear energy and fossil gas related activities
are included in the denominator of their KPIs.
In view of the CSRD requirements and the continuous amendments on Taxonomy regulation, the Group closely monitors all relevan t
announcements to ensure transparency and completeness of the information.
Limitations in data and information
The adoption of the EU Taxonomy framework is subject to several practical constraints and considerations that influence the calculation and
interpretation of the GAR. More specifically:
• Due to the publication timelines of disclosures by reporting entities, the GAR is calculated using counterparties’ eligibility and
alignment ratios as of 2024, as these represent the most recent data available.
• A limited perimeter of the Group’s portfolio is considered in the calculation of GAR. This is largely attributable to the str ucture of the
Greek market, which includes many unlisted and SME companies outside the scope of CSRD.
• In relation to mortgage lending to households, the assessment of technical screening criteria is also constrained due to the lack of
complete datapoints for the Energy Performance Certificate (EPC) labels of collaterals. At present, no publicly accessible central
registry exists that provides energy-performance information (such as Energy Class ratings) for certified properties.
• For dedicated-purpose financing, obtaining sufficient documentation to substantiate alignment (e.g., Substantial Contribution
Criteria (SCC), Do No Significant Harm (DNSH), and minimum safeguards) remains challenging. For example, in the case of motor
vehicle loans, the assessment of DNSH criteria was not possible due to unavailability of relevant data (i.e. tires of the motor vehicle
etc).
The Group will continue to enhance its reporting methodology over EU taxonomy requirements to ensure transparency and completeness of
the information disclosed as further robust information becomes available from counterparties.
ESRS E1 CLIMATE CHANGE
[E1-1] Transition plan for climate change mitigation
Alpha Bank has developed a comprehensive Transition Plan that aligns with EU climate corporate disclosure regulations (CSRD, ESRS E1 Climate
Change) and prudential requirements (EBA Guidelines on the management of ESG Risks), integrating climate and environmental considerations
across strategy, governance, risk management, and portfolio steering.
The Bank’s Transition Plan is structured around four key themes:
(1) Strategic Foundations & Objectives
(2) Implementation Strategy
(3) Monitoring, Metrics & Reporting
(4) Governance
The Transition Plan provides a structured and credible, forward-looking approach for addressing ESG financial risks and climate change mitigation
aligned with Paris Agreement, while maintaining prudence in risk management and supporting clients in the transition to a more sustainable
economy.
Strategic Foundations & Objectives
Long-term Commitment
Alpha Bank Group has adopted a Strategy for Sustainable Development, which aims to mitigate material negative impacts arising from its
operations, while enhancing its positive impacts, on the environment, society and the economy, as well as ensuring best practice Corporate
Governance.
This Strategy is designed to guide the transition toward a low-carbon, resilient, and sustainable future. It reflects the Group’s commitment to
align with international objectives set by the Paris Agreement on Climate Change and the United Nations 2030 Agenda for Sustainable
Development and supports the broader economy through responsible financing practices. It aims to strengthen financial stability, meet
regulatory expectations, and create long-term value for stakeholders including investors, Employees, clients, while ensuring responsible business
conduct.
Strategic objectives in supporting an environmentally sustainable economy:
• Enable client and economy-wide decarbonization through targeted financing, advisory services, and strategic partnerships.
• Align portfolio emissions with Paris Agreement objectives and credible Net Zero pathways.
• Promote biodiversity protection and circular economy principles across banking activities and financed projects.
• Achieve Net Zero in own operations while enhancing resilience to transition and physical climate risks.
As a result, the Group is expected to strengthen long-term balance sheet quality and financial stability under evolving risk scenarios, while
ensuring compliance with EU sustainability and supervisory requirements.
As a financial institution, Alpha Bank recognizes the opportunity to help steer financial flows toward the transition to a low‑carbon economy.
Mainly, to enhance the Bank’s resilience by managing and mitigating Climate/ESG risks and to support our clients’ investment needs. The key
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
83 | ANNUAL FINANCIAL REPORT
instrument to address the strategic objectives related to the Bank’s lending and investment portfolio is the introduction of net zero targets (2050
and 2030 interim) and risk appetite metrics to control the exposure in sensitive to transition sectors.
In line with the EU Climate Law, the Bank is committed to achieving net-zero greenhouse gas emissions across its lending and investment
portfolio by 2050 and has set interim 2030 climate targets. The targets take into account the UNEP FI’s guidelines and the Net Zero Banking
Alliance (NZBA) target setting framework. This commitment anchors the Bank’s long-term strategy and informs its approach to portfolio steering,
client engagement, and risk management.
Interim Targets and Target-Setting Approach
In 2024, the Bank introduced its first wave of intermediate decarbonization targets for four carbon-intensive sectors — Power Generation, Oil
& Gas, Cement, and Iron & Steel — which collectively account for more than half of the Bank’s total financed emissions. After accounting for
the appropriate value chain, these sectors correspond to ~15% and ~54% of the Bank’s outstanding exposure and financed emissi ons (excluding
shipping), respectively, of the sectors in scope for the NZBA. These targets follow NZBA requirements and are grounded in PCAF-compliant
emissions baselines.
The Bank recognizes that there is a significant amount of uncertainty and complexity associated with the net zero transition. Progress towards
net zero in Greece will depend on the policy landscape, the scale and pace of technological developments, economic and geopolitical factors. In
addition, climate data, scenarios and methodologies continue to evolve, which may require the Bank to evolve its methodology and target setting
approach over time.
In this context, the Bank recognizes that the targets rely to a great extent on Alpha Bank’s key clients meeting their decarb onization
commitments. The Bank will regularly engage with its clients on their level of progress and commitments. While changes in the operating and
macroeconomic environment (for example, prevailing macroeconomic conditions or systemic events) may adversely impact progress towards
the target, the Bank has not identified material locked-in emissions that would prevent achievement of its Net Zero targets, based on current
portfolio composition and available data. Alpha Bank is following NZBA guidelines and recommendations to make progress in defining
decarbonization targets and achieving net zero emissions by 2050.
A second wave of sectoral Net Zero targets is expected to be finalized by H1 2026, depending on regulatory and methodological developments.
The Bank is developing an internal process for both lending and investment portfolios, effectively enhancing the client assessment for net zero
target alignment and integrating the net zero target information to the credit decision making process. The net zero targets are expected to be
incorporated in new client onboarding and existing client review for in scope sector financing.
Purpose of the Transition Plan
The Transition Plan describes the operationalization of the Group’s sustainability strategy, by defining the actions, tools, and decision frameworks
that will enable the portfolio to align with a 1.5°C pathway. It links Alpha Bank’s climate ambitions to it s core business activities, including:
• Enhancing the sustainability and resilience of the bank’s asset portfolio
• Increasing volumes of Sustainable financings to support the economy’s low carbon transition
• Addressing the needs of clients and engaging with them on sustainability related issues
• Incorporating sustainability criteria in Risk Assessment and credit under-writing
• Enhancing the skills and capabilities of the Bank’s Business Units to identify climate related risks and opportunities
• Creating appropriate structures and processes for the integration of future sustainability-related themes
Decarbonization Levers
Sustainable Finance Expansion
As part of the commitment to support the transition to a more sustainable economy, the Group has committed to:
• Allocate Euro 3.8 billion to new Sustainable Financings in 2025-2027
• Within the Sustainable Financings, achieve at least Euro 2.6 billion to Renewable Energy Systems by 2026.
Alpha Bank developed its Sustainable Finance Framework (the Framework or SFF) which defines in detail the criteria and processes to classify
loans and specific financial products and services as sustainable. Green eligible categories are grouped into five distinct themes: Energy
efficiency, green buildings, renewable energy, sustainable transport, resource efficiency and pollution control. Social eligible categories target
activities that positively impact socioeconomically disadvantaged population through economic inclusion, affordable basic infrastructure,
access to essential services and affordable housing. Please refer to [E2-Policies] for the detailed Sustainable Finance Framework description.
The Bank has developed an internal mechanism to assess the alignment of loans with both the Framework and the EU Taxonomy. Specific
criteria are incorporated in the Sustainable Finance Transaction Assessment tool to help inform the credit decision making process.
In addition, the Bank successfully issued its first green senior preferred bond in 2025, raising EUR 500 million with a maturity of six year and an
option for early redemption after five years, to support green investments.
Managed Decline of High-Impact Activities
Alpha Bank applies an Exclusion List of economic activities that impose environmental or social threat, including zero financing of:
• Thermal coal mining
• Coal-fired electricity generation
• Upstream oil exploration and extraction
• Activities with significant biodiversity harm
The Climate related, Environmental, Social and Governance Risk Management Policy on Group’s Business Lending defines the activities that the
Group does not consider financing due to the environmental and social risks they entail.
Portfolio Steering and Scenario Alignment
Application of the NZBA guidelines on sector pathways and specifically, the use of the science-based International Energy Agency Net Zero
Emissions by 2050 (IEA NZE2050) scenario as its benchmark pathway to steer the Bank’s portfolio transformation. To measure its financed
emissions, Alpha Bank follows the Global Greenhouse Gas (GHG) Accounting and Reporting Standard for the Financial Industry developed by
the Partnership for Carbon Accounting Financials. Financed emissions calculations include clients’ Sco pe 1, Scope 2 and Scope 3 emissions,
where data allows. In this context, the Bank uses physical emissions intensity metrics and/or absolute emissions to set and monitor sector
portfolio progress towards both long-term and intermediate targets. It is important to recognize the role that is played in filling critical funding
gaps for sectors actively working towards reducing their carbon footprint and facilitating the transition to a low-carbon economy.
External Dependencies and Enablers
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The effectiveness of the plan depends to an extent on the evolution of EU and national decarbonization policy as well as the development of
legal frameworks, and the availability of client-level emissions and transition plan data. Regulatory convergence (EC, ECB, EBA, ESMA, national
authorities) on climate-related risk management expectations is expected to continue driving the integration of ESG risk in the short, medium
and long-term, including resilience analysis and processes to identify and assess climate-related impacts, risks and opportunities.
The Bank will adapt its implementation priorities in line with the evolution of these external factors while continue to collaborate with peer
institutions through its membership in the United Nations – Environment Programme Finance Initiative (UNEP FI) on advancing the finance
sector sustainability journey.
Governance Architecture
The Bank has established a strong governance framework to oversee its ESG initiatives, including dedicated ESG committees at the Board and
executive levels. This ensures that financial commitments are monitored, reported, and aligned with international best practices.
The Bank’s Transition Plan is overseen through the Bank’s existing sustainability and risk governance:
At Board level, the Corporate Governance, Sustainability and Nominations Committee (CGSNC) acts as the ultimate liaison/responsible Board
Committee with respect to all sustainability issues and promotes respective communications and feedback from all the Board of Directors
Committees.
At the Executive level the Group Sustainability Committee oversees ESG topics and implementation while steering the Group’s sustainability
Strategy. At the operational level, an ESG Working Group has been established to implement key initiatives, led by the Group ESG Coordinator,
who is also responsible for providing direction to subsidiaries and other Units. The Bank’s Governance and Sustainability Div ision drives the
ESG agenda and ensures internal adoption of best practice across the Group.
The Bank has developed the Sustainable Finance Framework (SFF) to provide the classification mechanism, decision pathways, and
governance for all sustainable finance products. In addition, climate and environmental risk drivers are embedded into the credit approval
process, reputation policy, RAF, ICAAP, stress testing, and risk inventory. The implementation of the Bank's transition plan rests on the
integration of climate considerations into the business planning by setting limits through the Risk Appetite Statement and specific
sustainability targets.
The Bank’s governance structure emphasizes the development of its human resources and re-skilling. Incentives are being incorporated into
remuneration policies and practices, while data and IT systems are important in supporting business development and further ESG integration.
Alignment with CSRD and EBA Guidelines
This Transition Plan has been designed to fully reflect:
• ESRS E1-1 requirements on transition planning
• EBA Final Guidelines on ESG Risk Management on governance, strategy, risk integration, data, methodology and credit processes
• expectations under Article 449a of CRR for climate-related disclosures
• ECB supervisory expectations, including sectoral analysis, time horizons, and scenario-based analysis.
The objective is to provide a coherent, forward-looking framework that supports transparent communication with stakeholders.
Implementation Strategy
The Implementation Strategy sets out a plan to monitor and address financial forward-looking ESG risks arising from the transition to a more
sustainable economy, with a focus on addressing climate mitigation in alignment with the Paris Agreement and peer practice. The plan focuses
on strengthening capabilities, embedding transition-related processes across the Bank, and supporting clients transition to a low-carbon
economy. Consistent with CSRD and the EBA Guidelines on the management of ESG Risks, the Bank adopts a progressive, multi-year approach,
taking account of methodological developments, sectoral policy evolution, and data availability.
The Implementation Strategy is organized in five core pillars: Sectoral target development, Portfolio steering towards net zero ambitions,
Client engagement, Sustainable opportunities and Risk integration.
Sectoral Target Development and Methodology Enhancement
In 2024, Alpha Bank announced a first-round of sector targets across its lending and investment portfolios to align with the NZBA overarching
principles of setting and disclosing long-term and intermediate targets to support meeting a net zero by 2050 greenhouse gas emissions goal.
The Bank employs the widely used, science-based International Energy Agency Net Zero Emissions by 2050 (IEA NZE2050) scenario as its
benchmark pathway to set 2030 interim targets and ultimately converge towards net zero by 2050.
The Bank prioritized setting targets for the Power Generation, Oil & Gas, Cement and Iron & Steel sectors, taking into consideration each
sector’s materiality based on the financed emissions measurement, outstanding exposure, sectoral contribution to Greece’s emissions, the
availability of credible sectoral target-setting guidance, data quality and availability, as well as peer practice. These priority sectors represent a
significant share of financed emissions and are already integrated into portfolio steering, engagement intensity, and RAF thresholds. Reported
data coverage expected to leverage client information collected through the inter-banking ESGr questionnaire and used to enhance emissions
baselines.
Alpha Bank will expand its target perimeter by H1 2026 and strengthen existing sector targets monitoring processes. Sectors under
consideration for the next phase of Net Zero target-setting include Commercial Real Estate, Residential Real Estate, Shipping, and Aluminum,
subject to clarity on sectoral transition pathways and regulatory developments. The Bank will also continue reviewing target setting
methodologies and decarbonization pathways to ensure its target architecture remains robust, science-based and aligned with European and
national policy frameworks. Alpha Bank has established science-based GHG emission reduction targets for downstream activities due to their
significance under the Group’s business activities. At the same time, it has set voluntary GHG emission reduction targets for its own operations
that contribute to the achievement of the Group’s sustainability objectives. For further information, please refer to section [E1-4] “Targets
related to climate change mitigation and adaptation”.
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Table 31 Progress on Sectoral Targets
Sector
Emissions
scope
Metric
Benchmark
Scenario
Base
year
Baseline
Target
year
Target
Baseline vs 2025
Power
1
kgCO2e/MWh
132
IEA
NZE2050
2022
223
2030
-41%
-36.4%
Oil & Gas
1 and 2
Index to 100
(2022)
74
IEA
NZE2050
2022
100
2030
-26%
4.3%
Cement
1 and 2
kgCO2e/ t
cement. prod.
584
IEA
NZE2050
2022
687
2030
-15%
-9.4%
Iron &
Steel
1 and 2
kgCO2e/ t steel
1,260
IEA
NZE2050
2022
540
2030
Below
Benchmark
-27.8%
Actions with clients to support climate mitigation objectives
• Support financing of economic activities included in the Bank’s Sustainable Finance Framework
• Support clients active in the expansion of renewable energy investments
• Focus on actions to enable the transition of hard-to-abate sectors
• Active engagement with clients on their Net Zero target setting
• Active engagement with clients investing in new technologies to meet their decarbonization goals
• Collect information on new clients decarbonization trajectories
• Discuss carbon emissions measurement and how to close disclosure gaps
Portfolio Steering and Risk Appetite Integration
Alpha Bank’s portfolio steering framework ensures that the lending and investment activities progressively align with a 1.5°C pathway, in line
with NZBA, CSRD, and EBA expectations. The Net Zero portfolio framework integrates science-based sector pathways and defined risk appetite
thresholds for key priority sectors critical for the transition to a low carbon economy. Sector heatmaps and exposure analytics are being
leveraged to inform the client engagement process and prioritize possible actions to enact.
This enables Alpha Bank to systematically reduce financed emissions while supporting the real economy through a credible, orderly, and client-
centric transition.
Portfolio Steering Mechanisms
The Bank uses a diversified suite of steering mechanisms, applied proportionately across sectors as it continues to embed transition-risk
considerations into the Risk Appetite Framework (RAF), including refinement of Early Warning and Risk Tolerance thresholds for sectors with
climate targets. Both RAF indicators and client transition trajectories offer the Bank a structured process to apply to business decision making
and credit underwriting guidelines.
Exposure Steering
Exposure changes in the Bank’s lending and investment portfolio cover achieved or prospective emission reductions resulting from Alpha
Bank’s zero financing in excluded activities and from portfolio composition changes (e.g. due to high ESG risk classifica tion, capital allocation
into less carbon-intensive sectors vis-à-vis high carbon-intensive sectors). Through the Credit Policy’s exclusion list, the Bank has established
clear boundaries in what activity should be considered for financing due to their nature as well as ESG risk and implications they entail.
Financing can also be influenced by the alignment of the Bank’s credit appetite with decarbonization pathways, by pricing adj ustments for
transition risk and by sustainability-linked covenants. The operationalization of the ESG obligor assessment and Net Zero target setting offers a
mechanism to control for changes in new and existing clients with respect to ESG risk and to the future achievement of decarbonization
targets while also enables management of the exposure to high-emissions sectors.
Engagement-Based Steering
Effective client engagement is an important lever in steering the Bank’s Customers to more sustainable business practices. En gagement
frequency is prioritized based on ESG risk and sector relevance. For Customers assessed with high ESG risk score, engagement is warranted on
a biannual or more frequent basis whereas engagement with medium ESG risk Customers happens at least annually. For Customers in net
zero target sectors, more frequent engagement is performed to support Customers in high-emitting sectors transition. The majority of
financed emissions reductions, attributed to the Bank’s lending portfolio, is expected to be driven by Customers' emission re ductions. As a
result, the Bank contributes to Customers’ emissions reductions with its own mitigating actions through an effective engagement process.
Engagement priorities are also set on a case-by-case depending on a Customer’s performance deterioration, exposure size, and alignment
gaps.
Business Decisions Through RAF Thresholds
The Bank regularly monitors its performance with regards to the sectoral emission-reduction targets, reflected in defined RAF KPIs and
thresholds, including values for Early Warning (EW) bands and Risk Tolerance (RT) bands.
These thresholds act as triggers for relationship decisions:
• When a client’s performance falls in the EW–RT band, the Bank assesses the transition plan and progress to determine if the
relationship can be initiated or maintained.
• When RT is surpassed, possible actions include no financing for new clients unless a credible transition plan exists., and for existing
clients, the Bank will evaluate all available options, including engagement to identify additional decarbonization actions, exposure
reduction or sector portfolio rebalancing.
These thresholds ensure a consistent, forward-looking portfolio alignment approach, even if not publicly disclosed.
Client Engagement Framework
Alpha Bank has developed a Client Engagement Framework to ensure a consistent, and forward-looking engagement process across sectors
and client segments. Client engagement is a core lever of Alpha Bank’s Transition Plan as it enables the Bank to work responsibly with
Customers in encouraging sustainable practices. The Client Engagement Framework’s main objectives include the assessment of Customers’
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level of maturity in climate and ESG issues, identifying opportunities through sustainable finance solutions and improving it s Customers’ ESG
and climate performance.
Clint engagement represents an essential element for the Bank in addressing ESG and climate risks, identifying ways to support its Customers
transition to a low carbon economy, encouraging sustainable business models and achieving its sustainability targets including the reduction of
its financed emissions in line with its net zero strategy.
The Client Engagement Framework operationalizes the Bank’s engagement approach covering all clients above a predefined thresh old. Defines
annual or more frequent engagements depending on the client’s risk profile. Establishes client action plans and transi tion-readiness
monitoring and ensures the utilization of collected data in reviewing the progress achieved by clients. Gradually it serves to strengthen data
flows across Wholesale Banking, Governance & Sustainability, and Risk functions for consistent monitoring.
Client ESG Assessment and Risk Stratification
All corporate clients – legal entities are required to complete a standardized ESG questionnaire developed jointly by the Hellenic Banks
Association (HBA) and implemented across Greek banks. The questionnaire is hosted on a common IT platform accessible to all participating
banks to be used in evaluating and scoring their client responses independently based on internal methodologies. As a result, Alpha Bank
converts the output of the ESG questionnaire into an ESG Risk Score (High, Medium, Low) at the obligor level.
The ESG Risk Score is incorporated in the Bank’s Credit Policy leading to an adjustment in pricing after taking into account the ESG features of
the transaction. In addition, the ESG assessment influences the client engagement strategy. It serves to monit or clients’ ESG progress and
transition readiness, propose remedial action when appropriate and for early detection of potential transition or reputational risks. This
stratification acts as the backbone of the Bank’s client engagement strategy.
Engagement Strategy
Alpha Bank’s engagement model centers around the systematic evaluation of its clients and prioritization based on internal as sessment of ESG
risk, Net Zero target-setting and sector relevance to transition risk. The aim is to address the risks identified and support clients in improving
their ESG performance, so that ESG risks do not turn into a credit risk for the Bank in the future.
a. ESG risk assessment is the initial step as it is based on the evaluation of reported data on climate and other environmental factors as well
as social factors and corporate governance. The assessment serves to identify clients with High ESG risk score and focuses on deciding an
Action Plan with the client to remediate identified gaps. Measures are time-bound, realistic while progress is expected on an annual
basis. Credit pricing could be linked to risk remediation, where appropriate.
Examples of Action Plan outcomes:
• Adoption of energy efficiency measures
• Development of baseline emissions
• Establishment of governance practices
• Initiation of sustainability reporting
• Steps to prepare a credible Transition Plan
b. Integrating Net Zero into the engagement strategy has the objective of supporting clients in their transition and ultimately steering high-
carbon sectors towards global climate goals. Analysis focuses on tracking alignment with sectoral pathways within the Bank’s Net Zero
sector perimeter (e.g. power, cement, iron & steel, oil & gas), tracking progress of clients’ own targets and reviewing clients’ transition
plan.
Actions to manage alignment within the Net Zero sector perimeter include:
• Identifying gaps between client pathways and the Bank’s sectoral decarbonization trajectories
• Supporting clients to access sustainable finance solutions (e.g. SLLs, green CapEx loans)
• Advising on transition strategies, financing proposals and reporting structures
• Early identification of clients whose plans are misaligned (potential escalation)
This reflects the EBA requirement for banks to monitor client alignment with science-based sector pathways.
c. For clients in other climate sensitive sectors, the Bank prioritizes the top 20 clients with increased transition risk to initiate a dialogue. The
main objective is to highlight the need to adopt practices that improve clients' resilience to future regulatory developments and climate
change as well as identify new green finance opportunities.
Engagement Focus:
• Provide guidance on improving sustainability maturity
• Identify opportunities for energy efficiency, circularity, clean mobility, etc.
• Support clients in exploring sustainability-linked financing
• Improve data quality
Client engagement is performed on an annual basis with emphasis on opportunity-creation and risk-mitigation, including the enhancement of
data collection needed for regulatory reporting and for managing climate and environmental risks.
Engagement Process:
The client engagement framework operates under a multi-layered governance structure that ensures clear ownership, effective oversight, and
appropriate escalation pathways. This structure aligns with EBA expectations on governance and risk management integration, decision-making
and in the development of various internal processes. The engagement process key objectives reflect the assurance of the resilience of the
Bank's portfolio and the encouragement of the sustainable development of its clients.
All corporate clients subject to the ESGr questionnaire must be engaged at least once annually. Additional engagements occur if risk increases,
if the client is in a target-setting sector, or if an Action Plan is triggered. For High ESG Risk clients, engagement frequency could increase (biannual
or quarterly depending on severity and credit exposure).
The Wholesale Banking, Governance & Sustainability Division and Climate, ESG and Enterprise Risk Business Area cooperate to ensure
coordination, quality control and consistent interpretation across the Bank. As a result, Relationship Managers (RMs) receive consistent guidance
to apply fairly and transparently the Client Engagement Framework.
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Where client engagement outcomes reveal material issues such as lagging performance in alignment objectives, deterioration in ESG risk
assessment, or concerns related to specific transactions, an escalation to relevant Committees is followed:
(i) Credit Committee
For matters directly connected to a specific lending decision, including:
• Approval of a loan to a High ESG Risk client
• Proposed conditions, covenants, or pricing adjustments related to ESG risk
• Concerns that the client’s transition readiness is inconsistent with the Bank’s credit standards
(ii) Group Sustainability Committee
For matters of strategic significance, including:
• Clients in Net Zero sectors whose transition plans diverge from the Bank’s sector pathways
• Systemic issues identified across multiple sectors or client groups
• Topics affecting the Bank’s progress towards its Net Zero commitment
• Matters requiring Bank-wide policy alignment or adjustment
When appropriate, issues may be escalated to higher levels of authority, including the Executive Committee and the Board of Directors.
This structure ensures that important issues relating to transition risk, reputational risk, and portfolio alignment receive appropriate senior
oversight.
Data Systems and Information Flow
Client engagement data and ESG risk assessments are maintained across dedicated systems that allow for:
• Consistent tracking of engagement activity
• Monitoring of Action Plan progress
• Maintenance of audit trails for supervisory review
• Integration of ESG risk parameters into credit-risk systems
• The ability to generate client-specific reports for RMs in advance of meetings
• Aggregation of metrics for reporting to the Group Sustainability Committee and other governance bodies
The ESG Risk Assessment results are stored in an internal system, ensuring alignment with the Bank’s broader risk frameworks. Additionally,
onboarding processes are modified to incorporate the ESG data reported by clients to be used for both business and risk management purposes.
Alpha Bank employs a comprehensive suite of tools and analytical methodologies to support its client engagement framework, ensure
consistent risk assessment, and align portfolio decisions with the Bank’s Net Zero pathways. These tools are used across Whol esale Banking,
Risk Management, and Sustainability functions, ensuring an integrated and forward-looking approach as required by the EBA Guidelines.
Alignment with Risk Management Frameworks
The integration of governance across the Bank’s Wholesale Banking, Sustainability, and Risk Management Business Areas ensures that:
• ESG risks are considered as drivers of credit, operational, reputational and strategic risk, consistent with EBA guidelines
• Transition misalignment is captured in risk identification and monitoring
• Action Plan progress can influence credit terms, review frequency and risk ratings
• Client engagement outputs inform the Bank’s sector heatmaps, portfolio steering and transition-risk assessment methods
Climate Policy Relevant Sectors (CPRS) and Equivalent Sector Classifications
The Bank uses the CPRS perimeter to identify sectors most exposed to transition risk. These sectoral classifications:
• guide prioritization of client engagement intensity
• inform sector-level heatmaps
• support alignment with NZBA priority sectors
• structure risk identification and early warning indicators
In addition, the Bank identifies material exposures in non-financial corporates according to the measurement of financed emissions.
Physical Risk Assessment
Physical climate risks are assessed using the Bank’s dedicated methodologies at obligor level, collateral level (e.g., real e state exposure) and
sector and geographical levels.
Outputs include vulnerability scores and scenario-based indicators that feed into credit reviews, pricing considerations, and engagement
dialogues. These assessments support compliance with EBA requirements for physical risk integration into credit risk, operational risk, and stress
testing.
Reputational Risk Assessment
A dedicated Reputational Risk Questionnaire evaluates clients’ exposure to ESG-related reputational risks, including environmental incidents,
governance deficiencies, or social controversies. This tool is used to trigger the escalation process to the Reputational Risk Committee, to support
the development of an Action Plan and to enhance monitoring for clients with heightened reputational sensitivity.
ESG Risk Assessment (ESGr Questionnaire Scoring)
The Hellenic Bank Association (HBA) interbank ESGr questionnaire is used to collect client ESG information and to apply an internally developed
methodology to calculate the Alpha Bank ESG Risk Score. The outputs:
• Determine High/Medium/Low ESG Risk categories
• Influence loan pricing and credit structuring
• Trigger proposal on client Action Plan
• Inform the client engagement strategy
• Serve as a baseline for monitoring ESG performance
This tool is foundational to the Bank’s ESG data collection process, client engagement prioritization and credit review.
Opportunities in sustainable products and services
Alpha Bank has introduced ESG criteria across its financial products suite to support Sustainable investments and consumer choices. Moreover,
mechanisms have been developed to drive capital allocation towards sustainable investments through pricing adjustments and incentives.
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For large corporate clients the Bank draws on its expertise in deploying co-funding initiatives, to support clients’ transition pathways including
the EU Resilience and Recovery Facility (RRF) Green transition pillar to accelerate sustainable investments. Through the Recovery and Resilience
Facility, the Bank provides financing for the green transition, with a focus on Renewable Energy Sources. Eligible categories under the “green
pillar” include green technologies, green skills, biodiversity, energy effici ency, building renovation, preservation of energy security, circular
economy, sustainable development and creation of jobs.
For small businesses, the Alpha Photovoltaic product facilitates investment in photovoltaic stations up to 1 MW to boost renewable energy
generation. Additionally, in collaboration with the Hellenic Development Bank, the Green Co-Financing Loans program offers loans with
attractive terms—including interest-free portions and subsidies—to encourage sustainable projects.
For individual clients, the Bank offers a variety of green loans with preferential interest rates for green mortgages, home energy upgrades, eco-
friendly transportation (including electric and hybrid vehicles), and energy-efficient home equipment such as photovoltaic panels and heat
pumps. Also, the Bank actively participates in state-supported energy-saving programs.
The Bank’s sustainable lending operations are part of the Transaction Assessment & Loan Approval Process enabling favorable pricing scenarios
with respect to the categories of the Sustainable Finance Framework. For wholesale clients, pricing differentiates on the basis of obligor High
ESG risk and when the outcome of the transaction assessment is sustainable financing. In terms of retail clients, the pricing scenarios address
green mortgages, property renovation and green consumer loans.
Table 32 Sustainable financing
24
2025
2024
2023
Corporate Loans in Green thematic categories
3,251.3
2,068.6
1,517.4
of which renewable energy
2,134.7
1,400.5
1,066.8
of which energy efficiency
22.2
23.5
2.1
of which green buildings
1,040.2
613.1
378.2
of which sustainable transport
-
-
-
of which resource efficiency and pollution
control
54.2
31.5
70.3
Green mortgages
475.1
500.7
345.0
Total
(corporate green loans & green mortgages)
3,726.4
2,569.3
1,862.4
Sustainability-linked loans
1,100.4
925.9
303.4
According to the total sustainable stock breakdown for 2025, dedicated purpose loans to green eligible economic activities cover APPROX. 68%
of total sustainable wholesale loans. In addition, Renewable Energy is identified as the Sustainable Finance Framework green category with the
largest loan coverage.
The Bank continues to expand its offerings aligning with evolving market demands and regulatory frameworks.
Cornerstone of the Group’s Sustainable Finance Strategy is the design of financial products to enable its clients transition to low-carbon business
models, the provision of “green” retail loans with preferential interest rate to cover Customers’ needs and offering financing opportunities
through EU and state-funded programs covering green and sustainability-related categories as well as dedicated green solutions for small and
medium size businesses.
Table 33 Sustainable Financing Strategy delivery mechanism
Initiative
Description
Project Finance
Through its specialized Project Finance Unit the Bank supports green/low carbon investments:
- Providing financing for new investments in wind farms and solar parks.
- Providing financing for Commercial Real Estate (CRE) projects certified under an internationally or
nationally recognized green building certification scheme.
Co-Funding Programs
Utilize the Bank’s significant expertise in deploying co-funding initiatives, to support decarbonization:
− Leveraging the EU Recovery and Resilience Facility (RRF) Green transition pillar to accelerate green
investments.
− Enabling small businesses to improve their environmental footprint and reduce their energy use, via
the Hellenic Development Bank programs.
Green and Home Energy Solutions
Enhancement with new services and financial incentives in the context of the Green Loan Portfolio to encourage
consumer sustainability journey via:
− Home improvement or equipment loans (thermal insulation, solar panels, heat pumps, energy-
efficient electrical appliances).
− New Green mobility financing solutions to support electrification of transport (plug-in electric
vehicles, electric vehicles, scooters, public transport).
− Incorporation of sustainability criteria into mortgage and real estate lending policies, including
financing terms and pricing.
− Provision of other incentives to existing clients to accelerate the adoption of energy efficiency
standards.
24
Data presented in the table refer to Alpha Bank S.A.
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Sustainable Investment Products
− Enriching the offering of mutual funds that promote sustainable investment characteristics.
− Endorsing labelled Green and Social Bonds and promote impact investment-linked structured notes
that incorporate environmental and social characteristics.
− Engaging in training initiatives and dialogue with clients on sustainability themes.
Being a financial institution, Alpha Bank's climate change mitigation actions do not directly link to EU Taxonomy metrics, such as CapEx plans
for aligning economic activities. The most relevant KPIs in this space come from the Pillar III disclosures and include KPIs such as the Green
Asset Ratio (GAR). GAR calculations include loans, advances, and securities linked to aligned activities, excluding exposures such as central
government assets, trading securities, and non-NFRD entities.
Risk Management, Stress Testing and Data Integration
The Bank is committed to integrating ESG and Climate risks into its overall risk management framework. In this context, the Bank regularly
monitors its exposure concentration in climate sensitive sectors for its loan and investment portfolio, while updating its policies and processes,
improving data quality, coverage and calculation approaches. Key actions are summarized below:
• Continue integrating C&E drivers across ICAAP, credit risk, operational risk, reputational risk and strategic planning.
• Expand the application of physical and transition risk assessments using CPRS, sector vulnerability mapping, nature-related transition
risks, and financed-emissions analytics.
• Enhance climate and nature integration in stress testing, in line with supervisory expectations and developments in ECB/NGFS
scenarios.
• Maintain BCBS 239-aligned risk data aggregation processes to support ESG and climate reporting.
Alpha Bank recognizes climate, environmental and social (C&E/ESG) risks as transversal risk drivers that influence traditional financial and non-
financial risk categories.
Alpha Bank incorporates ESG and climate characteristics into the risk identification and materiality assessment processes and in the overall risk
management framework. Key elements include:
• The Bank’s materiality assessment analysis identifies the sectors most sensitive to climate-related risks. The Bank performs the
identification and materiality assessment of Climate and ESG risks on an annual basis, as part of its broader recurring risk materiality
assessment process.
• The Bank has developed The Climate related, Environmental, Social and Governance Risk Management Policy on Group’s Business
Lending. The Policy defines the exclusion list which comprises activities that the Group should not consider for financing due to their
nature as well as the ESG risks and implications they entail.
• The Bank’s Credit Policy incorporates the ESG client, ESG transaction and ESG overall assessment, into its credit approval pr ocess.
• The Bank regularly monitors its exposure concentration to climate-sensitive sectors in its loan portfolio, through the introduction of
credit concentration risk indicator within its Risk Appetite Framework.
• The integration is already operational, reflecting enhancements delivered since 2023 and publicly disclosed.
Risk Identification and Materiality Assessment
The Group conducts a double materiality assessment that leverages UNEP FI tools, CPRS classifications, and sector-level vulnerability mapping.
This identifies material impacts, risks and opportunities across climate, environmental, social and governance dimensions.
Climate-Related Risk Drivers
The Bank assesses both climate transition and physical risks for credit risk, market/liquidity risk, operational risk, reputational risk, and strategic
risk across relevant time horizons (short, medium, long-term).
Examples disclosed in the Bank’s Sustainability Statement include:
• Transition risk materially affects NFCs and Retail Real Estate portfolios in the medium and long term.
• Physical risk materially affects NFCs and real estate exposures across the same horizons.
• Reputational risk is materially affected by climate/environmental drivers.
• Transition risk also materially affects business and strategic risk.
Nature-Related Risk Drivers
The Bank integrates nature-related risks, using the UNEP FI and ENCORE tools to identify dependencies on ecosystems, biodiversity loss
implications, and “inside-out / outside-in” impacts. These assessments feed into client-level and portfolio-level risk identification. Please refer
to [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities for details.
Integration into Credit Risk Management
The Bank’s Credit Policy incorporates the ESG client, ESG transaction and ESG overall assessment, into its credit approval pr ocess.
At the client level, the Bank applies a granular client screening during the credit origination process, against certain environmental, social and
governance criteria collected through the application of inter-banking client ESGr questionnaires sectoral or cross sectoral considering the size
of the company. At the transaction level, the activity for which the client is applying or has received financing is assessed for alignment with the
Sustainable Finance Framework. The ESG overall assessment represents a combination of the client and transaction assessment and is captured
per transaction. These assessments are integrated into the credit decision-making process, influencing pricing.
In addition, the Bank has developed a Reputational Risk Policy which defines the main principles, processes and governance structure for
effectively managing reputational risk exposures, including those stemming from ESG factors.
The Bank has introduced additional indicators within the Environmental, Social and Governance (ESG) category of its RAF which incorporates
both quantitative indicators and qualitative commitments for climate and ESG risks.
Enhancements disclosed include:
• Climate & Environment indicators upgraded to Tier II status, with limits for effective monitoring.
• Integration of sector-specific emission reduction targets into RAF thresholds (EW/RT bands) for Net Zero sectors.
• Commitment to zero financing for exclusion-list activities (coal mining, coal power, upstream oil exploration, biodiversity-harmful
activities).
The RAF ensures that transition risk and misalignment are addressed through exposure appetite, underwriting decisions and escalation process.
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The Bank has updated its Risk Inventory and ICAAP to reflect climate and environmental risks as transversal drivers. Specifically, the Bank has
developed climate risk-specific methodologies to estimate the impact of climate scenarios under both the Economic and Normative perspective.
The current methodologies focus on the impact of both transition and physical risks (Flood & Drought) on credit risk, as well as the impact on
operational risk and business & strategic risks considering the relevant risk materiality assessment that has been performed.
ICAAP integration includes:
• sector transition risk assessments
• sector vulnerability analysis
• linkage to PD/LGD adjustments where relevant
• alignment with supervisory expectations for forward-looking capital adequacy
Stress Testing and Forward-Looking Analysis
Stress testing follows regulatory requirements and incorporates climate-related elements. The Bank has developed a Climate Risk Stress Testing
Framework enhanced with the integration of C&E risks into macro-scenarios, examination of Gross Interest and Fees & Commissions sensitivity
to transition shocks and physical risk overlays for real estate and vulnerable sectors.
Climate-related stress testing applies the NGFS scenarios, where applicable, and a sector-specific calibration informed by CPRS, NZBA, ECB and
national LTS data. The Bank’s approach responds directly to EBA’s requirement for scenario-based analysis of ESG risks over short, medium, and
long-term horizons.
Operational Risk
Climate and environmental factors are deemed material, especially regarding Own-Use Real Estate, data centers, and environmental events.
Reputational Risk
Reputational risk is materially affected by climate and environmental drivers. The Bank has established the Reputational Risk Committee
responsible for the oversight over any ESG-related reputational concerns.
Business & Strategic Risk
C&E risk materially affects long-term strategic risk due to economic shifts, client transitions, and regulatory developments. As a result, the Bank
conducts a materiality assessment of business and strategic risk for the Gross Interest and Fees & Commissions income generated by the Non-
Financial Corporations (NFC) portfolio broken down to activities/sectors more sensitive to transition risk, based on the CPRS perimeter.
Data, Models and Risk Reporting
The Bank follows an integrated approach ensuring that identification and materiality assessment of ESG risks are performed on an annual basis,
as part of the broader recurring risk materiality assessment process.
Specifically,
• ESG drivers influence PD/LGD, credit decisions, and portfolio strategy
• Climate and nature risks feed into ICAAP and capital planning
• RAF thresholds operationalize sector targets
• Escalation processes intervene early in cases of misalignment
• Data aggregation supports Article 449a CRR disclosures and CSRD reporting
• Governance bodies maintain oversight across risk and strategy
A dedicated ESG report is presented quarterly to the Group Sustainability Committee (GSC) and Risk Management Committee (RMC), and
onward to the Board. In addition, transparent monitoring and annual external reporting ensure accountability and compliance with regulatory
frameworks.
Alpha Bank continues to validate risk models and implement a “Risk Data Aggregation and Reporting Validation Framework” to co mply with
BCBS 239 and has centralized data for Obligor-level CPRS classification and Physical risk assessment for obligors and real estate collateral.
IT, Tools and Workflow Enhancement
Emphasis is placed on the integration of ESG client and transaction-related data into the Bank’s credit systems and workflow environments.
Specifically, IT tools are used to expand internal analytics capabilities for portfolio-level steering and monitoring. In addition, planned
development of client dashboard is expected to provide a consolidated view of ESG risk scores, alignment indicators, engagement outcomes and
sector benchmarks. These enhancements support business management and decision-making, oversight, and regulatory compliance while
facilitating team collaboration and client servicing.
Phasing and Milestones
The implementation activities follow a phased, multi-year timeline, aligned with methodological development, sectoral policy updates and UNEP
FI/NZBA guidance.
Without disclosing sensitive or operational details, the Bank’s implementation logic can be summarized as follows:
• Focus on improving data collection, emissions measurement methodologies, risk identification, RAF monitoring, client engagement,
and governance reporting.
• Ongoing refinement of risk integration, model enhancements, stress-testing practice, and alignment with evolving supervisory
expectations.
• Further operationalization of transition analytics, client transition readiness assessments, improved workflow integration, a nd
development of future metrics.
• Expansion of the sectoral target perimeter, second wave of target setting to be finalized by H1 2026.
Monitoring, Metrics & Reporting
Effective monitoring and transparent reporting are essential components of Alpha Bank’s Transition Plan. They ensure that pro gress toward the
Bank’s Net Zero objectives is tracked systematically, that risks are adequately identified and managed, and that s enior leadership and
stakeholders receive reliable, forward-looking information.
The monitoring framework integrates quantitative indicators, qualitative assessments, and escalation mechanisms across client, sector and
portfolio levels. It is designed to comply with CSRD ESRS [E1-1] and the EBA Guidelines on management of ESG Risks, as well as broader
supervisory expectations under the ECB and Article 449a CRR.
Portfolio-Level Monitoring
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The Bank regularly measures its financed emissions, covering investment and lending products of its corporate portfolio across all the sectors it
finances, based on the GHG emissions of its borrowers or investee companies. To measure its financed emissions, the Bank follows the Global
Greenhouse Gas (GHG) Accounting and Reporting Standard for the Financial Industry developed by the Partnership for Carbon Accounting
Financials (PCAF, version Dec. 2022). Specifically, the Bank measures:
• Physical emissions intensity metrics for relevant Net Zero sectors
• Absolute emissions measured in tCO2e, where required (e.g. Oil & Gas)
• Portfolio emission trajectories relative to sector-specific science-based pathways
• Financed emissions captured in sectors the Bank has not set climate targets
• Exposure to PAB-excluded activities, as reported in the Bank’s Pillar 3 disclosure
These indicators support regular assessment of whether the portfolio is converging toward Net Zero.
To strengthen its portfolio and client monitoring process, the Bank is developing additional metrics in relation to the asses sment of key clients’
transition plans and disclosure of key information (current GHG performance, impact of a low carbon transition on business, strategy and
financial planning, actions and activities to accelerate the transition). Building on clients’ transition plans, the Bank focuses on mapping clients’
decarbonization projects included in the Net Zero target perimeter to the Sustainable Finance Framework eligible economic activities to support
sustainable financing solutions proposed during client engagement.
These metrics will track the clients’ transition readiness and alignment with sectoral decarbonization pathways.
Client-Level Monitoring
To support early identification of misalignment or deterioration, the Bank incorporates tools to monitor client performance and risk assessment.
In this context, the Bank calculates client ESG Risk Scores derived from the inter-banking ESGr questionnaire and based on internal methodology.
For clients assessed as High ESG Risk, the implementation of actions set to improve performance is reviewed and included in the engagement
output. Transition-readiness indicators support the Bank’s monitoring of client progress against climate targets and assessment of CapEx
consistency with decarbonization commitments. For clients in Net Zero target sectors, Early Warning to Risk Tolerance and Risk tolerance limits
and thresholds are introduced in the RAF.
For all clients above eligibility threshold, a structured engagement process is followed at least annually. High ESG risk or clients in the Net Zero
target perimeter are monitored more frequently on a case-by-case basis. Engagement outputs are expected to be logged in structured IT systems,
ensuring consistency, traceability and auditability.
Sector-Level Monitoring
At sector level, the Bank monitors regularly sector vulnerability based on the CPRS perimeter, nature-risk assessment, physical risk indicators,
and transition risk indicators. The Bank also monitors sector decarbonization pathways against the progress made in its own sector portfolios,
in addition to client alignment to the net zero targets. Sector-level risk limits and thresholds as defined in the Risk Appetite Framework are
calculated and assessed regularly offering early signals and escalation triggers for further actions.
Sector-level insights feed into portfolio steering, model updates, ICAAP and strategic planning.
Risk Management and Internal Reporting
A detailed ESG report is produced quarterly to ensure continuous senior oversight to inform the Group Sustainability Committee, the Risk
Management Committee, and the Board of Directors.
The report includes progress on key metrics that enable the assessment of the Bank’s performance towards its commitments. Specifically, these
metrics include the Bank’s financed emission measurement, RAF KPIs, exposure to high-emitting sectors, progress against climate targets in the
Bank’s Net Zero sector perimeter, as well as any information on material developments in methodologies or regulatory expectat ions.
Outputs from the monitoring framework feed into Internal Capital Adequacy Assessment Process (ICAAP), portfolio vulnerability analysis, stress
testing and strategic planning and capital allocation, ensuring alignment of the Transition Plan with the Bank’s long-term financial resilience.
Governance
The Transition Plan is integrated in the Group ESG Governance model for effective oversight, management, and implementation of
sustainability-related matters across all levels of governance:
• Board level: The Corporate Governance, Sustainability, and Nominations Committee (CGSNC) oversees ESG issues, ensuring
alignment with sustainability goals and regulatory requirements.
• Executive level: The Group Sustainability Committee directs ESG initiatives and ensures alignment with strategic objectives.
• Operational level: The Governance & Sustainability Business Area, led by the Group ESG Coordinator, implements ESG and
sustainability initiatives across the Group.
Please refer to [GOV-1] “The role of the administrative, management and supervisory bodies in the Sustainability Statement for the detailed
governance and oversight”.
Remuneration linked to ESG and Sustainability
The Remuneration Policy of the Members of the Board of Directors has been revised to incorporate ESG and sustainability considerations by
aligning variable remuneration elements with both financial and non-financial Key Performance Indicators (KPIs), including environmental,
social, and governance (ESG) goals. The 2025 Remuneration Policy can be accessed on the Group’s website.
• The short-term targets of the Combined Bonus Plan CBP include criteria linked with corporate social responsibility and/or wider ESG-
related goals, e.g. the balanced scorecard for Senior Executives includes targets on Group Sustainable Financing products. These
targets may vary each year and are always subject to the approval of the Board of Directors.
• The long-term (3-year) performance targets of the CBP, additionally to the short-term targets, include Sustainable Finance
disbursements and female participation at middle management level and above. These targets bear specific weights and aim to
incorporate ESG criteria in long-term incentive remuneration.
Skills
The Group provides ESG training through the ESG Academy and by prioritising three learning paths for its Employees: (i) ESG Awareness, (ii)
Fundamentals towards ESG integration, (iii) Technical capabilities for ESG. The training topics aim to build an understanding of ESG and how it
is being integrated into the Bank’s core operations and procedures as well as to improve communication with the Bank’s Customers. Details for
the ESG Academy progress in 2025 are provided under [E1-3] “Actions and resources in relation to climate change policies”.
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Specifically, the training dedicated to operationalizing ESG covers the client and transaction assessment process and provides information to
support the RMs when engaging with clients on completing the annual ESGr questionnaires.
Disclosure and External Reporting
The Group reports on climate-related metrics and transition progress through:
• Annual Sustainability Statement (CSRD)
• Article 449a CRR disclosures
• EU Taxonomy disclosures
• Pillar 3 report
• relevant investor and supervisory dialogues
These disclosures are made using verifiable methodologies, subject to internal governance controls and external assurance where required.
The Group maintains a commitment to clear, factual, non-promotional reporting, consistent with the expectations of regulators, investors,
clients, and other relevant stakeholders.
Continuous Improvement
Monitoring processes will evolve as sectoral pathways are refined, more granular data becomes available from clients, regulatory and
methodological guidance advances, and the Bank’s maturity expands to enable further ESG integration.
Alpha Bank aims to maintain alignment with the most credible methodologies available, while adapting monitoring frameworks proportionately
to risk, materiality and regulatory expectations.
[E1.SBM-3] Material impacts, risks and opportunities related to Climate Change and their interaction with strategy and
business model
Climate related-risks
Regarding climate-related risks, the Group performs materiality assessment separately for Transition and Physical Risks.
In accordance with the scientific literature and regulatory guidance the Group acknowledges that transition risks are the risks of any negative
financial impact on the institution, stemming from the current or prospective impacts of the transition to an environmentally sustainable
economy on its counterparties or invested assets. The following transition risk sub-types are considered for the materiality assessment of
transition risk: policy and legal, market, reputation and technology.
Physical risks are the risks of any negative financial impact on the institution stemming from the current or prospective impacts of the physical
effects of environmental factors on its counterparties or invested assets. They are categorized either as acute - if they arise from particular
extreme events, or chronic - if they arise from progressive shifts in climate and weather patterns or a gradual loss of ecosystem services.
Detailed information on the Group qualitative materiality assessment for transition and physical risk sub-types, is provided under [E1.IRO-1]
Description of the processes to identify and assess material climate-related impacts, risks and opportunities.
Resilience analysis
Scope & Methodology
Transition Risks
The Group has performed an assessment to identify sectors sensitive to transition risk, while for those sectors lying within the transition risk
sensitive perimeter a risk assessment has been performed under different time horizons (i.e., 2026, 2030, 2050). The scale of the transition risk
is defined by combining the outcome of the Likelihood (the probability of occurrence within a provided time horizon) and the Impact analysis
(the extent to which the impact, if occurred, would affect the business). In order to estimate the likelihood of the transition risks more recent
literature scenarios, strategic plans and roadmaps were used, to qualitatively estimate the probability of occurrence of each transition risk
driver, as explicitly described under [E1.IRO-1]. The analysis covers the Group’s Non-Financial Corporate portfolio.
Alpha Bank in the context of the Internal Capital Adequacy Assessment Process (ICAAP Report), aligned with International best practices, has
developed climate risk-specific methodologies to estimate the impact of transition on credit risk across different time horizons (short, medium
and long term) by making use of leading global macroeconomic and sectoral models. Additional characteristics such as building s’ energy
efficiency, geographic and counterparty level characteristics are also incorporated in the estimation to further account for heterogeneity of
impacts inherent in climate risks. These are examined as stand-alone climate scenarios and used under both the Economic and Normative
perspective. Where applicable these scenarios are also applied on operational risk and business & strategic risks considering the relevant risk
materiality assessment that has been performed. More details on the above is provided in the ICAAP climate scenarios section below.
Physical Risks
As part of the physical risk assessment, multiple IPCC climate scenarios were reviewed - RCP 4.5, RCP 6.0, and RCP 8.5. Each climate scenario
represents a distinct transition pathway, shaped by varying assumptions about global emissions, policy actions, technological developments,
and societal behavior. The RCP 8.5 pathway reflects a high-emissions, business-as-usual scenario, where minimal global action is taken to
mitigate climate change. It is commonly used in stress testing and materiality assessments to evaluate worst-case climate impacts. In contrast,
the Net Zero Emissions (NZE) pathway represents a transition to a low-carbon economy, driven by ambitious decarbonization efforts aligned
with global climate targets. RCP 8.5 was selected due to its conservative nature and alignment with worst-case outcomes and the assessment
was performed for 2026, 2030 and 2050 horizons.
More specifically, as described under data point [E1.IRO-1] “Description of the processes to identify and assess material climate-related
impacts, risks and opportunities”, and [SBM-3] “Material impacts, risks and opportunies and their interacon with strategy and business
model”, the Bank has laid down a methodology based on sensitivity and exposure analysis to derive vulnerability to physical risk factors.
Vulnerability analysis is performed to identify potential significant hazards per subsector covered by the analysis for Business portfolio, as well
as across the different geographic regions where real estate properties used as collateral extend. More details regarding the sensitivity &
exposure analysis as well as the scenarios utilized, may be found under [E1.IRO-1] “Description of the processes to identify and assess material
climate-related impacts, risks and opportunities”.
Alpha Bank in the context of the Internal Capital Adequacy Assessment Process (ICAAP Report), aligned with International best practices, has
developed climate risk-specific methodologies to estimate the impact of physical risk (chronic and acute risks – specifically flood and wildfire)
on credit risk across different time horizons (short, medium and long term) by making use of leading global macroeconomic and sectoral
models, as well natural catastrophe models for Greece. Additional characteristics such as geographic and counterparty level characteristics are
also incorporated in the estimation to further account for heterogeneity of impacts inherent in climate risks. These are examined as stand-
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alone climate scenarios and used under both the Economic and Normative perspective. Where applicable these scenarios are also applied on
operational risk and business & strategic risks considering the relevant risk materiality assessment that has been performed. More details on
ICAAP climate scenarios are provided below.
ICAAP climate scenarios
As part of ICAAP, institutions are expected to conduct a comprehensive and tailored review of their vulnerabilities through stress testing.
These stress scenarios should encompass all material risks that could deplete internal capital or impact regulatory capital ratios and should be
incorporated into the institution’s stress-testing program from both an economic and normative perspective. Institutions are encouraged to
consider scenarios that align with scientifically supported climate change pathways, such as those outlined by the IPCC. According to the
materiality assessment the Bank conducted credit risk, operational risk and business & strategic risk are material in the medium- and long-
term horizons (please see “Climate-related Risks Materiality Assessment” section for more details).
The Bank has developed a Climate Scenario Analysis methodology to support stress testing across all material risks, ensuring alignment with
international best practices and ECB expectations. Regarding climate and environmental (C&E) risks to capital adequacy, from both economic
and normative perspectives, the Bank has designed climate risk-specific methodologies to evaluate the impact of climate scenarios. These
methodologies assess the effects of transition and physical risks on credit risk over the medium and long-term horizons. They leverage
advanced global macroeconomic, sectoral, and natural catastrophe models, including those specifically tailored for Greece. For transition risks,
the analysis incorporates factors such as buildings' energy efficiency, geographic attributes, and counterparty-level characteristics to account
for the heterogeneous impacts of climate change. For physical risks, (chronic and acute risks – specifically flood and wildfire), the
methodologies incorporate key factors such as geographic location and counterparty-level characteristics. The scenarios are analysed
independently under both the Economic and Normative perspectives. Where relevant, they are also extended to operational, business and
strategic risks, considering the outcomes of detailed risk materiality assessments.
Regarding estimations of the transition risks, the Bank is using models for different time-horizons (medium and long term), which comes along
with a set of climate scenarios. This model draws its various climate scenarios from international organizations like the NGFS, IEA, and IPCC
providing an impact quantification of these scenarios on key macroeconomic and sectoral variables across different time horizons.
The model is a leading macroeconomic model which provides a rigorous and consistent structure for forecasting and testing scenarios. It is a
global, general equilibrium macroeconomic model which includes 85 countries and can be used to address questions on a wide range of
economic variables. The framework used, is based upon three key components a) Climate policy levers, b) an electricity module, and c) a
climate damage function which quantifies the relationship between environmental change and the resulting economic damages or losses
(related to long-term physical risk scenarios). These components provide a rigorous and consistent structure for analyzing the implication of
alternative climate scenarios, taking account linkages between economies such as trade and commodity prices.
Regarding medium-term transition risk a proprietary disorderly transition scenario is used in a 3y horizon. Regarding long-term (2050)
scenarios the Bank based on the above-mentioned macro model utilizes NGFS’ Net zero, Delayed transition and a proprietary Baseline aligned
with NGFS NDC scenario for transition risk, while for physical risk it utilizes a proprietary physical risk scenario aligned with IPCC’s RCP 8.5.
Regarding physical risk in the short-term, the Bank has focused on specific acute risks, namely flood (Fluvial, pluvial and coastal flood) and
wildfire, based on its ESG Risk Materiality assessment. The Bank has followed an approach similar to that of the 2022 ECB Stress Test, utilizing
Average Annual Losses estimates from natural catastrophe model. In this scenario, it is assumed that severe floods and wildfires take place in
Greece. These events bring in one year the losses that, on average, the country will experience in a 50 years’ time horizon, which is a rather
conservative assumption. While the probability of such an event is low, it allows the creation of relevant acute physical risk scenario.
Regarding the estimations of acute physical risks, the Bank has procured a solution to assess the expected economic impacts of acute physical
risks on collaterals and economic activity. The assessment consists of three main physical risk components:
• Hazard: the geographical hazard can be seen as the probability of the residential real estate or the company to be hit by physical
risk events, given their localization.
• Vulnerability: the vulnerability represents the non-dimensional impact (e.g. percentage damage on the asset value) in case of a
natural event: for a building, it depends on structural characteristics which affect its resilience to natural events.
• Exposure: the exposure represents the value of the asset exposed to physical risks and is the main ingredient needed to translate
an a-dimensional impact to monetary impacts.
The combined assessment of the three aforementioned components (exposure, hazard, and vulnerability) – which is coherent with the
approach used for the development of the ECB climate-related statistical indicators - allows estimating the expected economic impacts arising
from different acute physical risks.
The Bank follows a proportional approach regarding estimating acute physical risks using collateral specific characteristics versus regional
averages depending on the collateral’s materiality to the Real estate portfolio. More specifically, regarding colla terals representing a large
share of collateralized exposures in terms of value losses are calculated using collateral specific characteristics such as specific location,
intended usage (residential vs commercial) and year of construction. However, regarding collaterals representing an immaterial share of
exposures estimates of losses at NUTS3 level are used.
The Bank assesses the impact of the transition to a lower carbon economy on Real Estate prices as expressed through changes to more energy
efficient buildings indicated by collaterals’ Energy Performance Certificates (EPC). Due to lack of publicly available data regarding building
characteristics the Bank has used for this exercise a combination of data from its databases and external geospatial data. Specifically regarding
EPCs these include both actual and estimated EPCs by the Bank’s model. In parallel, the Bank is undertaking intensive efforts to increase the
coverage of actual EPCs in its portfolio through a combination of individual and banking sector-wide initiatives.
For the Economic perspective, Alpha Bank estimates the impact from climate scenarios in a similar fashion as in the Normative perspective.
The impact calculated covers both transition and physical risk, taking into account the long-term nature of specific physical risk events
(selection of scenario, use of relevant credit risk models to calculate impact), adopting the 1-year impact (2025) as Pillar 2 add-on hit, in line
with the horizon applicable for the economic perspective aligned to ECB’s supervisory ex pectations.
Additionally, regarding the climate risk impact on operational risk, the Group has adopted an AMA oriented quantification methodology with
the intention to introduce a more risk sensitive estimation of the internal operational risk capital. In this respect, data from the Operational
Risk Framework components (the operational risk events, the RCSA results and the Scenarios) are used in the capital calculations through a
specific internal statistical model. For ESG Risk purposes, the Group has developed operational risk ESG related scenarios and has flagged ESG
Risk-related operational risk events and RCSA risks accordingly. The abovementioned data is used in the model for capital calculation purposes.
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Using allocation techniques, the contribution of the ESG Risk factors to the Total Capital requirements is calculated. In addition to the above, a
long-term horizon (2050) analysis providing an additional Pillar 2 add-on (yet without leading to a capital add-on considering the P1 capital is
higher) has, also, been considered.
Regarding the impact of climate risks on business & strategic risk, the Bank performed an analysis in the economic and normative perspective,
to quantify the forgone interest income based on the reduced EIRs of sustainable financings that are assumed in order to maintain the
respective volumes and therefore cope with competition and the reduced net fee & commission income.
The resilience analysis has been performed by Alpha Bank, with reference date 31.12.2025.
Results
The results of the materiality assessment performed are illustrated under [SBM-3] Material impacts, risks and opportunities and their
interaction with strategy and business.
Transition to Net-Zero
As per previous references, Alpha Bank Group actively participates in the global effort to build a sustainable future for the economy and the
planet. In this context, the Bank joined the UN-convened Net Zero Banking Alliance (NZBA), committing to net zero greenhouse gas emissions
by 2050. This reflects the Group’s social responsibility, as a leading financial institution in Greece, to help mitigate climate change and drive the
transition to a Net-Zero economy. As part of its commitment to environmental stewardship, the Group focuses on reducing operational
emissions, supporting its Retail and Wholesale Customers transition to a low carbon economy, increasing awareness and foster sustainable
practices to the entire spectrum of financial and social activity.
Further, the Group continues to implement the ESG Client Engagement Process, additional details which may be found under [SBM-3] Material
impacts, risk and opportunies and their interacon with strategy and business model.
This has resulted in increased portfolio of green loans and investments, supporting projects that contribute to renewable energy and
sustainable economy. In line with the SFF and GBF, the Group allocates capital to Green and Social investments, with emphasis on the power
generation sector, buildings and transportation. Through sustainable financing, the Group aims to support the development of low-carbon
infrastructure and accelerate Greece’s transition to an environmentally sustainable and resilient econom y.
Taking the above into account, along with the lack of any significant risk impacting access to funding in the bond markets, the Group reflects
the trust of its counterparties, borrowers, and investors in its ability to adapt its strategy and business model to address climate change over
the short, medium, and long term.
[E1-2] Policies related to climate change mitigation and adaptation
The Group adopts a proactive approach to the management of ESG risks, with particular emphasis placed on risks arising from climate and
environmental change, which is already a key component of its Risk Management. Specifically, it aims to:
• Support Customers’ decarbonization and the alignment of their portfolio emissions with the objectives set in the Paris Agreem ent.
• Invest in activities dealing with climate change and reduction of environmental effects from the Group’s operation.
• Support the development of sustainable solutions for cities and communities.
The Policies included in this section relate to the Negative Impact on Climate Stability, the Climate Transition and Climate Physical Risks, as well
as Opportunities linked to Climate Change Mitigation and Climate Change Adaptation as per the Double Materiality Assessment conducted by
the Group in the reporting year.
Climate related, Environmental, Social and Governance Risk Management Policy on Group’s Business Lending
The Group is committed to providing sustainable finance and in this context has incorporated the “Climate related, Environmental, Social and
Governance Risk Management Policy on Group’s Business Lending” (hereinafter referred to as the “Policy”) in its exi sting Credit Risk
Management Framework and Credit Policy. The Policy presents the responsibilities and the approach followed in managing ESG risks in
business lending both in credit origination and monitoring process. The purpose of the Policy is:
• To serve as a brief declaration of the Group’s commitment to sustainable development and management of climate and ESG risks;
• To become the driver that enhances the continuous development of sustainable finance practices; and
• To provide the appropriate guidance on the way climate and ESG risks should be considered at all stages of the business lendi ng
credit process, i.e. during assessment, approval, origination and credit risk monitoring.
Key principles and requirements:
• Definition of critical industry sectors that are connected with potential climate and ESG risks. In particular, definition of the Exclusion
List, i.e., a list of activities that the Group does not finance, and the transition risk sensitive sector’s classification which is a
classification of economic activities for the assessment of the transition to a low-carbon economy.
• The applicable national and international laws and regulations on climate, environment, society and governance and relevant
standards established with the Policy.
• The definition and implementation of climate and ESG risks assessment and monitoring procedures including ESG assessment at
obligor, transaction and overall level in accordance with the provisions of the relevant Credit Policy Manuals, the due diligence
conduction, the guidelines on the “Environmental and Social Requirements” of the European Bank for Reconstruction and
Development (EBRD), as well as the national and EU laws and regulations.
• Monitor and Control of the ESG Obligor’s/ Project’s performance.
• Managing Obligor’s/ Project’s Non-Compliance with the Policy Rules and Standards.
• Internal and External Reporting
Among the main responsibilities of the Credit Control Business Area are to:
• Developing and updating the Policy in collaboration with the competent Units, taking into account the regulatory framework, t he
international best practices and any current developments.
• Monitoring the implementation of the Policy, conducting credit controls and notification of the Credit Risk Committee which i s
responsible for its approval, the General Manager – Chief Risk Officer (CRO), the Chief Risk Control Officer and Senior Management
on the significant arising issues.
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ESG in Loan Origination
In 2024, the Group enhanced its credit assessment process according to the “Climate related, Environmental, Social and Governance Risk
Management Policy on Group’s Business Lending”, “Retail Banking Credit Policy Small Businesses” and “Wholesale Banking Credit Policy”,
incorporating additional dimensions of climate related and governance risks. The main amendments concern ESG assessment, which is more
holistic and is carried out at obligor, transaction and overall level per transaction. More specifically:
• ESG assessment at obligor level is based on specific inter-banking client ESG questionnaires on a sectoral, cross sectoral or on a
simplified basis, completed by the Clients. The answered questionnaires are scored via internal rating models and the outcome of the
assessment may be Low, Medium or High ESG risk. The Bank has rolled out a bottom-up process, at the obligor level, which is used to
evaluate the performance of each obligor around ESG topics and better inform the credit origination processes in place. This process
embeds a materiality assessment, through which the Bank concluded environmental and social topics for several economic sectors in
its portfolio. Through the questionnaires climate-related information is captured (e.g., emissions data, energy consumption data
etc.).
• ESG assessment at transaction level, through Alpha Bank’s Sustainable Finance Framework Tool, concerns the activity for which the
Customer is applying or has received financing based on the information provided during the preparation of the credit request. The
outcome of this assessment may be “sustainable” or “non-sustainable” financing. Sustainable financings are further divided into
aligned or not aligned with the EU Taxonomy. Νon-sustainable financings are rated and classified as Low, Medium, or High ESG risk.
In case the transaction is non-sustainable Medium or High Risk and the request under consideration concerns new specific purpose
financing of an investment nature (i.e. project financing), an ESG due diligence (i.e. on-site visit by specialized technical advisors) is
carried out and a respective plan of corrective actions is drawn up with a specific implementation schedule on behalf of the
Customer, if needed. An additional functionality of the SFF Tool is the possibility for the user to attach documents that confirm the
Transaction Assessment Result. This is particularly relevant in the case of Sustainable transactions, since it ensures compliance with
the requirements of the Bank's Sustainable Finance Framework and prevents Greenwashing.
• ESG overall assessment which is a combination of the ESG assessment at obligor and transaction level. The outcome of this
assessment may be Low, Medium, High ESG risk outcome or Sustainable.
The Group has enhanced its due diligence process with respect to the assessment of its Customers’ ESG/climate risk profile, t hrough the
collection of relevant information. This effort aims to ensure obligors' compliance with the Group's Environmental and Social (E and S)
requirements. The Group aims to finance its counterparties’ green/sustainable transition both in the short-and in the long-term. In this respect
the Group collaborates with High-Risk Obligors to develop an action plan outlining a timeframe and appropriate mitigation measures, while in
the case of new lending investment nature Medium and High-Risk transactions an on-site visit is conducted by specialists. Also, with the aim to
mitigate reputational risks, the Group has designed a robust process that involves identifying and assessing the potential participation of its
Obligors in controversial activities. Additionally, as a mitigating action to physical risk impact, the mandatory property insurance securing new
financing that is provided to the Bank also includes the risk of flooding.
Reputational Risk Policy
The Group has developed the Reputational Risk Policy to effectively manage its reputational risk exposures, including reputational risk
exposures stemming from ESG factors. In this context, the processes that may arise are presented below: By financing Obligors who are
involved in Controversial Activities. This reputational risk exposure is assessed and is taken into account in the Credit Approval process. By
initiating new activities, such as Bond Issuing, Investment Banking activities, Public Offerings, Outsourcing Arrangements, new Suppliers, new
partners or step-ins, new investors or new services / fees charges to the Bank’s clientele. From existing activities, such as Obligors (regula r
review), existing Outsourcing Activities (annual review), existing Suppliers, etc.
Sustainable Finance Framework
Alpha Bank’s Sustainable Finance Framework (“SFF”) was developed in 2023 and sets out a series of approaches and procedures r equired for
classifying financing as sustainable. Specifically, the Sustainable Finance Framework stipulates the decision and classification process, that the
Group implements, to categorize its financial products or services as sustainable (i.e., green, or social). The SFF follows a set of globally
accepted industry guidelines, including: The Green Bond Principles (2021), the Green Loan Principles (2021), the Sustainability-Linked Loan
Principles (2021), the Social Bond Principles (2020), and the EU Taxonomy Climate Delegated Act (2021). The Bank aims at aligning the
framework with the requirements of the EU Taxonomy eligibility criteria to the extent possible; thus, it will keep monitoring any developments
of the Taxonomy regulation for the framework to remain up to date. The SFF is publicly available on Alpha Bank’s website.
Green Bond Framework
The Bank’s Green Bond Framework (GBF) was developed in 2025 and represents the governing document for the issuance of green b onds by
the Group, providing a structured and transparent approach to financing environmentally beneficial activities. Developed in alignment with the
ICMA Green Bond Principles (GBP), the GBF establishes a rigorous set of methodologies, eligibility criteria, and internal processes that ensure
the environmental integrity and credibility of all green financing activities carried out under it.
The GBF outlines the process for identifying, selecting, and categorizing eligible green projects and assets, with the aim of directing capital
towards initiatives that contribute meaningfully to the transition to a climate-neutral, resilient, and environmentally responsible economy.
Eligible categories include, among others, renewable energy, energy efficiency, green buildings, clean transportation and resource efficiency &
pollution control, in alignment with the Sustainable Finance Framework green theme. The Framework governance is supported by a dedicated
Working Group and specialized teams responsible for evaluating the suitability of each loan or investment included in the Green Bond
Portfolio. This evaluation process incorporates environmental due diligence, technical assessments, and verification of certifications or
performance indicators that demonstrate the project’s contribution to decarbonization and environmental sustainability.
Reporting is a key component of the Green Bond Framework and includes the annual Allocation and Impact Reports for as long as green bonds
remain outstanding.
The Green Bond Framework is published on the Group’s website and is periodically reviewed and updated to remain in line with evolving
European standards, , as well as with market expectations for sustainable finance.
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Exclusion list
As part of the aforementioned policies, the Group applies, maintains, and updates an exclusion list that determines specific activities, which
are not allowed to be financed. This is applicable to all business lending obligors across all geographies and industry sectors. The criteria for
exclusion span across various environmental and social matters. Specifically, the Group does not finance the following activities:
• The production of or trade in any product or activity deemed illegal under host country (i.e. national) laws or regulations or
international conventions and agreements or subject to international phase out or bans, such as PCBs, pharmaceuticals,
pesticides/herbicides and other hazardous substances, ozone-depleting substances, persistent organic pollutants, trade in wildlife or
production of or trade in wildlife products regulated under the Convention on International Trade in Endangered Species of Wild
Flora and Fauna (CITES), transboundary movements of waste prohibited under public international law.
• a) Activities of Defense Sector Groups in alignment with the “Defense Sector Financing Policy” that are:
o Involved in the development, production, trade, or maintenance of
▪ controversial weapons related activities;
▪ nuclear weapons related activities in violation of the International Non-Proliferation Treaty (“NPF”). Any kind of
support to activities related to nuclear weapons is not in the risk appetite of the Group and is prohibited from
any form of financing;
o listed under EU sanctions, UN Security Council sanctions, National Arms Embargoes, sanctions imposed by the US
Government Services, namely the Office of Foreign Assets Control of the US Department of the Treasury (OFAC), or the
United Kingdom, namely (His Majesty’s Treasury – HMT);
o exporting defense and security equipment to countries subject to EU / UN Security Council embargos and / or in violation
of EU export controls.
• b) The following categories which are out of the scope of the “Defense Sector Financing Policy”:
o The non-military use of goods and services, even when supplied to defense related entities.
o Munition retail stores.
o Groups of companies and/or entities involved in dual use goods that provide a declaration confirming that all supplied
goods and services are exclusively for civilian use (including but not limited to Civil Protection).
o Groups of companies and/or entities whose defense related activities account for less than 20% of total turnover for three
consecutive years, provided that they have not received any defense related financing from the Bank.
The Bank allows financing of Defense Sector Groups up to Euro 500 million, limited to conventional weapons related activities in the
scope of the “Defense Sector Financing Policy”.
• Production or trade in alcoholic beverages (excluding beer and wine) Tobacco, Gambling, Casinos and equivalent enterprises. T he
funding of these activities is permissible on a combined basis up to 5% of the total loan portfolio.
• Production or trade in radioactive materials. This does not apply to the purchase of medical equipment, quality control
(measurement) equipment and any equipment where the radioactive source is considered to be trivial and/or adequately shielded in
accordance with international practices.
• Forced evictions.
• New investments in thermal coal mining or coal-fired electricity generation capacity.
• Upstream oil exploration - extraction and production.
• Upstream oil development projects, except in rare and exceptional circumstances where the proceeds of the project exclusively
target the reduction of GHG emissions or flaring from existing producing fields.
• Activities involving force-feeding of ducks and geese.
• The keeping of animals for the primary purpose of fur production or any activities involving fur production.
• The manufacture, placing on the market and use of asbestos fibers and of articles and mixtures containing these fibers added
intentionally. This does not apply to purchase and use of bonded asbestos cement sheeting where the asbestos content is less than
20%.
• The export of mercury and mercury compounds and the manufacture, export and import of a large range of mercury-added
products.
• Activities prohibited by host country legislation or international conventions relating to the protection of biodiversity resources or
cultural heritage.
• Drift net fishing in the marine environment using nets in excess of 2.5 km in length.
• Shipment of oil or other hazardous substances in vessels, which do not comply with International Maritime Organization (ΙΜΟ)
requirements.
• Trade in goods without required export or import licenses or other evidence of authorization of transit from the relevant countries of
export, import and, if applicable, transit.
• Conversion of natural forests into plantation.
• Wholesale and retail trade of thermal coal.
• Construction of new nuclear power plants. The Group will continue to consider funding for safety improvements of operating plants
as well as for radioactive waste management and decommissioning of nuclear facilities.
• Any activity involving degradation, conversion or destruction of the UNESCO World Heritage Sites.
• Any activity involving significant degradation, conversion or destruction of the sites included in the Natura map.
• Health technology activities relevant to human cloning for research or therapeutic purposes and genetically modified
organisms/food.
• Clients who are involved in violations of human rights, according to the United Nations’ “Universal Declaration of Human Rights”.
The Group should apply the following exclusions, in addition to the Exclusion List:
• Production or activities involving harmful or exploitative forms of forced labor / harmful child labor;
• Commercial logging operations for use in primary tropical moist forest;
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• Production or trade in wood or other forestry products other than from sustainably managed forests.
Monitoring Process
The BoD supervises and approves the ESG objectives and commitments of the abovementioned policies, and it has the oversight of the Group
risk management framework. Within this context, the BoD reviews the risk management strategy, delegates authorities to Committees and
Senior Management for implementing the risk management strategy, reviews the overall risks assumed under the delegated authorities,
provides guidelines, and ratifies the Group’s risk appetite.
One of those committees is the Group Sustainability Committee (GSC) which was established in November 2021 to approve and oversee the
sustainability strategy and to steer all related initiatives. The Committee takes cognizance of and decides upon Sustainability and ESG-related
matters to ensure an internal governance framework that allows the Group to manage ESG risks and consider all sustainability topics. GSC
membership includes 5 General Managers as permanent members and additional members at the General Manager or senior executive level
could attend.
During 2025, the Committee convened 8 times, highlighting Management’s commitment to enhancing the Group’s sustainability pos ition. The
Group Sustainability Committee’s agenda covered a range of topics, including progress of the Group’s ESG Action Plan, ri sk identification and
materiality assessment of Climate Risk, the SFF operationalization, the GBF publication and operationalization, updated Policy documents, as
well as key disclosures and regulatory submissions. The role of the Group ESG Coordinator was also established, to lead sustainability
initiatives and steer operational teams on implementation.
Implementation of climate-related policies
In the context of ESG and Climate Risk Governance, Alpha Bank Group has implemented a comprehensive structure, addressing relevant
decision making and implementation at all levels, from the BoD down to the operational level.
The BoD approves and oversees the implementation of the Group’s strategic objectives, risk strategy, ESG strategy and interna l governance.
The overall Organizational Structure for supervising and managing the implementation of the climate-related objectives, strategy, and policies,
is presented in [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities and [SBM-2] Interests and
views of stakeholders.
With reference to the Climate related, ESG Risk Management Policy on Group’s Business Lending, Credit Control Business Area is responsible
among others of monitoring the implementation of the Policy, conducting credit controls and notification of the Credit Risk Committee, the
General Manager – Chief Risk Officer (CRO), the Chief Risk Control Officer and Senior Management on the significant arising issues;
Communicating with the competent Group Units to ensure the proper comprehension of the principles and rules set out in this Policy.
The Climate related, ESG Risk Management Policy on Group’s Business Lending is established according to the regulatory framew ork, including
but not limited to the Greek and EU legislation, the guidelines of the European Central Bank (ECB), of the European Banking Authority (EBA), as
well as other international guidelines and best practices.
Stakeholder engagement for policy setting and implementation
The development of the Group policies has been largely informed and shaped by the climate-related interests of stakeholders across the
Group’s value chain, as these were identified and assessed through direct and indirect engagement with a broad range of s takeholders.
Policies with relevance to external stakeholders are publicly available while policies with internal use are available to the Group’s intranet.
As previously mentioned, the Group has adopted policies to manage ESG risks, including climate change-related risks. However, policies are
not particularly dedicated to a specific area, as they are defined in ESRS (i.e. climate change mitigation/adaptation, energy efficiency,
renewable energy deployment, biodiversity and ecosystems and circular economy).
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[E1-3] Actions and resources in relation to climate change policies
Key actions in relation to climate change
From policies and pledges to action, Alpha Bank Group supports the decarbonization journey of its Customers and own operations across the markets it operates in. The following table presents how its pledged
actions are linked to time horizon, polices, value chain segment of the Group, the geographies, and stakeholders. Most actions have been taken so far at Alpha Bank S.A level, while subsidiaries are expected to
follow in the coming years.
Table 34 Key actions (existing and planned) in relation to climate change policies
List of actions
Time horizon
Expected outcome
Relation to policy objectives
/ targets (where relevant)
2025 Progress on
Action
Scope of Action
Completion year
Value Chain Segment
Geographical
boundaries
Affected Stakeholders
Upgrade lighting to LED
lighting throughout the
network of Branches
Completion year:
2028
Reduce the energy consumption and the
relevant emissions by at least 10%
comparing with the existing lighting
systems.
The expected reduction of electricity
consumption for lighting is 50%, which
corresponds to approximately 13%
reduction of the total energy
consumption of the relevant Branches,
improving at same time the Customer
Exeperience.
Energy saving affecting
energy footprint and target
setting
45 Branches
Own Operations
Greece: Branches
operated by Alpha
Bank SA
Employees/ Customers
Replace 85% of the
Bank’s fleet with electric
and/or plug-in and
hybrid vehicles
Completion year:
2025
Reduce emissions and lower fuel cost
25
.
• 2023: Average 110gr/km CO
2
• 2024: Average 74gr/km CO
2
• 2025: Average 70gr/km CO
2
Also, the required percentage of ¼ of
new leases with pollutant emissions
below 50gr CO
2
was also covered, as
defined by the new Climate Law.
Energy saving affecting
energy footprint and target
setting
Vehicles fleet renewed:
PHEV
26
69 total:
26- new leases
43- replacements
EV
27
7 (3 new leases, 4
replacements)
PETROL 3 (1 new lease,
2 replacements)
HEV
28
56 (2 new leases,
54 replacements )
TOTAL LEASES 135
Percentage of electric,
plug-in and hybrid
vehicles 97%
Own Operations
Greece: Alpha Bank
S.A. transportation
Employees
25
The following figures refer to Alpha Bank S.A.
26
Plug-In Hybrid Electric Vehicle
27
Electric Vehicle (EV)
28
Hybrid Electric Vehicle (HEV)
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Continue to procure
Certification of Origin
from renewable energy
systems for all our office
buildings, warehouses
and Branches
Ongoing
To compensate the 100% of the
emissions related to the operation of
our office buildings, warehouses and
Branches, taking advantage of
appropriate market solutions.
-
Alpha Bank S.A. has a
contractual agreement
for receiving
Certificates of Origin
from renewable energy
sources covering 100%
of its own electricity
consumption.
Additionally, in 2025
Alpha Bank London Ltd
and Acarta Construct
SRL received
Certification of Origin
from renewables for
their total electricity
consumption.
Own Operations
Alpha Bank S.A. and
subsidiaries operating
in buildings operated
by Alpha Bank S.A.
(Greece), Alpha Bank
London Ltd (UK) and
Acarta Construct SRL
(Romania).
Employees
Fossil Fuel- Limit
operational emissions,
enable the supply of low
carbon liquids and gases,
carbon, capture,
utilization and storage
technologies
Completion year:
2030
Eliminate the use of fossil fuel for
heating purposes
Replacement of oil / gas
burners with heat pumps
In 2025, 3 oil burners
were replaced in
Branches
29
due to the
upgrade of the air -
condition system.
Own Operations
Greece: office
buildings, warehouses
and Branches operated
by Alpha Bank SA
Society (local
environment),
Employees
Zero financing to new
investments in thermal
coal mining, upstream oil
exploration or coal-fire
Ongoing
No new financing volumes
No new investments to
sectors that may have a
negative impact on the
environment.
Downstream
Alpha Bank S.A.
Customers/ Society
Oil and Gas – Reduction
of financed emissions in
the sector.
Completion year:
2030
Achieve a 26% reduction in absolute
financed emissions from
2022 to 2030. The Bank’s target exceeds
the 23% reduction required by the IEA
NZE, reflecting the ambitious
decarbonization commitments of the
Bank’s key clients in the sector.
Achievement of Bank’s
Strategy:
Membership with NZBA and
PRB, compliance with EU
Green Deal, alignment with
EBA Guidelines
Monitoring the Oil and
Gas sector new
disbursements in
alignment with the
relevant risk indicators
established to
safeguard the progress
towards meeting the
target.
Downstream
Spanning the Group’s
geographical footprint
Customers/ Society/
Shareholders
Power generation -
Deployment of
renewable energy
technologies
Completion year:
2030
Target for Power sector is 132
kgCO2e/MWh, which represents a 41%
reduction in physical intensity from 2022
to 2030. The Bank’s target is below the
IEA NZE in 2030, reflecting the lower
starting point relative to the industry
average – driven by the high share of
Achievement of Bank’s
Strategy:
Membership with NZBA and
PRB, compliance with EU
Green Deal, alignment with
EBA Guidelines
Increase in Sustainable
Financings based on
Alpha Bank’s
Sustainable Finance
Framework
Downstream
Spanning the Group’s
geographical footprint
Customers/ Society/
Shareholders
29
This refers exclusively to Alpha Bank S.A.
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renewables in the Bank’s portfolio – and
the ambitious decarbonization
commitments of the Bank’s key clients.
Cement - Employ green
financing included in the
Bank's Sustainable
Finance Framework and
use regular engagement
with key sector clients on
decarbonization
opportunities
Completion year:
2030
584 kgCO2e/t Cementitious product,
which represents a 15% reduction in
physical intensity from 2022 to 2030.
The Bank’s target for 2030 is above the
IEA NZE pathway, reflecting the fact that
Cement is a hard-to-abate sector, with
limited cost-effective opportunities to
decarbonize to 2030 and much of the
abatement expected to occur after
2030. The Bank will continue to engage
with its key clients in the sector to
support their decarbonization efforts.
Achievement of Bank’s
Strategy:
Membership with NZBA and
PRB, compliance with EU
Green Deal, alignment with
EBA Guidelines
Application of Alpha
Bank’s Sustainable
Finance Framework to
support clients’
decarbonization efforts
and targets
Downstream
Spanning the Group’s
geographical footprint
Customers/ Society/
Shareholders
Iron and Steel - Employ
green financing included
in the Bank's Sustainable
Finance Framework and
use regular engagement
with key sector clients on
decarbonization
opportunities
Completion year:
2030
The Bank’s starting position in the Iron
and Steel sector is well below the IEA
NZE pathway, with a portfolio intensity
of 540kgCO2e/t Steel in 2022, compared
to the IEA level of 1,737 kgCO2e/t Steel.
This is because the Bank’s exposure in
the sector is primarily to secondary steel
producers. In this context, the Bank is
not setting a quantitative target for its
Iron and Steel portfolio. The Bank
remains committed to support its clients
in the sector decarbonize and will aim
for its emissions intensity to remain
below the IEA NZE pathway to 2030.
Achievement of Bank’s
Strategy:
Membership with NZBA and
PRB, compliance with EU
Green Deal, alignment with
EBA Guidelines.
Application of Alpha
Bank’s Sustainable
Finance Framework to
support clients’
decarbonization efforts
and targets
Downstream
Spanning the Group’s
geographical footprint
Customers/ Society/
Shareholders
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Green Bond Issuance
In October 2025 Alpha Bank successfully completed the pricing of a Green Senior Preferred Bond of Euro 500 million, attracting demand that
exceeded Euro 3 billion through an international book building process. Please refer to [ESRS 2] for more information.
ESG Academy
In 2025, Alpha Bank’s strategic commitment to sustainable growth remains extended, focusing strongly on empowering its People to unleash
their potential. Central to the Group’s Learning and Development capabilities is Alpha Bank’s learning ecosystem ACE “#together we grow”,
which was enriched with the design and launch of specialized Academies (Digital, ESG). Through the ESG Academy, the Bank aims to provide
awareness and training to its Employees on ESG and climate risks, aiming also to add the power of its brand name to the wider sustainability
transition effort. The ESG Academy is an ongoing action with no defined end date and is fully embedded in Alpha Bank’s Learni ng &
Development framework, following its launch in 2024 and implementation throughout 2025 and beyond. No exclusions apply to this action, as
all Employees of Alpha Bank are eligible to participate in ESG Academy training activities. The ESG Academy aims to cover the following
thematic areas:
Table 35 Thematic areas addressed through ESG Academy
Horizontal Awareness
Technical capabilities for ESG
• Introduction to ESG
• Health & Safety: Flood in the Building
• Health & Safety: Earthquake
• Introductory Training on Health & Safety in the Workplace
• Health & Safety at Work: We Act Responsibly, We Live Better
• ESG Risks and Opportunities
• Energy Saving Awareness
• Health & Safety: Fire Incident in the Building
• Nutrition as a Key Factor for Quality Sleep and Mental Balance
• Act on Climate | Climate Action (20 minutes)
• Building Well‑Being and Balance at Work
o
• Sustainable Finance Framework Operationalization
During 2025, 60% of workforce of Alpha Bank Greece participated in training organized by the ESG Academy, while over 74% of retail banking
business Employees followed dedicated ESG lessons. Employees across the Bank benefited from introductory eLearning courses on ESG
fundamentals and the ESG Risks and Opportunities.
A dedicated session titled “Introduction to Climate Risks” was delivered to Employees in Wholesale Banking and Wholesale Cred it, with the
participation of 260 individuals, further strengthening awareness and understanding of climate-related risks within core business and credit
functions. In addition, the Bank delivered targeted training to Wholesale Relationship Managers and Risk Professionals on integrating ESG
criteria into client assessments and the evaluation of sustainable finance transactions. The program enhanced staff capability to apply the ESG
process, use the relevant internal tools, and ensure consistent identification and classification of sustainable financing activities.
Furthermore, Alpha Bank fostered employee engagement in sustainability initiatives through its collaboration with “Do Good People”, an ESG-
focused digital platform that achieved notable recognition in Alpha Bank’s FinQuest competition in 2022. The Bank launched the program in
December 2025 and will continue with multiple participation cycles throughout 2026. This initiative complements the ESG Academy by
supporting the transition from ESG awareness to action and fostering sustainable behaviors within and beyond the workplace through
interactive challenges across ESG pillars.
Decarbonization of portfolio
Providing zero finance to new investments in thermal coal mining, upstream oil exploration or coal-fire is an existing and continuing
commitment for Alpha Bank. Alpha Bank has committed to employ green financing included in the Bank's Sustainable Finance Framework and
use regular engagement with key sector clients on decarbonization opportunities- please refer to [E1-1] “Transition Plan for Climate Change
Mitigation” for further details.
Decarbonization of own operations
Reduction of operating footprint: Regarding the decarbonization of the operational footprint of the Group, the actions mentioned on table 33
relate to the rational use of energy, the elimination of fossil fuel use and implementation of energy conservation and high energy efficiency
measures are foreseen. For example, in 2025 Alpha Bank S.A. replaced 19 old HVAC systems with new, high energy efficient equipment that
reduce significantly the final energy consumption, proceeded to the upgrade of lighting systems with LED luminaires throughout the network
of 45 Branches, used FSC MIX paper, where possible.
Transition to renewable energy: Alpha Bank S.A., Alpha Bank London Ltd, and Acarta Construct S.R.L. have annual contracts for the purchase
of electricity with Guarantees of Origin from renewable energy sources for their own operating premises (e.g. branches, office buildings,
warehouses, ATMs). These contracts also cover subsidiaries operating within Alpha Bank S.A. premises. Furthermore, Alpha Bank S.A. has
already operated a small photovoltaic system at one of its branches and is currently awaiting the issuance of permits for an additional 10 small
rooftop PV systems. In addition, Alpha Bank S.A. is exploring the potential installation of larger-scale photovoltaic systems.
Resources for implementation of actions
Alpha Bank Group acknowledges the importance of allocating appropriate financial and other resources to effectively implement its action
plans. The Group incurs operating (OpEx) and capital expenditures (CapEx) in connection with initiatives aimed at reducing emissions from its
business activities and its own operations. However, they are not presented in the statement as they are not considered significant.
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102 | ANNUAL FINANCIAL REPORT
[E1-4] Targets related to climate change mitigation and adaptation
The Group has established a set of KPIs for each of the environmental priority impact areas of its Strategy (Climate), to enable the
measurement of the overall performance and make the necessary corrective actions to achieve the strategic commitments and management
of its impacts, risks and opportunities related to climate change. One of the top commitments for the Group is to support Cus tomers’
decarbonization and align their portfolio emissions with the Paris Agreement. As part of this commitment the Group has set the target to lend
Euro 3.8 billion in sustainable disbursements during 2025-2027. The main focus is in the Power sector (solar, wind, grid upgrading, etc.),
buildings (energy efficiency, upgrades, heat insulation, certification) and transportation (electric vehicles, alternative fuels).
Table 36 Targets related to downstream activities
Target description
Target level
Absolute
/
Relative
Baseline
value
Baseline
Year
Target
Year
Scope
Progress in 2025
KPIs
3.8 billion to new
Sustainable
Financings
increasing target
by 2027
Euro 3.8 billion
Absolute
N/A
2025
2027
Banking
sector
activity,
Downstream
Alpha Bank
S.A.(Greece)
AB Cyprus
Euro 2.1 billion
(2,128.4 million)
New
financing
volumes
(in Euro
million)
Within the total
Sustainable
Financings,
achieve at least
Euro
2.6 billion to
Renewable
Energy Systems by
2026
(Target under
previous business
plan)
Euro 2.6 billion
Absolute
N/A
2024
2026
Banking
sector
activity,
Downstream
Alpha Bank
S.A.(Greece),
AB Cyprus
Euro 0.77 billion
(769.35 million)
New
financing
volumes
(in Euro
million)
Zero financing to
new investments
in thermal coal
mining, upstream
oil
exploration or
coal-fired
electricity
generation
0 million
Absolute
Euro 0
million
2023
Ongoing
Banking
sector
activity,
Downstream,
Alpha Bank
S.A.(Greece)
Euro 0 million
New
financing
volumes (in
Euro million)
Financed
emissions targets:
Power Generation
132 kgCO
2
eq /
MWh
Relative
223 kgCO
2
eq
/ MWh
2022
2030
Banking
sector
activity,
Downstream,
Alpha Bank
S.A.(Greece)
142 kgCO
2
eq / MWh
(-36.4% compared to
baseline value)
physical
intensity
metric
(kgCO
2
eq /
MWh)
Financed
emissions targets:
Oil and Gas
74 Indexed
tCO2e of 2022
= 100 tCO
2
eq
Absolute
100 Indexed
tCO
2
eq of
2022 = 100
tCO2e
2022
2030
Banking
sector
activity,
Downstream,
Alpha Bank
S.A.(Greece)
104.3 Indexed tCO2eq of
2022 = 100 tCO2eq
(4.3% compared to baseline
value)
absolute
emissions
metric
(Indexed
tCO2e of
2022 = 100)
Financed
emissions targets:
Cement
584 kgCO
2
eq /
t Cementitious
product -
intensity
Relative
687 kgCO
2
eq
/ t
Cementitious
product -
intensity
2022
2030
Banking
sector
activity,
Downstream,
Alpha Bank
S.A.(Greece)
623 kgCO2eq / t
Cementitious product –
intensity
(-9.4% compared to baseline
value)
physical
intensity
metric
(kgCO
2
eq / t
Cementitious
product –
intensity)
Financed
emissions targets:
Iron and Steel
Intensity of
portfolio to
remain below
the reference
pathway
Relative
540 kgCO
2
eq
/ t Steel -
intensity of
portfolio
2022
2030
Banking
sector
activity,
Downstream,
Alpha Bank
S.A.(Greece)
390 kgCO2eq / t Steel -
intensity of portfolio
(-27.8% compared to
baseline value)
physical
intensity
metric
(kgCO
2
eq / t
Steel -
intensity of
portfolio)
Total reduction target for Scope 3 emissions has not been disclosed as a cumulative figure, as financed emission targets have only been set for
the specific four sectors listed on “Table 36”.
Target setting process
As highlighted in [SBM-2] Interests and views of stakeholders, multiple stakeholder input has been taken into consideration in shaping each of
Targets set by the Group. In response to these expectations, Alpha Bank Group has taken concrete steps to deliver on its climate ambitions. It
is noted that there are no changes in targets and corresponding metrics to report.
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Financed Emissions Targets are aligned with the Paris agreement and the UN Sustainable Development Goals and are based on conclusive
scientific evidence. Specifically, with reference to the selected NZBA carbon-intensive sectors the Group has deployed science-based
International Energy Agency Net Zero Emissions by 2050 (IEA NZE) scenario as its benchmark pathway. Worth mentioning that the baseline
measurement relied on the GHG emissions of its borrowers or investee companies and followed the Global Greenhouse Gas (GHG) Accounting
and Reporting Standard for the Financial Industry developed by the PCAF. It is noted that the GHG emission targets have not been externally
assured. Additional information on the climate analysis is provided in [IRO-1] Descripon of the process to idenfy and assess material impacts,
risks and opportunies and the [E1-1] “Transion Plan for Climate Change migaon”.
The GHG emission reduction targets represent gross targets, meaning that GHG removals, carbon credits or avoided emissions are not taken
into account as a means of achieving the GHG emission reduction targets.
Due to the level of data availability, GHG emission in 2022 were set as baseline, regarding the Bank’s portfolio related emissions. Another
reason was that the Bank improved in 2022 the coverage and data quality of its financed emissions.
The Group has not set GHG emission reduction targets for the year 2030 regarding its own operations. However, is in the process of
developing targets regarding Scope 1,2 for the mid-term (2026-2030) and long-term time horizon (>2030). Additionally, the Bank has set
though GHG emission reduction targets for 2025 as disclosed in the table below:
Table 37 GHG emission reduction targets related to own operations
Target description
Target level
Absolute /
Relative
Baseline
value
Baseline
Year
Target
Year
Scope
Progress in 2025
KPIs
Reduction of Scope
1 and 2 GHG
emissions by 20%
until 2025,
comparing to 2022
N/A
Absolute
1,473
2022
2025
Own operations
Alpha Bank
S.A.(Greece)
4,400
Scope 1 GHG
Emissions
(tn CO
2
eq.)
N/A
Absolute
18,419
2022
2025
7,117
Scope 2 GHG
Emissions
Location-based
(tn CO
2
eq.)
15,914
Absolute
19,892
2022
2025
11,517(-42%
compared to
baseline value)
Scope 1 and 2
Risk Appetite Framework
The Group has already incorporated in its Risk Appetite Framework (RAF) a set of quantitative indicators and qualitative commitments
regarding climate risks. In terms of quantitative indicators, the Group has defined several C&E indicators designed to improve the sustainability
of the portfolio and mitigate potential exposure to risk, and that are incorporated in Risk Appetite Framework as supporting elements.
Additionally, limits have been established in part of the existing C&E indicators. The indicators cover the area of business planning and green
financing, collateral vulnerability to physical and transition risk, financial activity vulnerability to physical risk and sustainable investing. The
Group monitors its Risk Inventory to provide a comprehensive overview of the enhancements and progress achieved in climate-related risks in
the Bank’s Risk Registry. More specifically, the following Key Risk Indicators with thresholds are included in the Risk Appetite Framework (RAF),
considering the materiality assessment outcomes as well as the target-setting exercise and sector-specific commitments.
Table 38 the Risk Appetite Framework (RAF) indicators
Risk Category
Perimeter
RAF Indicator
Transition Risk
Credit Risk
Alpha Bank S.A.
Exposures to sectors considered more sensitive to transition risk
Credit Risk
Alpha Bank S.A.
New originations to sectors considered more sensitive to transition risk
Credit Risk
Alpha Bank S.A.
Exposures of Mortgage Portfolio with EPC label >= D
Credit Risk
Alpha Bank S.A.
New Originations in Mortgage Portfolio with EPC
label <= D
Physical Risk
Credit Risk
Alpha Bank S.A.
Exposures sensitive to impact from climate change physical events, specific sectors
Credit Risk
Alpha Bank S.A.
Real Estate Exposures sensitive to impact from climate change physical events
Transition Risk
Business and Strategic
Alpha Bank S.A.
Net interest income from sectors considered more sensitive to transition risk
Transition Risk
Market Risk
Alpha Bank S.A.
Bank’s ESG-related investment assets (such as Green Bonds) (in Euro million). /
Total Face Value of Bonds in AC, FVOCI and FVPL (non-TRD) portfolios classified as
Sustainable according to Bloomberg data
Physical Risk,
Social Risk,
Governance Risk
Operational Risk
Alpha Bank Services
and Holdings S.A.
Group
ESG Risk Losses
Environmental Risk,
Social Risk,
Governance Risk
Reputational Risk
Alpha Bank Services
and Holdings S.A.
Group
ESG Rating
Transition Risk
Business and Strategic
Alpha Bank S.A.
Physical intensity of new and existing clients in the Power sector, kgCO2e/MWh
Transition Risk
Business and Strategic
Alpha Bank S.A.
Physical intensity of new and existing clients in the Cement sector, kgCO2e/t
cement
Transition Risk
Business and Strategic
Alpha Bank S.A.
Physical intensity of new and existing clients in the Iron and Steel sector, kgCO2e/t
steel
Transition Risk
Business and Strategic
Alpha Bank S.A.
Oil and Gas refining drawn exposure, EUR million
Transition Risk
Business and Strategic
Alpha Bank S.A.
Change in % of exposure with 1.5ºC aligned climate targets for each priority sector
[E1-5] Energy consumption and mix
The Group recognizes that energy consumption for own operations is generating emissions that are directly contributing to climate change and
therefore need to be mitigated. It is also recognized that achieving the net zero target means that the Group will need to minimize energy
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
104 | ANNUAL FINANCIAL REPORT
consumption by implementing soft and hard measures. The Group focuses on the rational use of energy; the energy conservation by applying
relevant measures; and the use of high energy efficacy buildings’ equipment and cars. Moreover, where feasible the Group addresses any
residual emissions through Certifications of Origins or the procurement of energy from renewable energy sources. Since 2024 the Energy
Management System of Alpha Bank is certified against ISO 50001:2018, while its Environmental Management systems is verified from an
accredited external body against EMAS (Eco-Management and Audit Scheme)
30
. The Group is using the following consumption metrics to track
and assess effectiveness towards reducing operational emissions.
Table 39 Energy Consumption and mix
Energy consumption and mix
2024
2025
(1) Fuel consumption from coal and coal products (MWh)
0
0
(2) Fuel consumption from crude oil and petroleum products (MWh)
5,442
18,760
(3) Fuel consumption from natural gas (MWh)
5,448
7,683
(4) Fuel consumption from other fossil sources (MWh)
2.78
0
(5) Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil
sources (MWh)
11,328
30,522
(6) Total fossil energy consumption (MWh) (calculated as the sum of lines 1 to 5)
22,220
56,966
Share of fossil sources in total energy consumption (%)
33.0%
61.27%
(7) Consumption from nuclear sources (MWh)
2,194
776
Share of consumption from nuclear sources in total energy consumption (%)
3.3%
0.83%
(8) Fuel consumption from renewable sources, including biomass (also comprising industrial
and municipal waste of biologic origin, biogas, renewable hydrogen, etc.) (MWh)
4
590
(9) Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable
sources (MWh)
42,903
34,645
(10) The consumption of self-generated non-fuel renewable energy (MWh)
-
-
(11) Total renewable energy consumption (MWh) (calculated as the sum of lines 8 to 10
42,907
35,235
Share of renewable sources in total energy consumption (%)
63.7%
37.90%
Total energy consumption (MWh) (calculated as the sum of lines 6, 7 and 11)
67,321
92,977
In 2025, Alpha Bank activated a pilot small-scale flat roof PV system at one branch in Athens, Greece, which generated 15.28 MWh of
electricity. In 2026, the Bank expects to activate 10 additional small-scale flat roof PV systems. The Group will further explore opportunities to
expand PV installations, focusing on reducing both the overall emissions balance and operational costs.
Energy related calculations and methodologies
Almost all data collected for Alpha Bank Group refers to the period of January to September/October 2025. Consumption for 12-month period
was derived for all data as following:
• The annual electricity consumption was derived from the actual bills received. For the period that no actual was available, data from
previous corresponding period were used.
• For Alpha Bank London Ltd, electricity consumption has been estimated proportionally to its surface area from actual data.
Alpha Bank S.A. has an annual contract for purchasing electricity for its own operating premises (e.g. branches, office buildings, warehouses,
ATMs) and hence has purchased Guarantees of Origin for the total electricity consumption of Alpha Bank S.A. and number of subsidiaries
operating to these premises – buildings. Additionally, Alpha Bank London Ltd and Acarta Construct SRL have received Certification of Origins
from renewable energy sources for their total electricity consumed in 2025.
Energy intensity
The high climate impact sector used to calculate the energy intensity figure is L68 (Real Estate activities). The cumulative energy consumption
from the aforementioned entities is 42,208 MWh. The revenue associated with real estate operations is Euro 18.4 million and is included in the
Group’s financial statements by referring to the following lines: Income from leasing of investment properties; Income from services relating to
investment properties; Other income – Rental income from properties other than investment properties.
Therefore, the energy intensity associated with activities in high climate impact sectors is 0.00229MWh/Euro net revenue. The relevant values
for 2024 are: the cumulative energy consumption is 29,939 MWh, the revenue is Euro 12.3 million and the energy intensity is
0.00243MWh/Euro. It is noted that the energy intensity for prior reporting year has been restated due to methodological amendments.
The above metrics have not been validated by an external body.
30
https://green-forum.ec.europa.eu/green-business/emas_en
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105 | ANNUAL FINANCIAL REPORT
[E1-6] Gross Scopes 1, 2, 3 and Total GHG emissions
The measurement, continuous monitoring, and effective reporting of carbon emissions is a key priority for the Group and constitutes a critical
and objective means for assessing its performance and effectiveness against its climate commitments. By the time of reporting, 2025 Gross
Scopes 1, 2, 3 and Total GHG emissions have not been validated by an external body.
Table 40 Gross Scopes 1, 2, 3 and Total GHG emissions
Gross Emissions
2024
2025
Scope 1
Gross Scope 1 GHG emissions (in metric tons of CO
2
eq)
3,252
6,913
Share of Scope 1 GHG emissions from regulated emission trading schemes (%)
No emissions from regulated
emission trading schemes
No emissions from regulated
emission trading schemes
Scope 2
Gross Scope 2 GHG location-based emissions (in metric tons of CO
2
eq)
27,963
18,030
Gross Scope 2 GHG market-based emissions (in metric tons of CO
2
eq)
19,702
10,527
Share of contractual instruments used for sale and purchase of energy bundled
with attributes about energy generation in relation to Scope 2 GHG emissions (%)
Only certifications of Origins are
foreseen
Only certifications of Origins are
foreseen
Share of contractual instruments used for sale and purchase of unbundled energy
attribute claims in relation to Scope 2 GHG emissions (%)
Only certifications of Origins are
foreseen
Only certifications of Origins are
foreseen
Scope 3
Gross Scope 3 GHG emissions for each significant category (in metric tons of
CO
2
eq)- (Investments)
26,464,149
24,156,058
Share of emissions calculated using primary data obtained from suppliers or
other value chain partners (i.e. obligors) (%)
32.9%
12.8%
Totals
Total GHG emissions with location-based Scope 2 (in metric tons of CO
2
eq)
26,560,666
24,255,539
Total GHG emissions with market-based Scope 2 (in metric tons of CO
2
eq)
26,552,405
24,248,036
Table 41 Gross GHG Emissions
Emissions category
Gross emissions (tCO
2
eq)
2024
2025
Scope 1 emissions
3,252
6,913
Stationary combustion (in metric tons of CO
2
eq)
1,307
2,404
Mobile combustion (in metric tons of CO
2
eq)
1,342
4,142
Fugitive emissions (in metric tons of CO
2
eq)
604
367
Scope 2 emissions location-based
27,963
18,030
Scope 2 emissions market-based
19,702
10,527
Total Scope 1 + 2 emissions (Scope 2 location-based)
31,215
24,944
Total Scope 1 + 2 emissions (Scope 2 market-based)
22,954
17,440
Scope 3 emissions (excluding category 15)
65,302
74,538
Purchased goods and services
9,453
16,224
Capital goods
-
1,059
Fuels and energy related activities
2,097
5,263
Upstream transportation and distribution
343
351
Downstream transportation and distribution
5
5
Waste generation
39
95
Business travel
542
220
Employee commuting
3,338
3,819
Downstream leased assets
49,486
47,502
Investments
26,464,149
24,156,058
Scope 1, Scope 2 (location-based) and Scope 3 (excl. category 15) emissions
96,543
99,481
Scope 3 emissions (including category 15)
26,529,451
24,230,596
As shown, in the table above, the most significant category of Scope 3 GHG emissions (accounting for 99.7% of total Scope 3 emissions), based
on the Magnitude of the estimated GHG emissions is cat.15 Investments (Financed emissions).
The Group acknowledges that with the increase in demands for full carbon footprint measurements from its Customers in the coming years,
the absolute values (absolute values in tnCO
2
eq) of financed emissions may be materially affected in the coming years as well.
GHG emissions calculation and methodologies used
There are no significant changes compared to the previous year regarding the definition of what is considered upstream and downstream
value chain. However, changes in the reported Scope 1, 2 GHG emissions compared to previous year (compared to “2024 Sustai nability
Statement”, are attributed to the fact that certain subsidiaries were sold in 2025 (please refer to the Section: Assets Held for sale of the
Financial Statements).
Scope 1, 2 GHG emissions calculation and methodologies used
The GHG emissions of 2025 have been estimated with the following assumptions:
• Diesel consumption for generators and/or heating boilers for the period January 2025 – December 2025 was calculated using an
activity-based approach based on primary fuel consumption data, applying national emission factors (YPEN) and IPCC Guidelines.
• Natural gas consumption for the period January 2025 – December 2025 was calculated using an activity-based approach based on
supplier invoices, applying national CO₂ emission factors (YPEN) and IPCC Guidelines for CH₄ and N₂O.
• Fuel consumption for corporate vehicles for the period January 2025 – December 2025 was calculated using primary fuel data where
available or, alternatively, estimated based on mileage and average fuel consumption factors (DEFRA), applying emission facto rs
from the National Inventory System and IPCC Guidelines.
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• Electricity consumptions, period: 1 calendar year, as given from bills issued from Jan 2025 – Dec2025.
• Conversion coefficients (kWh to tCO
2
eq): Both for location and market-based calculation the appropriate values were used (DAPEEP
2024, TSOC 2024, EEA 2024).
• Refrigerants: emissions are attributed to the refrigerants’ losses of 2024.
Scope 3 GHG emissions calculation and methodologies used
Two specific approaches were used to calculate direct and indirect emissions:
i) Activity-Data Based Approach: Emissions were calculated using the activity data related to the service or product (e.g. quantities,
transport work, energy consumption), and
ii) Spend-Based Approach: Emissions were derived from the economic value of the service or product, correlating with the costs
incurred by the entity. This uses Input-Output tables for (EU-27), allocating national GHG emissions to economic sectors based on
economic flows.
List of GHG emissions included in the inventory and exclusions and reporting boundaries
The Group is currently at advanced state of a more detailed measurement of its Scope 3 financed emissions across asset classes and sectors,
following the Global Greenhouse Gas (GHG) Accounting and Reporting Standard for the Financial Industry developed by the PCAF. The PCAF
builds upon the GHG protocol guidance to calculate Scope 3, category 15 (see Table 41 Scope 3 Categories), emissions to provide asset class
specific calculation approaches with guidance on financial or operational control approaches, attribution factors, emissions factors and data
sourcing hierarchies.
For the following categories of Scope 3, an explanation of calculation methods for estimating the GHG emissions is provided:
Category 1: Purchased goods and services
This category includes, analyzes, and estimates Scope 3 emissions arising from the use of products (e.g., paper, toner, furniture, electronic
equipment), goods (e.g., water), and services (e.g., equipment maintenance, external mail, security, cleaning, legal, consulting, and other
services). For the Bank and its subsidiaries, indirect emissions are calculated using either: i) Activity-based approach – using the carbon
emission factors and physical quantities of the goods, or ii) Spend-based approach – applying environmental emission factors for the relevant
economic sector, based on total Scope 1, 2, and 3 emissions per € of turnover, as well as the Bank’s/subsidiary’s related exp enses. Carbon
emission factors primarily come from the UK Government GHG Conversion Factors for Company Reporting (DEFRA & BEIS, full set for advanced
users) and other relevant sources, such as industry associations (e.g., European Printing Ink Association – EuPIA). If primary data on product or
goods quantities (e.g., paper purchases in kg, water consumption in m³) are not available, emissions are estimated using the associated
expenditure recorded in the balance sheet.
Category 2: Capital goods
In this category are included the purchase of goods with a long useful life, which are used for the production of products or services. In the
case of the Bank and its subsidiaries, this category includes, based on the balance sheet (“Other expenses”), cap ital expenditures for
equipment, machinery, or infrastructure.
Category 3: Fuel-and-energy-related activities (not included in Scope 1 or 2)
Category 3 includes the analysis and assessment of emissions associated with the extraction, production, and transportation of energy
products procured by the organization, as well as losses in electricity transmission and distribution networks. These emissions are not included
in Scope 1 and 2 emissions, but they cover all types of conventional fuels used, such as natural gas, oil, gasoline, and electricity. To calculate
indirect emissions, carbon footprint conversion factors are applied, along with the physical quantities of energy products consumed.
Specifically, for all fuels except electricity, the carbon footprint conversion factors (from well-to-tank) are taken from the "UK Government
GHG Conversion Factors for Company Reporting" (full set for advanced users), developed by the UK Department for Environment, Food and
Rural Affairs (DEFRA) and the Department for Business, Energy, and Industrial Strategy (BIES). For electricity, a separate carbon footprint
conversion factor per kWh is used, based on data from the Carbon Data Intelligence database, which contains both national and European
datasets. For the subcategory “TD losses”, which corresponds to emissions from losses in the electricity transmission and distribution network,
the emission factor used was based on data from Carbon Footprint Ltd. For the subcategory “WTT losses” that corresponds to electricity
production, the emission factor used was based on data from Carbon Footprint Ltd. It is noted that for companies which have an active
contract with an electricity provider, taking provision for providing Guarantees of Origins from renewable energy sources, “WTT losses” has
not been calculated.
Fuels and electricity quantities used to calculate emissions are provided through bills or invoices.
Category 4: Upstream transportation and distribution
This category accounts for emissions arising from the transportation and handling of goods to and from the facilities of the entity concerned
through vehicle fleets owned by external suppliers. In the case of the Bank, this category includes emissions from the transportation of goods
purchased from suppliers where transportation costs were not incorporated into the sales prices of the products, the transportation of
materials to and from the Bank’s warehouses carried out by partner companies, as well as the transportation of items resulting from mergers
of departments and branches. This category is not typically encountered among the activities of the Bank’s subsidiaries.
Category 5: Waste generated in operations
The methodology used for the emissions calculation is based on spend-based method and average-data method. Scope 3 emissions from
waste generated in operations include solid wastes produced by Employees and sent to landfill, as well as recycled materials. Activity data for
solid wastes produced in Group’s premises are calculated based on specific assumptions (e.g. by using the indicator of solid wastes produced
per employee in the tertiary sector provided by Eurostat and taking into account the number of Employees who were exempted from
teleworking. Furthermore, for the recycled materials the expenses made for their transportation have been used as activity data, which has
been derived from invoices. DEFRA emission factors per type of material wasted and treated are also used to calculate a weighted emission
factor for solid wastes on the basis of a typical composition of the produced mixture (based on an EPA’s study).
Category 6: Business Travel
The methodology used for the emissions calculation is based on actual data. Scope 3 emissions are derived from business travel comprises air,
sea, and land transportation of Employees for business-related activities, as well as accommodation in hotels during these trips. All relevant
information is provided by the collaborating travel agencies. Defra 2025 emission factors have been applied.
Category 7: Employee commuting
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
107 | ANNUAL FINANCIAL REPORT
This category concerns emissions arising from Employees’ commuting to and from the Bank using various modes of transport. For the Bank,
due to the large number of Employees, emissions are estimated based on expert judgement and standard commuting profiles, taking into
account the distribution of transport modes, average travel distances, and the extent of teleworking. For subsidiaries, emissions are calculated
through employee questionnaires, which collect key information such as the mode of transport, travel distance, commuting frequency, and
the number of days of on-site presence. Emissions from vehicles leased by the Bank and provided to Employees are excluded, as they are
accounted for under Scope 1. Scope 3 emissions are calculated using an activity-based approach. Specifically, total annual transport work is
calculated per travel mode and multiplied by DEFRA & BEIS conversion factors for all means of transport, except for public transport, for which
national emission factors based on OASA and STASY data are applied. The calculation also takes into account the avoided transport work
resulting from the implementation of teleworking among the Group’s Employees.
Category 8: Upstream leased assets
This category does not apply to Alpha Bank because emissions from the operation of leased office buildings are included under scopes 1 and 2.
Category 9: Downstream transportation and distribution
Category 9 includes indirect greenhouse gas (GHG) emissions (Scope 3) arising from the transportation and distribution of products after the
point of sale, where such transportation is not performed or directly controlled by the organization. It relates to emissions from the dispatch of
correspondence to various geographical regions in Greece (Attica, the rest of mainland Greece, and the islands), calculated based on activity
data and transportation parameters (mode of transport and distance). The Bank classifies emissions from the dispatch of correspondence
under Category 1.
Category 10: Processing of sold products
The Group, as a financial service provider, does not sell products, only services that do not need processing. As a result, emissions in this
category are not relevant.
Category 11: Use of sold products
The Group offers only services to its clients and does not sell products that lead to emissions when used. Τherefore, use of the sold products
does not have an impact and does not represent position in the Group’s carbon footprint.
Category 12: End of life treatment of sold products
The Group offers only services to its clients and does not sell products that lead to emissions when disposed. Τhe end-of-life treatment of sold
products does not represent a significant position in the Group’s carbon footprint.
Category 13: Downstream leased assets
This category includes, analyzes, and estimates Scope 3 emissions arising from the operation of assets owned by the company (acting as lessor)
and leased to third parties during the reporting year, which are not already included in Scope 1 or Scope 2. Emissions from the leased assets
(e.g., real estate, equipment, etc.) are considered. For the relevant calculations, a spend-based approach is applied, using environmental
emission factors corresponding to the economic factors of the various subcategories of loans and investments.
Category 14: Franchises
This category is not relevant as the Group has no Franchises.
Category 15: Investments (Financed Emissions)
In order to align its portfolio with the Paris Agreement climate objectives, the Group is carrying out a full measurement of its financed
emissions, covering investment and lending products of its corporate portfolio across all the sectors it finances, based on the GHG emissions of
its borrowers or investee companies. To measure its financed emissions, the Bank follows the Global Greenhouse Gas Accounting and
Reporting Standard for the Financial Industry developed by the PCAF (version Nov. 2021). PCAF builds upon the GHG Protocol Corporate Value
Chain (Scope 3) emissions – Investments (Category 15), to provide asset class specific calculation approaches. In this context, the asset class
coverage includes Listed and Unlisted Equity, Corporate Bonds, Corporate Loans, Commercial Real Estate (CRE), Mortgages, Motor Vehicle
loans, Sovereign Debt and Project Finance. For the purposes of the financed emissions measurement, the counterparty NACE sector allocation
was identified and GHG financed emissions calculated for Scope 1, Scope 2 and Scope 3 emissions (in tons of CO2 equivalent), depending on
availability of information. Financed emissions have been measured by using primary data % (e.g., reported emissions) for the 12.8% of the
portfolio (in terms of financed emissions), whereas for the remainder of the portfolio (i.e., 87.2 %), financed emissions have been estimated by
using proxy data (e.g., EEIO). To the extent GHG emissions, activity or financial data were not available on behalf of the counterparties for
2024, the measurement for the financed emissions was based on data for 2023. Bank exposure to each counterparty corresponded to end of
2025. The Group’s category 15 emissions include the emissions of all the Banks' subsidiaries, JVs, and associates. Given that the Bank has no
operational control over JVs and associates, Scopes 1, 2 and 3 of these entities are included in the Group’s carbon footprint under Scope 3
category 15, as these entities are considered investees, following the PCAF methodology
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108 | ANNUAL FINANCIAL REPORT
GHG emissions intensity
Table 42 GHG emissions intensity (total GHG emissions per net revenue)
2025 GHG emissions intensity (total GHG emissions per net revenue (tn CO
2
e/Euro net revenue).
Location -based
Market-based
2025
2025
0.011
0.011
For FY24 GHG intensity was 0.012 for both location-based and market-based.
Table 43 Net Revenue Amounts for GHG intensity (in Euro)
2025 Net Revenue Amounts (in Euro)
Net revenue used to calculate GHG intensity (in Euro)
31
2,184,362,000
[E1-9] Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Anticipated Financial Effect
For information regarding the anticipated financial effects from material Physical and Transition risks, please refer to SBM-3.
Real Estate Assets Energy Efficiency
The following tables illustrate the gross carrying amount of loans collateralized by commercial & residential immovable property per energy
efficiency class (actual) and energy efficiency consumption (estimated & actual) accordingly, at Group level.
Table 44 Gross carrying amount of loans collateralized by commercial & residential immovable property per Actual EPC
Level of energy efficiency (EPC label of collateral)
32
Total gross carrying amount (in Euro million)
33
A
371
B
205
C
372
D
246
E
90
F
41
G
92
Table 451 Gross carrying amount of loans collateralized by commercial & residential immovable property per Energy
Efficiency Consumption (Estimated and Actual)
Level of energy efficiency (EP score in kWh/m²)
34
Total gross carrying amount (in Euro million)
0; <= 100
1,101
> 100; <= 200
4,239
> 200; <= 300
2,237
> 300; <= 400
1,716
> 400; <= 500
346
> 500
1,315
ESRS E4 – BIODIVERSITY AND ECOSYSTEMS
[E4-1] Transition plan and consideration of biodiversity and ecosystems in strategy and business model
Resilience Analysis
Scope & Methodology
The Group has performed a resilience analysis to assess biodiversity and ecosystem risks within its portfolio, as described under [E4.IRO-1]
“Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks, dependencies and
opportunities”. Regarding nature risks and in alignment with its materiality assessment the Bank has run multiple long-term nature scenarios
for credit risk. The methodology uses the GLOBIO model to assess the dependency component of the Bank’s counterparties (outside-in) and
estimates counterparties’ land usage reduction costs for the impact component (inside-out).
The dependency component is estimated under two Shared Socioeconomic Pathways (SSPs) with corresponding Representative
Concentration Pathways (RCPs) based on the Mean Species Abundance (MSA) index. This results in two global scenarios: Sustainability (SSP1
× RCP2.6) and Fossil-fueled Development (SSP5 × RCP8.5). Changes in the MSA index are subsequently translated into Probability of Default
(PD) impacts.
31
Total Income from banking and investment property management as included in the financial statements.
32
Source: Pillar III Disclosures
33
Perimeter: Sum of collateralized loans commercial immovable property and of residential immovable property, Actual EPC, Group Perimeter
34
Source: Pillar III Disclosures
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The impact component is estimated by leveraging Land usage intensity based on the SBTN 2030/2050 target under two scenarios i.e. 'Baseline'
and a 'Stressed' scenarios'. The 'Baseline scenario' reflects the most likely macroeconomic trajectory under current policies and prevailing
market conditions, assuming no major shocks or structural breaks, based on the 'NGFS NDC scenario'. While the 'Stressed scenario' represents
the future pathway associated with the highest environmental transition risk costs based on the 'NGFS Delayed transition scenario. 2025 is
considered the starting year for the reduction of absolute land footprint.
Results
The results of the materiality assessment performed are illustrated under [SBM-3] Material impacts, risks and opportunities and their
interaction with strategy and business.
Stakeholder Involvement
Alpha Bank Group proactively engages with all stakeholders to address biodiversity and ecosystem preservation, aligning its approach with
supervisory expectations, regulatory requirements, and evolving best practices, including the development of metrics, targets, and goals.
Biodiversity and ecosystems preservation and restoration is considered an emerging topic in the agenda of the Bank’s Clients with more
prominent impacts recognized in the long-term time-horizon. Regarding shareholder feedback, no specific biodiversity considerations have
been received to date. The Group’s approach in this area is primarily guided by legal and regulatory frameworks and its commitment to long-
term environmental stewardship.
In addition, for the purposes of the Double Materiality Assessment the Group leveraged its existing stakeholder engagement output (i.e.
existing employee surveys, investor and client and market feedback, etc.) to identify potentially additional priority topics coming from its
stakeholders. For further information on the Group’s overall stakeholder engagement process and involvement please refer to [SBM-2]
Interests and views of stakeholders.
[E4.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model
The Group has not identified any actual and potential impacts on biodiversity and ecosystems either on their own operational sites or sites
under their operational control, nor they have specified any activities negatively affecting biodiversity sensitive areas and affect threatened
species. Specifically, there are no material negative impacts regarding land degradation, desertification or soil sealing and their portfolios of
investment activities have all the required environmental terms and conditions. However, biodiversity has been defined as material only in
relation to the Group’s downstream value chain and the overall portfolio of investments.
[E4-2] Policies related to biodiversity and ecosystems
Key Environmental and Biodiversity Policies
The Group recognizes that biodiversity loss and ecosystem degradation arising from economic activities may have social impact. Therefore,
nature-related considerations have been embedded into its policies to indirectly avoid and minimize any negative effects on local
communities. The Group adopts a proactive approach to the management of ESG risks, with particular emphasis placed on risks arising from
climate and environmental change, which is already a key component of its Risk Management. Thus, it has set a series of key policies to
manage material sustainability matters such as the Climate related, Environmental, Social and Governance Risk Management Policy on Group’s
Business Lending and the Credit Policy Manual Wholesale Banking & Credit Policy Manual Small Business. For further details about these
policies as well as the monitoring process please refer to [E1-2] Policies related to climate change migaon and adaptaon.
To further mitigate its impact on biodiversity, the Group maintains an exclusion list to determine which activities are prohibited from being
financed. Specifically, the Bank prohibits financing towards:
• Activities prohibited by host country legislation or international conventions relating to the protection of biodiversity resources or
cultural heritage.
• Drift net fishing in the marine environment using nets in excess of 2.5 km in length.
• Conversion of natural forests into plantation.
• Wholesale and retail trade of thermal coal.
• Any activity involving significant degradation, conversion or destruction of the sites included in the Natura map
The Group’s exclusion list under the Climate related, Environmental, Social and Governance Risk Management Policy on Group’s Business
Lending Policy to allocate zero financing to targeted activities harming species diversity, habitats and waterbodies pertains to the downstream
scope of its value chain. The established commitments apply to all the Group’s operations, in every country where it operates.
In 2025, Alpha Bank strengthened its contribution to biodiversity and ecosystem protection through the establishment of its Green Bond
Framework, which directs financing towards activities with measurable environmental benefits. The Framework incorporates stringent
eligibility criteria that require financed assets to comply with high environmental standards, including IFC Performance Standards and relevant
EU legislation, thereby supporting projects that minimize ecological impacts and promote nature-positive outcomes. Through its “taxonomy-
aware” design, the Framework seeks, to the extent possible, to align with the EU Taxonomy environmental objectives — including climate
change mitigation, climate change adaptation, the transition to a circular economy, pollution prevention and the protection and restoration of
biodiversity and ecosystems. By integrating biodiversity considerations into its due-diligence processes, sectoral risk assessments and project
selection methodology, the Bank allocates financial resources in a way that reinforces sustainable land use, enhances environmental resilience
and supports long-term ecosystem preservation.
Implementation of biodiversity-related policies
In the context of ESG and Climate Risk Governance, Alpha Bank Group has implemented a comprehensive structure, addressing relevant
decision making and implementation at all levels. Further to that in E1 includes all third-party standards or initiatives the Group commits to
regarding the policy implementation. More details for this structure please refer to [E1-2] Policies related to climate change migaon and
adaptaon.
Stakeholder engagement for policy setting and implementation
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Stakeholders' engagement plays an important role in introducing new policies. As mentioned above, no specific biodiversity considerations
have been received to date by Shareholders. The Group, in response to Regulators’ expectations, implemented Climate Risk Management, ESG
criteria in all lending and investment decisions, and Risk and Capital Strategy incorporating ESG criteria. Customer feedback also influenced the
development of the Sustainable Finance Framework, Transition plans for clients, and ESG-related products and services.
Therefore, there are relevant policies that are available on the ESG and Sustainability section of the Alpha Bank S.A. website in both Greek and
English languages to address the different stakeholder groups:
• Environmental Management System
• Sustainable Finance Framework and External Review
• Green Bond Framework and Second Party Opinion
These policies are actively shared with affected stakeholders through direct communications and employee ESG awareness programs.
Specifically, all Employees have access to the policies through ABiD on Intranet – internal Alpha Bank website. For stakeholders implementing
policies, including investors, the Group ensures access through regular updates, sustainability reporting, and dedicated investor engagements.
These methods include participation in conferences, briefings, and the publication of detailed frameworks, such as the SFF and the Climate-
Related, Environmental, Social, and Governance Risk Management Policy, which outline the bank's commitments and operational integration
of ESG standards.
Relation of Policies with Biodiversity and Ecosys tems matters
The Group acknowledges that its current biodiversity and ecosystems-related policies are still under development to fully address the specific
subject matters outlined in the Datapoint. However, it is committed to progressively integrating these aspects into its operational and
financing frameworks. Below is the status and alignment of policies with the subject matters.
a) Contribution to direct impact drivers on biodiversity loss:
i. Climate Change: The Group’s policies address climate change indirectly through its focus on decarbonization and support for
renewable energy and energy-efficient projects, but these measures do not currently target biodiversity impacts directly.
ii. Land-Use Change: While land-use assessments are part of the ESG risk review for projects, the policies do not comprehensively
address land artificialization, freshwater-use change, or sea-use change impacts. These gaps are recognized and planned for future
iterations of the policies.
iii. Direct Exploitation: The Group’s exclusion list explicitly prohibits financing activities such as deforestation and overfishi ng, but
further integration of biodiversity-specific exploitation metrics into the due diligence process is still under development.
iv. Invasive Alien Species: This is not explicitly addressed in current policies but could be included in future updates as part of the
Group’s evolving biodiversity strategy.
v. Pollution: Policies currently address pollution risks, particularly in industrial projects, through ESG due diligence, but direct links to
biodiversity impacts are not yet systematically incorporated.
b) Impacts on the State of Species:
The Group does not currently have detailed mechanisms to assess impacts on species population sizes or extinction risks. Biodiversity
considerations are indirectly addressed by excluding funding for activities in protected areas, but further development of species-specific
impact monitoring is required.
c) Impacts on the Extent and Condition of Ecosystems:
Ecosystem impacts, including land degradation and soil sealing, are partially addressed through ESG risk reviews and exclusion of certain
activities. However, a comprehensive ecosystem health monitoring framework is not yet in place.
d) Impacts and Dependencies on Ecosystem Services:
Dependencies on ecosystem services, such as carbon sequestration and water provision, are considered in project evaluations where relevant,
but these are not yet systematically linked to biodiversity impacts across the portfolio.
The Group applies, maintains, and updates the exclusion list to determine specific activities, which are not allowed to be financed. The criteria
for exclusion span across various environmental and social matters. The exclusion list is part of the Climate related, Environmental, Social and
Governance Risk Management Policy on Group’s Business Lending which incorporates activities related to biodiversity and ecosy stems.
In addition, following the ESG risk categorization at the obligor/project/lending transaction level and depending on the outcome (described in
detail in the relevant Credit Policy Manuals), an ESG Due Diligence is carried out based on specific evaluation criteria, defined as Environmental
and Social Requirements, which reflect those of EBRD. One of the ESG evaluation criteria describes potential risks and impacts on biodiversity
conservation and sustainable management of living natural resources. All obligors/projects of the Group are required to manage the ESG
performance stemming from their business activity to this domain. When the outcome of the ESG assessment is non-sustainable Medium or
High Risk financing and the request under consideration concerns a dedicated purpose investment nature new financing e.g. project finance
(infrastructure, energy, etc.), construction / expansion / purchase of real estate including industrial premises, hotel and tourism units, a due
diligence is carried out on the basis of which, if required, a corrective action plan is compiled which should be implemented in a specific
timeframe by the client.
In addition to all the policies described above, the Group has established an Environmental Management Policy since April 2019 that sets the
framework for the Group’s Environmental Management, aiming at improving its environmental performance, its complian ce with the
institutional and regulatory framework on environmental issues and ensuring the effective use of natural resources. According to the Policy, an
Environmental Management System (EMS)- certified with ISO14001- is developed according to international standards, setting the framework
for the monitoring, management, and improvement of the environmental impact of its activities. The EMS monitors the Bank's environmental
performance related to its operations and assesses financed projects on the basis of environmental and social risks.
Alpha Bank, through its Environmental Management System (EMS), indirectly addresses the impacts related to biodiversity and ecosystems,
recognizing their importance for its business operation and model. Although there is no specific reference on biodiversity and ecosystems as
separate entities, the EMS incorporates procedures for assessing and managing environmental and social risks that touch upon natural
systems and the challenges they face.
Material Dependencies: The Group recognizes its dependence on material resources derived from ecosystems. Through the EMS, it identifies
and assesses the environmental aspects of its activities that interact with natural ecosystems, such as energy and water use, emissions, and
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
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resource management. The emphasis on efficient resource use directly correlates the recognition that the sustainability of business activities is
inextricably linked to the health of natural systems.
Physical Risks: The EMS includes the assessment of environmental impacts and risks arising from extreme weather events or other natural
disasters (physical risks). The Group examines the impact of these phenomena on its operations and business model and takes measures to
minimize them.
Transition Risks: By integrating non-financial criteria into its credit assessments, the Group proactively addresses the risks of transitioning to a
more sustainable economy. By evaluating financed projects based on environmental and social standards, the Group reduces its exposure to
businesses or sectors that may be negatively affected by regulatory changes, reputational issues, or economic challenges related to
biodiversity loss or ecosystem degradation.
Opportunities: The Group recognizes the opportunities arising from promoting sustainability. It encourages green financing and offers
products that help its Customers improve their environmental performance. In this way, The Group seeks to contribute to the growth of
sustainable investments and services, while also contributing to ecosystem protection.
Sustainable Land and Agriculture Practices
In agriculture involving animals, Group prohibits financing activities such as force-feeding ducks and geese, fur factory farming, and any other
activities deemed illegal under national or international laws or subject to phase-out bans. To mitigate specific sectoral risks—such as
managed grazing, prevention of overgrazing, large-scale livestock farming, wastewater management, waste management, air emissions,
animal feed, disease control, responsible use of antibiotics, and ensuring animal welfare—the Group conducts Environmental and Social risk
due diligence through qualified personnel in accordance with required legislation. As of December 2025, agriculture represents only a small
portion of the Group’s current loan portfolio.
Sustainable Sea and Ocean Practices
Furthermore, the Group prohibits financing drift net fishing activities using nets longer than 2.5 km to mitigate risks in fisheries and
aquaculture. To address other sector-specific risks—including fish types, bycatch, organic waste management, petroleum management,
wastewater and effluents, air emissions, solid waste management, plant-based feeds from sustainable agriculture, cultivation of native species
in bag nets or closed-wall sea-pens, cultivation of non-native species in land-based tanks, risk prevention for local wild populations, stocking
densities to minimize disease outbreaks, net loss prevention in fish protein yield, water management, discharges and effluents, soil erosion
and sedimentation, and the use of fertilizers and chemicals—the Bank conducts Environmental and Social due diligence through technically
qualified personnel in accordance with required legislation.
Deforestation Practices
Finally, to prevent environmental and social risks associated with forestry projects, the Group Credit Policy prohibits financing commercial
logging operations in primary tropical moist forests, and the production or trade of wood or other forestry products unless sourced from
sustainably managed forests.
To address sector-specific risks such as water management, responsible use of fertilizers and pesticides, alternatives to chemical inputs,
hazardous materials management, soil erosion, fire management, reforestation with native species, and promoting multi-age and multi-
species forests over monocultures, the Group conducts environmental and social risk due diligence through qualified personnel to verify
compliance with legislation. As of December 2025, forestry constitutes only a small portion of its loan portfolio.
[E4-3] Actions and resources related to biodiversity and ecosystems
Biodiversity and Ecosystem related Actions
To remain compliant with its exclusion list, the Group retains a commitment to allocate zero finance to targeted activities h arming species’
diversity, habitats and waterbodies. This action was achieved for the reporting year as no new financing volumes were allocated to any
exclusionary categories. This expects to remain unchanged as the Alpha Bank commits to its target in the future and is expected to continue
over the short-, medium, and long-term horizons.
The Group’s aim for zero financing towards targeted activities harming species diversity, habitats and waterbodies, pertains to its downstream
value chain and applies to all Group’s operations, in every country where it operates and affects individuals, co rporates and SMEs. This
commitment took effect in 2023 and the target has been achieved for 2024 and 2025.
Additionally, the implementation of this commitment contributes directly to Group’s broader sustainability objectives, partic ularly aligning
with SDG 15 “Life on Land.” It supports the Group’s strategy to minimize its environmental footprint and safeguard biodiversity by financing
only those activities that meet strict environmental criteria as outlined in its Climate-Related and ESG Risk Management policies.
Regarding geographies and stakeholder groups, this commitment applies comprehensively across all countries of operation, primarily affecting
individuals, SMEs, and corporates in the Group’s downstream value chain. While the commitment has been implemented globally, a significant
focus remains on the Greek market, given the regional impact of activities on local biodiversity and ecosystems.
Reforestation enablement through private banking products
Further to that, starting in 2021 and continuing through 2026, Alpha Bank has also set an additional action to collaborate with Reforest Action
and subsequent promotion of impact investing to private banking Customers. Since 2021 as part of the collaboration with Reforest’Action, a
global actor in reforestation and agroforestry, more than 69,921 trees have been financed for planting, of which nearly 9,135 were financed in
2025. The reforestation projects have been implemented in critical areas across Greece, including the Arona forest in Katerini, Thessaloniki
forest, Pierian Mountains forest, and Kastanolongos forest in Southern Evia. This effort has resulted in the storage of 1,370 tons of CO2 and
the creation of 27,405 natural shelters for wild animals according to the certificates the Group has received for the completion of each
initiative.
Regarding the operational and upstream value chain segments, the Group has not identified any material impacts related to biodiversity and
ecosystems.
The Group confirms that its own operational model, primarily centered on financial services, does not inherently or directly generate issues
requiring remediation actions. However, in cases where harm has occurred due to external circumstances, such as natural disasters, Alpha
Bank Group has historically supported affected communities through financial assistance and social programs.
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In 2025, Alpha Bank mobilized 74 Employees from the Risk Control Business Area to support a volunteer initiative in the Aesthetic Forest of
Kaisariani, in collaboration with the Philodassiki Society of Athens. The team contributed to the restoration of an eroded forest road in the
Analipsi area, using natural materials to stabilize the pathway and improve access for firefighting vehicles and visitors. This action supported
the preservation and resilience of a protected forest ecosystem and reflects the Bank’s commitment to biodiversity enhancement and
community-based environmental stewardship.
Case studies: Biodiversity-related and bio-product certified companies financed through Alpha Bank and InvestEU
In 2025, Alpha Bank supported a series of enterprises whose products and operations are certified under recognized European environmental
and organic standards, thereby indirectly contributing to biodiversity protection and sustainable agricultural practices. Through the InvestEU
Sustainability facility, the Bank provided general-purpose financing to five companies whose eligibility was based on verified environmental
criteria. One financed company qualified on the basis of holding an EU Ecolabel for liquid dishwashing detergents, demonstrating compliance
with stringent requirements on reduced toxicity, biodegradability, water protection and overall lower environmental impact.
Four additional financed companies demonstrated eligibility through valid organic production certifications issued under Regulation (EU)
2018/848 and listed on the EU TRACES platform. Their certified product ranges include unprocessed and processed organic agricultural
goods—such as plant-based foods, beverages, fruit derivatives, herbs, and organic convenience products—produced with methods that
restrict synthetic inputs, safeguard soil and water quality, and promote the conservation of agricultural biodiversity.
While the InvestEU Sustainability loans are general-purpose in nature, their allocation to certified organic and eco-labelled companies supports
the continued operation and potential expansion of business activities with lower environmental burdens. By directing resources to
enterprises adhering to EU organic and environmental compliance schemes, Alpha Bank contributes—albeit indirectly—to the conservation of
agricultural biodiversity, the protection of ecosystems, and the scaling-up of sustainable production models within the Greek market.
As such, while the nature of the Group’s services minimizes direct instances of material harm necessitating remedy, its frameworks, initiatives
and lending activities ensure that any identified impacts are effectively addressed in alignment with best practices and stakeholder
expectations.
Resources for implementation of actions
It is important to mention that for the implementation of its action plan the Group does not require significant operational expenditures
(OpEx) and/or capital expenditures (CapEx). Thus, no significant current or future financial and other resources have been allocated to the
implementation of the action plan.
Worth noting that no biodiversity offsets have been used in the actions.
[E4-4] Targets related to biodiversity and ecosystems
Alpha Bank Group has identified through its Materiality Analysis the potential negative impacts on biodiversity and ecosystems through its
financial products/services. As a result, the Group is committed to zero financing to targeted activities harming species diversity, habitats and
waterbodies. This represents an ongoing target that serves to mitigate any material impacts the Group has on biodiversity and ecosystems
through the provision of its financial products and services.
The Group ensures it will not finance transactions that impose environmental or social threat, through the incorporation of t he “Climate
related, Environmental, Social and Governance Risk Management Policy on Group’s Business Lending” in the existing Credit Risk Management
Framework and the Group’s Credit Policy.
This target was implemented in 2023, is absolute, with no permissible thresholds, and continues to be in effect from fiscal year 2023 onwards.
Compliance to the Group’s expanded exclusion list is tracked through regular monitoring of financing activities and the established credit risk
management processes.
The Group's commitment to maintaining zero financing is an ongoing objective, evaluated annually. Consequently, the baseline value is
anticipated to consistently remain at zero each year.
The Group ’s target relating to biodiversity and ecosystems serves to mitigate its downstream material impacts and is applicable everywhere
(i.e., in each country) the Group has its operations. The initial focus for the Group’s sustainable lending targets is its largest entity, Alpha Bank
S.A., with the related policies having been expanded across the Group.
Target setting process
The Group’s target applies to its downstream value chain. The Group sets its sustainable lending targets for the purpose of a ligning its portfolio
with the Paris Agreement objectives and is in the process to develop more targets on material sustainability matters by actively leveraging its
Materiality Analysis and SFF to identify areas of priority and impact. As part of its membership in the UN Environment Program Finance
Initiative (UNEP FI), the Group applies best practices to assess risks and opportunities in its financing activities, particularly related to climate
and biodiversity impacts. Furthermore, through its participation in the United Nations Global Compact (UNGC), the Group ensures its
sustainability targets address broader social and environmental considerations.
The targets under development also align with Greece’s Recovery and Resilience Plan and other relevant EU and national polici es. The
methodologies incorporate both quantitative metrics and qualitative indicators, ensuring progress is measurable, traceable, and aligned with
the Bank's commitment to sustainable development. Alpha Bank remains committed to maintaining transparency through regular updates in
its Sustainability Report and other disclosures.
Stakeholder Involvement in Target Setting
As per the stakeholder engagement process described in [SBM-2] Interests and views of stakeholders, forms an essential input to the Group’s
strategic planning, including target setting. By actively participating in initiatives like the UNEP FI and its working groups, the bank ensures that
its goals reflect broad societal priorities and address key sustainability challenges.
Target Progress
The Group’s zero financing target for activities with an adverse impact on species diversity, habitats and waterbodies is an absolute target
which is measured through two KPIs: 1) new financing volumes in Euro million (Zero volume) and 2) Operational sites owned, leased, managed
in or adjacent to protected areas and areas of high biodiversity value outside protected areas. The target was achieved with no new financing
volumes announced for either metric category.
Target Alignment with international and national policies and legislations
At this stage, the Bank’s biodiversity-related target has not yet been informed by the Kunming–Montreal Global Biodiversity Framework or the
EU Biodiversity Strategy for 2030. However, the Bank’s target contributes towards nature conservation by not financing activities with high
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biodiversity impact. Alpha Bank Group leverages the framework of Greece’s National Recovery and Resilience Plan (NRRP), to su pport projects
classified under the green transition pillar, which allocate significant resources to biodiversity protection. Thro ugh the Bank’s participation in
the Recovery and Resilience Facility (RRF) co-financing, the Group can allocate financing to projects aimed at urban regeneration, protection of
biodiversity, and enhancements in environmental infrastructure, including investments in Civil Protection Centers. These activities contribute
to the preservation and sustainable management of ecosystems while fostering the Group's broader sustainability objectives. .
Targets reflected in Value Chain
The Group recognizes the critical importance of biodiversity in its downstream value chain. Through its downstream value chain assessment,
the Group has identified key biodiversity-related risks and opportunities, including dependencies on ecosystem services and the impacts of
financed projects on habitats and ecosystems. The Group’s activities in sectors such as real estate, tourism, and infrastruct ure are analyzed
using tools like UNEP FI's Portfolio Impact Analysis to identify and manage biodiversity impacts.
The Group has not used biodiversity offsets as part of its target-setting and their target pertains to avoidance on the mitigation hierarchy.
Target effectiveness, ambitions and progress
Alpha Bank Group tracks the effectiveness of its policies and targets in relation to material sustainability-related impacts, risks, and
opportunities. This is implemented through:
1. structured approach:
• implementation of policies and frameworks
• annual report for Principles for Responsible Banking and corresponding assessment
• qualitative and quantitative indicators that are aligned with international standards such as the EU Taxonomy, and Alpha Bank
Group’s SFF.
2. mechanisms, not limited to:
• Policy Effectiveness Tracking: Regular reviews of environmental, social, and governance (ESG) risks and integration into credit
assessment processes to ensure that clients meet sustainability thresholds.
• Defined Levels of Ambition: Commitment to achieving net-zero greenhouse gas emissions by 2050, operationalized through
interim science-based reductions and sustainable financing expectations.
• Qualitative and Quantitative Indicators: Metrics such as exposure to transition-sensitive sectors, greenhouse gas emissions
metrics and biodiversity impacts indicators to evaluate progress and manage risks.
• Baseline Assessments: Reference points for progress measurement, such as emissions intensity benchmarks and sectoral
sustainability profiles.
The Group implements a process of ESG risk categorization and due diligence during credit approvals. The governance structure, both at the
Board and Executive level ensures oversight and accountability at all levels. The Group’s sustainability strategy is integrated into operational
policies and stakeholder engagement efforts.
[E4-6] Anticipated financial effects from material biodiversity and ecosystem-related risks and opportunities
Anticipated financial effect of material biodiversity and ecosystems-related risks & opportunities
The results of the materiality assessment performed are illustrated under [SBM-3] Material impacts, risks and opportunities and their
interaction with strategy and business.
ESRS E5 - RESOURCE USE AND CIRCULAR ECONOMY
[Ε5-1] Policies related to resource use and circular economy
Key Environmental and resource Use Policies
The Alpha Bank Group adopts a proactive approach to the management of ESG risks, with particular emphasis placed on risks arising from
climate and environmental change, which is already a key component of its Risk Management. Thus, the Group has set a series of key policies
to manage material sustainability matters such as the Climate related, Environmental, Social and Governance Risk Management Policy on
Group’s Business Lending. For further details about these policies as well as the monitoring process please refer to [E1-2] Policies related to
climate change migaon and adaptaon.
The Group’s exclusion list pertains to the downstream scope of its value chain. The established commitments apply to all the Group’s
operations, in every country where it operates.
Implementation of resource use-related Policies
In the context of ESG and Climate Risk Governance, Alpha Bank Group has implemented a comprehensive structure, addressing relevant
decision making and implementation at all levels. For more details on this structure, you may refer to [E1-2] Policies related to climate change
migaon and adaptaon.
All third-party standards or initiatives the Group commits to regarding the policy implementation are listed also in E1 as referred above.
Stakeholder Involvement in Policies
In accordance with the established Environmental Policy, the Group maintains ongoing dialogue with shareholders, clients, business partners,
and government bodies on sustainability matters. It consistently publishes reports detailing the outcomes of its environmental initiatives.
For more information on relevant stakeholder involvement in policies and how the aforementioned policies are made available to
stakeholders, please refer to [E4-2] Policies related to biodiversity and ecosystems.
In its financing activities, the Group actively promotes circular economy practices among its clients by integrating environmental and social
criteria into credit assessments. Projects focusing on recycling, waste reduction, and the use of recycled materials are prioritized in the Group's
SFF, which aligns with the EU Taxonomy for environmentally sustainable activities.
Additionally, through the financial services, the Group encourages clients to transition away from reliance on virgin resources by adopting
circular economy principles as ESG criteria are embedded throughout the financing process to ensure alignment with sustainability objectives
at every stage of the credit lifecycle.
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To strengthen these efforts, the Group has established robust monitoring mechanisms, overseen by the Corporate Governance, Sustainability,
and Nominations Committee, to assess and track the environmental impact of financed projects.
The Group’s approach to sustainable sourcing and the use of renewable resources is firmly integrated into its business practi ces and aligned
with international sustainability standards, including the EU Taxonomy for environmentally sustainable activities and its ISO 14001-certified
Environmental Management System (EMS).
In its financing activities and broader economic contributions, the Group prioritizes funding for projects and businesses that advance the use of
renewable resources and sustainable practices. Financing is directed towards industries such as renewable energy, green buildings, and
sustainable agriculture according to the SFF.
[Ε5-2] Actions and resources related to resource use and circular economy
Resource Use and Circular Economy key actions
The Group has a negative impact to Resource Security (which affects the development of a Circular Economy) through the Group’s
products/services and business relationships.
As a result, the Group has developed a list of green and social activities that are eligible for sustainable financing which has been implemented
for 2025 and will continue to be applied in the future. These activities include five distinct themes: Energy Efficiency, Renewable Energy,
Sustainable Transport, Resource Efficiency and Pollution Control, and Green Buildings. Thus, the Group has committed to (re)finance:
• Processes and infrastructure that facilitate recycling. Examples: waste management companies which incorporate recycling and
sustainable waste management practices.
• New technology to facilitate maximum use of waste. Examples: separation of materials or energy efficient recycling technology.
• Treatment of bio-waste through anaerobic digestion in dedicated plants with the resulting production and utilization of biogas and
digestate.
• Treatment of bio-waste through composting (aerobic digestion) in dedicated facilities with the resulting production and utilization of
compost.
• Companies/projects that substitute virgin raw materials with secondary (recycled) materials originating from materials and resources
recovery.
• Companies/projects that increase the capacity utilization of a product or asset during its useful life through sharing business models.
Sharing is circular when it optimizes the utilization of the product or asset.
• Repair activities and activities that facilitate reduction in material use. Examples: renting electric appliances instead of buying or
community-based equipment sharing, etc.
Alpha Bank Group is implementing sustainability into its operations and financing activities according to its SFF and in alignment with global
sustainability goals, including the Paris Agreement, the EU Green Deal, and the United Nations Sustainable Development Goals (SDGs).
The Group provides funding for projects that promote recycling, composting, and innovative waste-to-energy solutions, including the
production of biogas and secondary materials with an established goal of achieving Euro 3.8 billion in sustainable disbursements by 2027.
Regarding geographies and stakeholder groups, actions applicability please refer to the relevant section in [E4-3] Acons and resources related
to biodiversity and ecosystems.
To support remediation for communities impacted by material environmental harms, the Group has financed projects aimed at improving
waste management infrastructure in regions with historically inadequate waste processing systems. The Epirus Region and Peloponnese
Region PPP projects exemplify this commitment, directly reducing pollution, minimizing harmful environmental impacts, and improving public
health outcomes. These efforts address the systemic harm caused by improper waste management, ensuring compliance with international
environmental standards while benefiting local communities.
The Epirus plant, operational since 2019, ensures at least 17,000 tonnes of recyclable materials are recovered annually, contributing to
national recycling targets. The plant generates 10,800 kilowatt-hours of green energy every year, enough to power 3,000 households, while
preventing the release of 12,000 tons of carbon dioxide into the atmosphere. Additionally, it produces 25,000 tonnes of compost annually,
supporting sustainable agricultural practices and reducing reliance on chemical fertilizers.
The Peloponnese plant, which has been completed in 2025, prevents regional landfill waste, at least 65% of biodegradable materials are
utilized, 60,000 tons of liquid waste are diverted from landfills, and green energy is generated to serve the needs of 6,000 households, while
avoiding release of 24,000 tons of carbon dioxide into the atmosphere.
Resources for implementation of actions
Alpha Bank Group acknowledges the importance of allocating appropriate financial and other resources to effectively implement its action
plans. The Group incurs operating (OpEx) and capital expenditures (CapEx) in connection with initiatives aimed at supporting circular economy
from its business activities and its own operations. However they are not presented in this statement as they are not considered significant.
[Ε5-3] Targets related to resource use and circular economy
Resource Use and Circularity Targets
The Group has identified through its Materiality Analysis the potential negative impacts on circularity (resources and waste) through its
financial products/services. In order to promote the reduction of waste generation and promotion of the principles of the circular economy in
alignment with SDG 12 “Responsible Consumption and Production” the Group monitors the financing provided in alignment with the Bank’s
SFF Green pillar - Resource efficiency and pollution control theme which targets loans for recycling and reuse and circular economy.
Alpha Bank sets an overall target for new sustainable financings of EURO 3.8 billion for 2025-2027 which includes dedicated purpose financing
to Companies/projects that substitute virgin raw materials with secondary (recycled) materials originating from materials and resources
recovery, Companies/projects that increase the capacity utilization of a product or asset during its useful life through sharing business models
and Repair activities and activities that facilitate reduction in material use. However, no specific target for circular-focused disbursements has
been set.
In addition, the Bank measures and monitors the financing eligible and aligned to the EU Taxonomy objective for the transition to a circular
economy, in accordance with Article 8 of the EU Taxonomy.
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The Group’s target applies to its downstream value chain and is applicable everywhere (i.e., in each country) that there are operations. The
initial focus for the Group’s sustainable lending targets is its largest entity, Alpha Bank S.A., with the targets having been expanded across the
Group for 2025.
In accordance with the waste management hierarchy, the Bank’s target is positioned mainly at the “avoid” stage, as its primary objective is to
prevent the generation of waste at source, by contributing to the elimination of the use of virgin materials and to the promotion of the
prolonged use of products through its portfolio. Moreover, it shall be stated that the target is not mandatory.
Targets Assumptions, Methodologies, Scenarios, Data Collection and Alignment with International Policies
The Bank is in the process of developing more targets on material sustainability matters for the organization and is actively leveraging its
Materiality Analysis and SFF to identify areas of priority and impact. The finalization will consider both local and international sustainability
contexts.
To ensure the robustness of its existing target of Euro 3.8 billion towards new Sustainable Financings including circularity-focused projects by
2027, Alpha Bank utilizes methodologies and frameworks provided by the organizations and initiatives it participates in or supports. As a
signatory of the Net-Zero Banking Alliance (NZBA), the Bank is aligning its long-term objectives with the net-zero pathways, using science-
based scenarios to measure and track emissions reductions. Through the UN Principles for Responsible Banking (PRB), Alpha Bank has
integrated the SDGs and Paris Agreement objectives into its business model.
Further, Alpha Bank adheres to the Green Bond Principles (2021) and Green Loan Principles (2021) to classify and track sustainable financing
activities, ensuring that these meet globally recognized sustainability standards. As part of its membership in the UN Environment Program
Finance Initiative (UNEP FI), the Bank applies best practices to assess risks and opportunities in its financing activities, particularly related to
circular economy and resource (re)use.
To enhance transparency and align with international policy goals, the Group incorporates guidance from the TCFD in its reporting and
integrates climate-related risks into its decision-making processes. Furthermore, through its participation in the United Nations Global
Compact (UNGC), the Group ensures its sustainability targets address broader social and environmental considerations.
The targets under development will also align with Greece’s Recovery and Resilience Plan and other relevant EU and national p olicies. The
methodologies will incorporate both quantitative metrics (e.g., total amount allocated to sustainable financing, total financing specifically to
renewable energy projects, percentage reduction in financing activities that negatively impact the environment) and qualitative indicators
(e.g., governance improvements, programs initiated to educate stakeholders, awards and recognitions received), ensuring progress is
measurable, traceable, and aligned with the Group's commitment to sustainable development.
Further engagement to diverse stakeholders, including regulators, Customers, and community representatives takes place through structured
dialogues and collaborative platforms, with the most recent example of materiality assessment. More details on the stakeholders engagement
process please refer to the relevant section in [SBM-2] Interests and views of stakeholders. By actively participating in initiatives like the UNEP-
FI, the Group ensures that its goals reflect broad societal priorities and address key sustainability challenges.
While more targets are included, Group remains committed to maintaining transparency through regular updates in its Sustainability Report
and other disclosures.
Progress against targets
Alpha Bank has a commitment of EURO 3.8 billion towards new Sustainable Disbursements including circularity-focused projects, according to
the 2025-2027 business plan.
The metric for circularity-focused projects is absolute, with no significant assumptions behind it. It is based on the activities incorporating
circular economy principles in alignment with Alpha Bank’s Sustainable Finance Framework and SDG 12. Disbursemen ts for circularity-focused
projects amounted to Euro 6.6 million for 2025.
The European Recovery and Resilience Facility (EU RRF) plays a critical role in Alpha Bank’s sustainability strategy. RRF loa ns are aligned with
Greece’s Recovery and Resilience Plan, financing projects that enhance resource efficiency, promote circular economy principles, and
accelerate the green energy transition. While compliance with RRF requirements is mandatory, Alpha Bank voluntarily extends these principles
to its broader lending portfolio, further supporting the green transition of SMEs and other key sectors.
The Group’s broader sustainability strategy integrates the Paris Agreement and the European Circular Economy Action Plan.
Targets Applicability
The Group acknowledges the importance of improving disclosures for its subsidiaries and entities in other countries. For entities or subsidiaries
not explicitly covered in the present Sustainability Statement, the Group reaffirms that efforts are underway to extend these frameworks and
assessments. Reasons for this stem from varying stages of implementation of standardized materiality assessments and data collection
processes across regions such as local regulatory requirements, operational structures, and resource availability
[Ε5-6] Anticipated financial effects from material resource use and circular economy-related risks and opportunities
Anticipated Financial effect of circular economy-related risks & opportunities
The results of the materiality assessment performed are illustrated under [SBM-3] Material impacts, risks and opportunities and their
interaction with strategy and business.
SOCIAL INFORMATION
ESRS S1 - OWN WORKFORCE
Alpha Bank Group is dedicated to advancing responsible business practices that foster an ethical working environment for its workforce. The
Group has integrated sustainability into its core operations, acknowledging that respect for human rights is fundamental to long-term value
creation. In alignment with international frameworks and taking into consideration the Stakeholders’ considerations, the Grou p continuously
adapts to meet evolving standards and best market practices, please refer to [SBM-2] “Interests and views of stakeholders in relationship with
strategy and business model” for further details.
[S1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model
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Regarding material impacts, risks, and opportunities, all Employees in Group’s own workforce who could be materially impacted by business
activities are included within the scope of disclosures. The Employees are directly employed by the Group’s Subsidiari es, and include
permanent and temporary Employees, as well as trainees or part-time Employees in some subsidiaries. For more information, please refer to
“Connection of material impacts, risks and opportunities with strategy and business model” section abo ve.
Equal treatment and opportunities for all
Alpha Bank Group is committed to maintaining a fair and equal working environment that upholds human dignity, ensures non-discrimination,
and promotes equal opportunities for all Employees, regardless of age, gender, disability, or sexual orientation, actively fostering a culture of
inclusion, mutual respect, and shared responsibility in advancing diversity and equitable treatment across its workforce.
The Group has integrated equal treatment as a core principle within its governance and operational frameworks, through the adoption of
appropriate policies, the promotion of ethical standards as well as by adhering to all legal requirements, to maintain and support an ethical
and meritocratic working environment. Through its Code of Conduct and Ethics explicitly safeguards transparency, integrity, and equal
treatment across all internal and external relationships, including Employees, suppliers, and stakeholders. Its Diversity Policy demonstrates its
commitment to inclusive practices and merit-based selection, particularly at the Board level. These initiatives are, also, supported by the
Group’s adherence to the Hellenic Corporate Governance Code, which rein forces ethical conduct and non-discrimination. Alpha Bank, also,
ensures that all Employees have access to appropriate communication channels to express concerns or report issues, in alignment with the
Group’s whistleblowing procedures and ethical standards. By embedding these values into its strategy and business model, Alpha Bank
proactively manages material risks and opportunities related to workforce equity, fostering a fair and respectful working environment that
enhances Employee engagement and organizational resilience.
The Double Materiality Assessment identified “Staffing and training issues” as the only material risk related to Alpha Bank’s own workforce. No
material opportunities were identified within this category, the assessment also highlighted positive impacts as sociated with the Group’s
workforce practices.
The Group recognizes that emerging technologies and accelerated digitalization present both new prospects and potential risks for workforce
adaptability which is applicable to all Employees. In particular, the Group acknowledges that insufficient, delayed, or uneven access to training
and skills development may pose a risk of skill obsolescence, reduced confidence and engagement, and psychosocial strain (e.g., stress or
“technology fatigue”) that could adversely affect employee well‑being and productivity. To proactively mitigate these risks, Alpha Bank
ensures equitable access to tailored learning paths for Employees of all ages, backgrounds, and skill levels and monitors completion and
impact through defined KPIs. As part of this approach, the Bank has introduced AI Awareness sessions to demystify new technologies, promote
responsible and secure use of AI, and support Employees in adapting to evolving tools and processes, while mitigating health and safety
related risks from the use of emerging technologies. By investing in inclusive, data-informed development programs, combined with manager
check-ins and employee feedback loops, the Group aims to ensure that technological progress enhances productivity and innovation while
safeguarding engagement, inclusion and overall well-being.
Although no negative material impacts on its Employees were identified, the Group recognizes that the continuously growing demand for
upskilling and the inherent challenges in the implementation of Diversity, Equality and Inclusion principals can inadvertently result in
discriminatory practices, especially in fast-paced sectors where organizations are expected to fully adapt in rapidly changing conditions. To
protect its workforce, Alpha Bank Group is committed to proactively engage with its Employees to discover potential incidents of
discrimination early and ensure that such cases are stand-alone incidents which are not indicative of the Group’s values and practices. In terms
of equal treatment amongst the workforce, no specific category of Employees is considered to be at greater risk.
Some of the Policies applicable to the Group’s workforce, that help ensure positive impacts, in the context of equal treatmen t for all staff are:
• Code of Conduct & Ethics
• Remuneration Policy
• Diversity Policy
• Career Framework
Moreover, indicative activities and initiatives that contribute to the Group’s commitment to positive impacts in terms of equality are:
• Diversity and Inclusion programs, initiatives, and trainings to promote gender equality, provide support to underrepresented groups,
and ensure equal opportunities for all Employees with the ultimate goal of creating a more supportive and inclusive work
environment that values Employee satisfaction and promotes organizational as well as individual performance.
• Multiple programs designed to support Employees in various aspects of their lives, including initiatives that promote physical and
mental health, resources that encourage family engagement and flexible work arrangements, to ensure a healthy and well-balanced
workforce.
Working Conditions
Alpha Bank Group upholds high standards of working conditions, ensuring a fair, safe, and inclusive environment that supports Employee well-
being, professional development, and equal opportunity across all roles and functions, which is also highlighted through the positive impacts
that have been identified under the Double Materiality Assessment “Secure employment”, “Social dialogue” and “Freedom of association”.
The Group fully complies with all applicable European and national legislation and regulatory requirements concerning working conditions and
consistently applies international best practices across its entire workforce. To ensure the highest working conditions for its workforce, Alpha
Bank Group:
• Implements various policies and procedures to eliminate health related risks and promote work-life balance, promoting job security,
through strategic workforce planning for all Employees, especially those impacted by potential restructurings.
• Ensures that high performance is rewarded through a well-structured remuneration policy and specifically, by its variable
remuneration framework, which consists of carefully planned measurable targets.
• Conducts annual performance reviews and provides feedback to all Employees regarding their performance.
• Offers continuous learning opportunities, providing access to professional development courses, and supporting career advancement
through mentorship programs and through learning and development tools for all Employees (e.g., Udemy) to help them seamlessly
adapt to modern work practices and evolving job roles.
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• Establishes regular communication channels between management and Employees, creating forums for discussion, and involving
Employees in decision-making processes (e.g., talk to us, Alpha Way Communities of Change, Townhalls, new Intranet etc.).
• Conducts annual Employee satisfaction surveys with high participation rates to monitor the Employees’ pulse on issues related to
working conditions.
• Provides various benefits to its Employees, such as health care coverage, teleworking options, initiatives related to Employee well-
being with focus on both physical and mental health etc.
• Supports the formation of Employee unions, ensuring the right of Employees to collective bargaining.
Alpha Bank Group’s operations are primarily concentrated in the European Union, where stringent regulations and oversight mechanisms are
in place to prevent cases of child labor, forced labor and compulsory labor, hence why the Group has not identified any types of operations or
geographical areas with the aforementioned risks. The Group’s implemented robust policies and practices have been designed to addre ss and
mitigate individual incidents, with prompt and effective responses, ensuring that no specific category of Employees is at greater risk in terms of
working conditions and no particular activities that could lead to a greater risk for individual with specific characteristics have been identified
at Group level. Furthermore, our net zero transition plan ensures that no negative impacts are expected on our Employees.
Health and Safety
Alpha Bank Group recognizes Health, Safety and Wellbeing to have an important aspect of its workforce. Thus, a Strategy on Health, Safety and
Wellbeing has been approved, structured around the following three pillars, with launches and implementation of initiatives and actions
around them:
• mental health,
• modern workplace, and
• resilience and readiness
Recognizing that resilience and preparedness for unexpected or adverse situations are crucial for safeguarding the health and safety of its
workforce, Alpha Bank Group:
• updates emergency and evacuation plans when required by changes in conditions, regulations or other requirements and events.
• establishes procedures to ensure that suppliers and third parties comply with those high standards, through technical assessments,
consultations and HSE audits
• provides on-site training on first aid
• organizes on-site ‘stop smoking’ clinics to support Employees in improving their health and overall quality of life.
[S1-1] Policies related to own workforce
Alpha Bank Group has established and implemented policies to address material impacts, risks, and opportunities for its own workforce,
ensuring coverage of all Employees, in alignment with the Minimum Disclosure Requirements on Policies (MDR-P) as outlined in ESRS 2. To
ensure that all Group policies are effectively designed, approved, and executed through appropriate governance structures and procedures,
and that they remain aligned with the Group’s strategic objectives and the interests of its stakeholder s, dedicated processes have been put in
place.
Alpha Bank Group upholds a strong commitment to safeguarding human rights and promoting fairness across its operations. The Group
actively cultivates a workplace culture that values individual expression, equal opportunity, and inclusive practices, guided by its internal
frameworks on Diversity, Equity, and Inclusion and its overarching human rights principles. All employment-related policies and procedures are
shaped by a firm respect for human rights, ensuring that equity and diversity are not only protected but also embraced throughout the
organization. Alpha Bank reinforces this commitment through structured initiatives and governance mechanisms, as well as continuous
engagement with its workforce through numerous initiatives and trainings regarding career and leadership development opportunities, regular
surveys and feedback mechanisms, flexible work options and health and well-being programs.
In alignment with internationally recognized standards such as 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, the Group integrates human rights
considerations into its strategic and operational decision-making, aiming to prevent violations and foster a responsible and respectful working
environment in its own workforce and its business partnerships. Several mechanisms, including trainings, are in place to monitor compliance
with the aforementioned standards and frameworks, and they are referenced in detail in the Grievance or Complaints Handling Mechanisms
Related to Employee Matters section of the S1- Own workforce. The Group also adheres to sectoral labor agreements in Greece and other
countries where it operates, ensuring compliance with national and international labor standards and legal requirements. In extremely rare
cases where human rights violations are identified in the Group’s operations, remedial actions are immediately imposed to not only correct
the specific violation but to also reinforce its identification system and overall ethical practices and standards.
Forced Labor, Compulsory Labor, Child Labor
Alpha Bank Group is dedicated to fostering a safe, healthy, and equitable working environment where all Employees are treated with dignity
and respect. In alignment with national and European legislation, as well as the Group’s core values and principles, any prac tices involving
forced, compulsory, or child labor are strictly prohibited across all operations.
To uphold these standards, Alpha Bank conducts comprehensive due diligence and background checks on both Employees and business
partners, ensuring alignment with its ethical commitments and safeguarding its operations from any involvement in such practices. These
measures reflect the Group’s unwavering commitment to human rights and responsible business conduct.
Elimination of discrimination, Harassment prevention, promotion of equal opportunities, Diversity & Inclusion
In relation to human rights, Alpha Bank Group has a wide variety of policies in place to safeguard its operations and foster a safe and fair
working environment. The Group is dedicated to preventing, mitigating, and addressing discrimination, violence, and harassment, including
gender-based and sexual harassment, and domestic violence and takes appropriate measures or makes reasonable adjustments to its working
conditions to support potentially affected Employees. Moreover, it informs and sensitizes its Employees through various means, including
printed and electronic materials and trainings, ensuring that they are all the policies and procedures regarding the prevention of discrimination
and harassment in the workplace.
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In 2025 the Group provided practical guidance, based on the Code of Conduct and Ethics, to all Employees to enhance its strategy against all
forms of discrimination, harassment, or misconduct against not only colleagues but also Customers, suppliers or contractors promoting the
Group’s values and commitment to provide a safe working environment.
To reinforce its strategic commitments, the Group applies the following policies:
Corporate Responsibility Policy
Policy Scope: Entire workforce
Policy Implementation Oversight at the highest organizational level: Chief Executive Officer (CEO)
This Policy is grounded in internationally recognized human rights frameworks, including the ILO Core Labor Conventions, the Universal
Declaration of Human Rights (UDHR) and the Organisation for Economic Co-operation and Development (OECD) Guidelines on Responsible
Business Conduct.
It affirms Alpha Bank Group’s commitment to respecting the rights of its workforce by explicitly prohibiting child, forced, a nd compulsory
labor. The Policy also upholds the rights to freedom of association and collective bargaining, in accordance with both national and
international standards.
The main objectives of the Policy are to:
• Promote fair, inclusive, and respectful working conditions, defend human rights and provide opportunities for employee
development, health, and safety.
• Support society by prioritizing initiatives in culture, education, health, and environmental protection.
• Incorporate environmental, social, and governance (ESG) criteria into financing and product development, actively contributing to
environmental protection and resource conservation.
• Ensure credibility, consistency, and efficiency in banking services while continuously improving products and services to meet
Customer needs responsibly.
This Policy promotes workforce diversity, fair remuneration, and continuous Employee development, while ensuring a strong focus on
occupational health and safety and work-life balance. These principles are consistently applied across all Group entities, both in Greece and
internationally. The oversight of the Policy is managed by the Communications and Corporate Affairs Business Area and it is uploaded to the
Group’s Intranet, where it remains available for all Employees. The policy has been updated in 202 5 and is due for Executive level approval in
H1 2026.
Diversity Policy
Policy Scope: Members of the Board of Directors, Senior Management and Employees
Policy Implementation Oversight at the highest organizational level: Chief of Corporate Center and General Counsel and Chief Human
Resources Officer (CHRO)
The Diversity Policy is applicable in the selection process for the Board of Directors’ Members as well as for the appointment of Alpha Bank’s
Senior Management and Employees and has been designed according to the legislative and regulatory frameworks currently in force, including
the Joint ESMA/EBA “Guidelines on the assessment of the suitability of members of the management body and key function holders”, as well
as embracing European best practices in corporate governance.
The main objectives of the Policy are to:
• Support and promote diversity on the Board of Directors and Employees.
• Engage a broad set of qualities and competences in the recruitment process, to achieve a variety of views and experiences and to
facilitate independent opinions and sound decision-making within the Board of Directors.
• Aim at an appropriate representation of all genders within the Board of Directors.
• Ensure that the principle of equal opportunities is respected when selecting Members of the Board of Directors.
• Ensure equal opportunities and treatment for Employees of different genders.
Through this Policy, the Group affirms its commitment to respecting, protecting, and promoting the diversity of all Employees. Alpha Bank
Group is dedicated to fostering an inclusive working environment that is free from any form of discrimination, including but not limited to
discrimination based on gender, age, nationality, marital status, sexual orientation, genetic characteristics, disability, race, color, religious or
political beliefs, ethnic or social origin, citizenship, or any other protected characteristic.
The monitoring process for the Diversity Policy consists of oversight and evaluation by the Corporate Governance, Sustainability and
Nominations Committee regularly, which is responsible for assessing the implementation of the Policy, reviewing gender representation and
overall diversity at the Board of Directors, Senior Management, and Employee levels within Alpha Bank S.A.
As part of the annual evaluation of the Board’s effectiveness, the Committee analyzes its composition, considering diversity in skills,
experience, and representation. If diversity objectives are not met, the Committee investigates the underlying reasons and recommends
corrective actions to ensure compliance with the principles of equal opportunity and inclusion. Additionally, the Policy is periodically
reassessed against diversity benchmarking results published by competent authorities such as the EBA ensuring its alignment with regulatory
requirements and industry best practices.
The key elements of the Diversity Policy are included in the Corporate Governance Statement that is uploaded in Alpha Bank’s website, where
it remains available for all Employees.
Career Framework
Policy Scope: Entire workforce
Policy Implementation Oversight at the highest organizational level: Chief Human Resources Officer (CHRO)
Alpha Bank Group is committed to providing structured growth opportunities, enhancing organizational effectiveness, and establishing itself as
a preferred employer. To support these objectives, the Career Framework Policy establishes a comprehensive structure to define, evaluate,
and manage roles within the Group, ensuring clarity, fairness, and alignment with strategic objectives. It categorizes roles based on job titles,
career levels, and job families, creating a consistent framework for role assessment and career development.
The basic principles governing the Policy are:
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• Transparency: The steps, rules and definitions followed to define the characteristics of each job role, as well as their approval
process, are published internally within the Group.
• Consistency: Job roles from different functional areas but with the same level of contribution to the Bank's goals are managed
similarly, based on specific evaluation criteria of importance.
• Validity: The relative importance of each job role for the operation of the Organization is determined objectively and with fair
judgment, based on the job description, impact indicators on the Organization, and required skills
• Flexibility: The Career Framework Policy is adapted to changes in the Bank's business models.
Prior to the launch of the Career Framework, HR engaged in a series of consultations with Business Area Directors to finalize role descriptions
and employee allocations to the new roles, incorporating feedback on an individual basis. Additionally, presentation of the Career Framework
was delivered to the Workers’ Representatives to ensure alignment and facilitate smooth implementation.
The Career framework provides a foundation for managing employee career development within an organization, it supports the alignment of
HR processes to the organization's goals and objectives and helps to build a motivated and engaged workforce. Specifically, this Policy can
help:
a) the organization benefit by:
• Becoming more competitive, by providing a job architecture, established in many companies, that is considered an important
employer selection factor
• Clearly defining different roles and their corresponding level of responsibility, as well as defining value adding hierarchical levels,
thus supporting career development programs
• Providing a solid building block for rewards programs, linking them to the role in the organization
b) the Employees benefit by:
• Minimizing subjectivity and enabling rational, consistent, and transparent decisions about roles
• Allowing them to see where they fit within the organization.
• Helping them understand their relative position within the organization.
• Empowering them to navigate their own career paths.
• Providing the ability to manage their own development plans.
• Unlocking multiple opportunities across the business.
The Policy integrates seamlessly with core human resources systems, including talent management, compensation, and workforce planning. It
supports dual career paths, enabling Employees to advance either through managerial roles or as individual contributors, based on their
expertise and aspirations. Role evaluations are conducted objectively, focusing on responsibilities, required competencies, and their impact on
the organization, ensuring a transparent and equitable approach.
The Policy is reviewed periodically to ensure that the framework remains aligned with market standards, GRI Standards and organizational
needs and is uploaded to the Group’s Intranet, where it remains available for all Employees. The Policy applies to all Employees of the Bank
and the Group Companies, except for any specific requirements and adjustments to individual issues. These exceptions must be approved by
the Executive Committee, adhere to the local, supervisory, and legislative provisions of the countries where the Group operates.
In 2025, Alpha Bank reaffirmed its commitment to career progression and talent development through the design of a structured career
pathing framework. This initiative provides Employees with clearly defined career trajectories, outlining required skills, experiences, and
development opportunities. By integrating this framework with key HR systems and policies, Alpha Bank has fostered a holistic approach to
internal mobility, enabling structured development, succession planning, and career progression.
Linking Policies with Actions related to Diversity
Along with the abovementioned Policies, since 2022 the Group has adopted and throughout the years enhanced a modern framework against
violence and harassment at the workplace and since 2023, the Bank developed its DE&I Strategy, consisting of five DE&I focus pillars:
• Gender Diversity: A framework of interventions has been developed to promote equal opportunities in professional development,
performance evaluation, and rewards, with a strong focus on women's personal growth. The program “A.W.A.R.E.” (Alpha Women,
Authentic, Resilient, Empowered), is the starting point for female empowerment. It has implemented a comprehensive framework
over the past years to promote gender equality and personal development for women. Key empowerment initiatives include the
Group’s mentoring and educational programs as Trading Alpha Brains (TAB),PosiDives, SheForHe, Bankers and Daughters. The last
two programs were not implemented in 2025.
• Generational Diversity: The Group offers students hands-on experience through short- and long-term internships and provides
young professionals with full-time roles via fixed-term contracts.. The Group also runs two Accelerator Programs in Retail and
Wholesale, supporting over 200 young professionals in their career development. Additionally, the Young Enthusiasts Society (YES)
fosters a vibrant community for Employees under the age of 30, encouraging engagement, skill-building, and collaboration across
departments.
• Health Equity: The Group promotes health equity by offering disability-related leave, reduced working hours, and financial
assistance, including support for child health issues. Employees and their families have access to comprehensive health and life
insurance plans, outpatient coverage, and savings plans. Additional benefits for parents include childbirth allowances, day-care
support, and flexible working arrangements. On-site medical care is provided by two physicians with fully equipped dispensaries. To
further support well-being, the Wellbeing Employee community designs initiatives focused on mental health, work-life balance,
financial wellness, and physical health.
• Financial Inclusion: Financial equity is one of the cornerstones for the professional development of Alpha Bank’s Employees.
Financial equity aims to create more informed citizens who make wiser financial decisions and thus become responsible consumers
& better bank Customers for the benefit of the bank and the economy overall.
• LGBTQ+ inclusion: Among numerous trainings in matters related to inclusion, the Group has also launched a large-scale awareness
program for people managers focused on identifying and preventing unconscious bias, reinforcing a culture of fairness, dignity, and
support.
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Code of Conduct and Ethics
Policy Scope: Entire workforce and business partners
Policy Implementation Oversight at the highest organizational level: Chief Compliance Officer (CCO)
Alpha Bank Group has introduced a Code of Conduct and Ethics, approved by the Board of Directors through the Corporate Governance
Sustainability and Nominations Committee, which describes the Group’s commitments and rules of conduct applicable to the inte ractions
between its Executives, Employees, transacting parties and shareholders. The Group attaches great importance to matters of ethics and
transparency and has in place clear rules regarding the protection of personal data, the prevention of bribery and conflicts of interest, as
presented also through Double Materiality Assessment, see section [SBM-3] Material impacts, risks and opportunities and their interaction
with strategy and business model.
The Code’s main objectives are to:
• Inform all Employees about Alpha Bank’s values and specific procedures, measures and practices they must follow to ensure a
healthy working environment as well as legal and regulatory compliance throughout the Group,
• uphold ethical business conduct, regulatory compliance, and corporate transparency across all Group operations, establishing the
foundation for integrity, accountability, and responsible corporate governance and ensuring alignment with the Group’s values and
regulatory obligations. It is directly linked to the material impacts, risks, and opportunities identified through the Group’s double
materiality assessment (e.g. ethical conduct, fair treatment, secure employment, social dialogue, and non-discrimination).
• Promote all five Diversity, Equity and Inclusion pillars in the workforce and avoid all types of discrimination, harassment o r
inappropriate behavior between all Employees, and
• support a corporate culture, where Employees are protected, empowered, and encouraged to uphold ethical standards.
The process for monitoring its adherence includes structured compliance frameworks, periodic internal audits, oversight by the Corporate
Governance Sustainability and Nominations Committee, and dedicated training programs. Additionally, whistleblowing mechanisms and
grievance procedures enable Employees to report unethical behavior or Code violations.
The Code of Conduct and Ethics supports Alpha Bank Group’s sustainability commitments by aligning with internationally recogn ized third-
party standards, including the UN Global Compact principles, the OECD Guidelines for Multinational Enterprises, and the Global Reporting
Initiative (GRI) Standards. These frameworks guide the Group’s approach to ethical business conduct, human rights, fair treat ment, anti-
corruption, and responsible corporate governance, and underpin the relevant disclosures under the European Sustainability Reporting
Standards (ESRS).
The Code of Conduct and Ethics is uploaded to the Group’s Intranet, where it remains available for all Employees.
Violence and Harassment Prevention Policy
Policy Scope: Entire workforce
Policy Implementation Oversight at the highest organizational level: Chief Human Resources Officer (CHRO)
The Group has a zero-tolerance approach to any form of harassment, including sexual harassment and domestic violence that could potentially
affect the workplace environment. The Violence and Harassment Prevention Policy sets the framework for preventing as well as addressing
workplace discrimination, violence, and harassment, ensuring a respectful and dignified environment. The Policy is applicable to all Employees,
contractors, interns, as well as all related stakeholders and has been designed and implemented according to Greek Law 4808/2021, which
ratified the ILO Conventions No. 190 and No. 187 and transposed the Directive (EU) 2019/1158 of the European Parliament and of the Council.
The Violence and Harassment Prevention Policy is uploaded to the Group’s Intranet, where it remains available for all Employees.
It establishes clear mechanisms for reporting, investigating, and taking appropriate actions to resolve incidents confidentially and impartially.
Reports of workplace violence, harassment, or discrimination are assessed through a structured process that ensures fairness, objectivity, and
protection of all parties involved. The Evaluation Committee for Reports and Complaints is responsible for reviewing all submitted cases and
determining appropriate actions, with strict adherence to confidentiality principles and non-retaliation safeguards.
Support and protection for victims are prioritized, and the Group commits to raising awareness through training and resources to prevent
future occurrences. Any form of retaliation or malicious reporting is strictly prohibited, ensuring a safe reporting system and compliance with
legal obligations. The Policy explicitly covers discrimination based on gender, race, color, ethnic or social origin, genetic characteristics,
language, religion or beliefs, political opinions, disability or health status, age, or sexual orientation.
The monitoring process for the Violence and Harassment Prevention Policy is structured in such a way to ensure its continuous
implementation and effectiveness. The Corporate Governance, Sustainability, and Nominations Committee is responsible for overseeing the
enforcement of the policy, ensuring that incidents are managed in a manner consistent with legal and regulatory requirements.
Additionally, awareness and training programs are regularly conducted to reinforce the Group’s zero-tolerance approach and to educate
Employees, contractors, and stakeholders on identifying and preventing workplace violence and harassment. Periodic internal reviews and
audits ensure compliance with the policy, while benchmarking against industry best practices and legal standards provide a framework for
continuous improvement. Any corrective actions required due to identified policy breaches or gaps are implemented to enhance workplace
safety and maintain a respectful and inclusive environment. The Violence and Harassment Prevention Policy is aligned with internationally
recognized third-party standards and frameworks for responsible business conduct and human rights. In particular, it reflects the principles of
the UN Global Compact, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and relevant Global Reporting
Initiative (GRI) Standards. Through this alignment, Alpha Bank reinforces its commitment to providing a safe, respectful, and inclusive working
environment, and supports transparent and comparable disclosures on workplace practices in line with international sustainability reporting
standards.
Remuneration Policy for Employees
Policy Scope: Entire workforce
Policy Implementation Oversight at the highest organizational level: Chief Financial Officer (CFO)
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The Remuneration Policy of Alpha Bank and the Companies of the Group establishes a structured framework for Employee compensation,
ensuring compliance with Greek laws, European Banking Authority (EBA) guidelines on sound remuneration policies under Directive
2013/36/EU, and financial best practices.
The Policy aims to attract and retain skilled Employees, encourage long-term sustainable performance, and align Employee remuneration with
strategic objectives and the group’s risk management framework. This Policy is gender neutral, promotes equal pay for equal w ork, supports
diversity and inclusion and balances the fixed and variable components of remuneration, where the fixed component includes the base salary
and specific benefits and the variable component consists of performance-based bonuses.
This Policy also includes risk management mechanisms, such as malus and clawback provisions, prevents excessive risk-taking and ensures
accountability. Moreover, ensures that performance evaluation is based on a mix of financial, non-financial, and risk-adjusted criteria, ensuring
that remuneration decisions support long-term corporate stability.
The remuneration governance model aims at ensuring clarity and reliability in decision-making processes related to remuneration. The HR
function is responsible for the design and annual review of the Policy to ensure alignment with regulatory changes and market trends, while
the competent Control Functions review the implementation of the Policy, provide input regarding matters pertaining to its risk and
compliance aspects, as well as opinions where needed. The principles, structure and governance of this Policy are overseen by the
Remuneration Committee, as well as the Board of Directors. An independent review is carried out, at least annually, by the Internal Audit
function to assess the design, implementation and effects of this Policy.
Within this structured and comprehensive remuneration policy, Alpha Bank ensures sustainable growth while safeguarding the interests of its
Employees, shareholders and stakeholders. The key elements of the Remuneration policy of Alpha Bank and the other Companies of the
Banking Group are uploaded to the Group’s Intranet, where they remain available for all Employees.
Occupational Health and Safety Policy
Policy Scope: Entire workforce
Policy Implementation Oversight at the highest organizational level: Health and Safety Board
The Occupational Health and Safety Policy, uploaded to the Group’s Intranet where it remains available for all Employees, establishes the
framework for managing health and safety across the Group. Its purpose is to implement best practices and procedures, enhance
performance, ensure compliance with institutional and regulatory requirements, and safeguard the health, safety and well-being of its
Employees.
The Policy incorporates the Occupational Health and Safety Statement Policy Statement outlining the commitments and principles that guide
its implementation. It defines the scope and framework designed to meet these commitments, including compliance with regulatory and other
requirements, consultation processes etc.
Additionally, the Policy describes the procedures and processes that support the Health and Safety Management System, such as risk
assessment, incident investigation, training and change management. In an annual basis, internal audits are scheduled by internal and external
bodies in order to ensure the policy's requirements implementation and identify potential nonconformities and potential improvements.
Moreover, Alpha Bank Group implements, monitors, and continuously improves its Health and Safety Management System certified by an
accredited body in accordance with ISO 45001 standards. This system includes policies and procedures aimed at preventing workplace
accidents and promoting Employee well-being.
Connection between Policies and IROs
The abovementioned Alpha Bank Group’s internal policies are directly linked to the material Impacts, Risks, and Opportunities (IROs) identified
through the relevant assessment. Each policy supports one or more workforce-related topics. Specifically, the Corporate Responsibility Policy is
primarily linked to Workforce Equality and Justice, while the Code of Conduct and Ethics supports the material impact of Contribution to
Livelihood as well as Workforce Equality and Justice. The Remuneration Policy relates to the material impact on Workforce Livelihood, whereas
the Violence and Harassment Prevention Policy and the Diversity Policy directly support the impact area of Workforce Equality and Justice.
Additionally, the Career Framework Policy is connected to the material impact of training and skills development, including associated staffing
and training risks, and the Occupational Health and Safety Policy underpins the material impact related to workforce health and safety.
[S1-2] Processes for engaging with own workers and workers’ representatives about impacts
Alpha Bank Group has established various comprehensive processes and initiatives for engaging with its workforce and workers’
representatives to address actual and potential risks and impacts. These processes are part of the entire Group’s ongoing due-diligence efforts
to ensure that Employees’ feedback, as key internal stakeholders, informs its decisions and activities effectively.
The Chief Human Resources Officer (CHRO) ensures that engagement efforts are happening throughout the year and that the relevant result
and feedback is communicated to the Group’s leadership as well as the entire workforce, along with remedial actions. Engagement with
workers’ representatives is pursued through regular in-person meetings, complemented by more frequent telephone communications. In
2025, a total of thirteen (13) in-person meetings were held. Indicatively, engagement is pursued through:
Communication and Feedback
• Human Resources Outreach: The Human Resources (HR) function is primarily responsible for ensuring that all Employees are
approached and heard and that the feedback acquired by this outreach will be incorporated and will inform the Group’s approac h.
This responsibility for two-way communication is led by the Chief Human Resources Officer (CHRO), who, along with the HR directors
and Managers, plays a pivotal role in ensuring Employee engagement. The CHRO and the HR leadership team regularly convene to
discuss and address various Employee matters and concerns raised, to develop and implement new policies and strategies within the
Alpha Bank Group and align the Group’s business targets with the latest needs and expectations of its workforce. Moreover, th e
Group has established the role of HR Business Partners, who serve as the first point of contact for Employees of all business units and
branches, supported further by on-site visits for interpersonal communication and open discussions.
• Employee Feedback Channels: Alpha Bank Group maintains open lines of communication with its Employees to continuously gather
data, input and feedback, with particular attention to Employees included in vulnerable groups, helping to identify specific issues and
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areas for improvement. Indicatively, internal campaigns, tools such as the Speak-Up Line and internal Communities, provide
Employees with accessible platforms to voice concerns and share input. Moreover, Employee engagement surveys, frequent
feedback sessions, and annual 360◦ performance reviews help monitor the effectiveness of implemented policies and strategies,
making necessary adjustments and ensuring continuous improvement.
• Targeted programs and initiatives: The Group implements targeted programs and initiatives to gain valuable insight in the
perspectives of more vulnerable or underrepresented groups, such as women and people with disabilities within its workforce, to
further support their needs. The Diversity and Inclusion Program specifically addresses the needs and challenges faced by the
aforementioned employee groups, to enhance the support provided.
Labor Agreements and Employee Representation
The Group respects and fully complies with the Employees’ right to unionize and take part in collective bargaining discussion s and agreements,
by engaging with worker representatives to discuss and negotiate on matters affecting the workforce.
• Special Corporate Collective Labor Agreement: The Top Management team of Alpha Bank Group Personnel Union jointly concluded
a Special Corporate Collective Labor Agreement, which also further reinforced policies that prevent, address and eliminate violent
and harassing behaviors in the workplace. A Sectoral Collective Labor Agreement (CLA) covers the entire banking sector, while
Corporate Collective Labor Agreements (CCLA) cover all permanent Employees of the Alpha Bank Group.
• Engagement with Unions: The Alpha Bank Group Employees Association closely collaborates with HR, with monthly meeting
discussions for topics related to Employee welfare, workplace policies, and other relevant issues. This collaboration and mutual
engagement effort provides a structured platform for open dialogue and ensures that Employee voices are heard and considered in
decision-making processes.
Employee Engagement Survey
The Group implements a systematic, structured, biennial Employee engagement survey designed to capture Employees’ perceptions of the
working environment, leadership, communication, and organizational culture. The survey forms an integral part of the Group’s broader
commitment to responsible people management and continuous improvement.
The 2024/25 survey was conducted from December 2024 to January 2025 and recorded an 84% response rate, with 5,334 Employees
participating across the Group including 2,880 qualitative comments. Results were communicated to management and Employees, and all
people managers received detailed reporting for their teams along with guidance on developing targeting action plans to foster open dialogue
and address areas for improvement.
Due to a significant organizational restructuring in Greece, it was determined that conducting an earlier iteration of the Employee engagement
survey in 2025 would not provide valid and comparable results. Consequently, a single survey iteration was conducted, which began on
December 15
th
2025 and will be concluded in 15
th
January 2026, the final results of which will be included in next year’s statement.
Communications with own workforce for engagement in health and safety issues
Alpha Bank Group prioritizes consultation and active engagement with Employees on health and safety matters. To achieve this, the Group has
implemented multiple communication channels and initiatives that allow Employees to raise concerns, share ideas and suggestions, identify
risks, participate in self-assessments and provide feedback on health and safety perceptions.
Key surveys and initiatives in 2025 include:
• “Stop Smoking” Survey: Designed to assess interest in quitting smoking and offer participation in on-site “Stop Smoking” clinics.
• Wellbeing Questionnaire: Establishing a baseline for Employees’ self-assessed wellbeing index.
• Wellbeing Index Integration: Added to the Employee satisfaction survey for continuous monitoring
Communication Channels:
• A dedicated mailbox where Employees might suggest ideas, raise concerns and provide feedback on health and safety matters
• A specific category within Success Factors for communication related to health and safety
Additional engagement methods:
• Encouraging Employee participation in events organized under health and wellbeing campaigns
• Regular meetings with the Employees’ Health and Safety Board
Adherence to human and labour rights
Alpha Bank Group has established a transparent and equitable remuneration framework that ensures compliance with labor regulations,
including minimum wage, working hours, and leave, while promoting gender neutrality, equal pay for equal work, and merit-based career
advancement, in alignment with national labour market standards. As mentioned in above (S1-SBM3), Alpha Bank Group operations
are
primarily concentrated in the European Union, where stringent regulations and oversight mechanisms are in place to prevent
cases of child labor, forced labor, compulsory labor and human trafficking. The Group is committed to safeguard human rights
through adherence
to all applicable national and European laws, as well as protecting the rights of Employees as established under national
and EU law and the ILO conventions.
Group Communities linked to material impacts
To promote collaboration and networking, Alpha Bank Group facilitated the establishment of the “Communities of Change” in 202 1, which are
Employee groups based on shared interests or characteristics. These communities encourage learning from diverse experiences, sharing best
practices, building cross-functional alliances, and enhancing the Employee value proposition. They provide safe, supportive spaces for
Employees to connect, grow professionally, and foster cultural awareness.
These communities are closely aligned with the Group’s strategic workforce priorities and play a vital role in fostering shar ed goals and
collective growth. Specifically:
• Alpha Ithacans (related to Diversity and Inclusion): Formed in July 2021, the Alpha Ithacans Community brings together a total of 102
Employees who have been repatriated through their employment at Alpha Bank since 2019. Its mission is to exchange knowledge,
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best practices, and diverse experiences to drive change and improve effectiveness across the Bank. The community also support s
Alpha Bank’s “Future Ithacans” initiative, encouraging Greeks abroad to consider returning and joining the organization, with
outreach events held in cities like London, New York, Amsterdam, and Düsseldorf.
• Agile Bankers (related to Diversity and Inclusion): Established in February 2021, the Agile Bankers Community includes
approximately 170 members focused on cultivating an agile mindset across Alpha Bank. Through regular meetups, workshops, and
participation in the Agile Academy (ACE), the community promotes leadership engagement, expands agile squads, and fosters
continuous learning to support the Bank’s transformation goals.
• Datah0l1cs (related to Diversity and Inclusion and Working Conditions): Launched in April 2024, the Datah0l1cs Community supports
Alpha Bank’s digital transformation by enhancing data literacy among Employees. With 376 members from various business areas,
the community offers a collaborative space for sharing ideas, learning tools, solving case studies, and developing leadership through
peer training. It empowers both novice and experienced data users to grow their skills and contribute to innovation, while
simultaneously raising data and AI awareness across the Bank.
• Young Enthusiasts’ Society (YES) (related to Diversity and Inclusion and Working Conditions): Founded in March 2024, YES is a
vibrant community of over 450 young Employees under the age of 29. It aims to empower early-career professionals by offering
tailored training, career development coaching, and a collaborative environment. Through networking, educational programs, an d
cross-departmental initiatives, YES helps young talent thrive and actively shape the Bank’s culture and future.
• Wellbeing Community (related to Wellbeing): Launched in November 2024, the Wellbeing Community is dedicated to promoting
holistic wellness across Alpha Bank. With its 141 members, it provides Employees with resources and activities focused on mental
health, emotional balance, physical wellbeing, and resilience. Through workshops and open discussions, the community fosters a
supportive culture where wellbeing is an integral part of everyday work life.
Additional Communities of Change are being designed and will be launched in 2026, to further strengthen cross-functional collaboration, peer
learning, and meaningful connections across the Group around the pillars of Diversity and Inclusion, and Wellbeing.
[S1-3] Processes to remediate negative impacts and channels for own workers to raise concerns
As per the previous section [S1-2], Alpha Bank Group provides multiple accessible channels for its entire workforce to raise concerns and
maintain an open line of communication to ensure that all Employees are heard and feedback is further leveraged for tailor-made action plans
to address potential shortcomings.
Cases related to human rights are primarily handled by HR Business Partners (HRBPs), who act as direct liaisons with Employees and are
specialized in understanding the unique needs and challenges of Employees within their specific business units. In an effort to make the
communication process more accessible, Employees can schedule meetings via the “Talk2Us” app or the “AskHR” app and report irregularities
through the internal “SpeakUp” and Whistleblowing mechanisms, managed by HR Operations and Regulatory Compliance respectively, while
all labor disputes are resolved in line with the Bank’s Personnel Regulation.
Employees are always encouraged to report incidents of discrimination and harassment, either in writing (signed or anonymously) or via
telephone, email or through the dedicated “SpeakUp” mechanism. All reports are treated with the utmost confidentiality, care and discretion,
with fair, timely, thorough, and objective investigations of reported incidents being conducted by the designated bodies, overseen by the
“Assessment Committee for reports or complaints related to discrimination, violence and harassment incidents”. The Group has also reserved
the authority to take necessary measures and impose appropriate sanctions on any individual exhibiting discriminatory or harassing behavior.
Grievance or Complaints Handling Mechanisms Related to Employee Matters
Alpha Bank remains committed to maintaining transparent and effective grievance or complaints handling mechanisms to address all
Employee concerns promptly and fairly. The currently implemented approach includes multiple channels through which Employees can raise
their grievances, including anonymous reporting options to protect their privacy and encourage openness.
The grievance handling process is designed to be transparent, impartial, and efficient. It involves the following key steps:
1. Submission: Employees can submit their grievances through various channels, including an online portal, email, or dedicated hotline.
2. Acknowledgment: Upon receipt, an acknowledgment message is sent to the Employee, confirming that their concern has been
received and will be addressed.
3. Investigation: A thorough investigation is conducted by the designated team to gather all relevant information and ensure an
unbiased review of the concern.
4. Resolution: Based on the findings of the investigation, appropriate actions are designed and enforced to resolve the issue. The
approach may include different measures or even a combination of measures, such as mediation, corrective measures, or
disciplinary actions if necessary.
5. Feedback: The outcome of the investigation and resolution process is communicated to the Employee, along with the actions taken
to address their concern. Where applicable, employee satisfaction feedback is reviewed in order to determine how to improve t he
resolution process and address ongoing concerns more adequately, thereby improving overall satisfaction in using the channels.
Alpha Bank Group ensures that all Employees are aware of their right to use the grievance mechanism and raise their concerns without fear of
retaliation. Regular training sessions and communication campaigns are conducted to promote awareness and understanding of the grievance
process and address potential questions Employees may have.
Employee Communication and Support
The Group has implemented various processes to support and mandate the availability of communication channels to all Employees, which are
crucial for maintaining transparency, addressing concerns, and fostering a positive work environment. Indicatively:
• Relevant Policies and instructions on how to use the channels are available at the Group’s Intranet, where every Employee can easily
access them. The Intranet serves as a centralized repository for all policy documents, ensuring that Employees have immediate
access to the latest versions, including detailed guidelines on how to report concerns, the procedures for handling reports, and the
support available. This way it is ensured that all Employees are well-informed about the processes in place to address their concerns
and needs.
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• Through the Intranet, every Employee can contact the Human Resources Business Area to discuss work-related concerns, as well as
matters related to health, safety, and wellbeing, via specially designed channels such as SpeakUp and Talk2us. In these channels,
each concern is carefully reviewed, and the Employee is kept informed about the status of their request. Where applicable follow-
ups are conducted to ensure that issues are addressed appropriately.
• The Violence and Harassment Prevention Policy explicitly prohibits any form of retaliation against Employees who report concerns
and also outlines the procedures for reporting incidents, investigating complaints, and taking appropriate actions to resolve issues.
More specifically, it designates a specific individual responsible for receiving all relevant reports and the processes to ensure the
prevention of related future occurrences.
• The Whistleblowing Policy aims to promote transparency and integrity within the organization by encouraging not only Employees,
but also Customers, and suppliers to report any incidents of fraud, corruption, coercion, or other violations of the Bank’s p olicies and
procedures. This Policy ensures that reports can be made in good faith and with reasonable belief that an offense has been or may
be committed. It also safeguards the anonymity of whistleblowers and outlines the procedures for investigating and addressing
reported incidents. Alpha Bank monitors the effectiveness of its reporting and whistleblowing mechanisms, including indications
related to Employee confidence in these channels, in order to ensure their continued relevance and reliability.
Health and Safety Mechanisms in place for Employees to voice their concerns
The Group actively promotes Employee engagement and open communication as essential for improving procedures, implementing
meaningful interventions and organizing impactful initiatives. To facilitate this:
• A dedicated Health and Safety mailbox has been established and communicated through via the Intranet, enabling Employees to
raise concerns, report risks, and share suggestions on health and safety.
• The Employees Health and Safety Board, widely recognized within the organization, consists of members elected by Alpha Bank
Employees. Before each meeting, the Board invites Employees to submit concerns for inclusion in the agenda.
• A Health and Safety category within the SuccessFactors app provides an additional channel for Employees to voice issues and access
relevant resources.
[S1-4] Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing
material opportunities related to own workforce, and effectiveness of those actions
Alpha Bank Group carefully considers any potential impact on its workforce and has implemented a wide range of measures to ensure their
safety, well-being, and professional development, including proactive risk mitigation strategies, continuous monitoring of working conditions,
and the promotion of a supportive and inclusive work environment.
Key actions for own workforce
Equal treatment and opportunities for all
Alpha Bank Group invests in continuous training and professional development opportunities of its workforce to ensure that Employees are
equipped with the necessary skills and knowledge to implement the newest processes and systems. The impact and effectiveness of these
programs are evaluated through the assessment of participation rates, performance metrics, feedback questionnaires as well as their actual
influence on employee performance and career progression.
In collaboration with external organizations that specialize in supporting women and people with disabilities, Alpha Bank Group is actively
utilizing their expertise to create a more inclusive and supportive work environment.
Throughout the reporting year, the implementation of key policy objectives was supported by actions that contributed to the Group’s targets
through impactful programs, initiatives and partnerships. The following initiatives were available for all Employees of the Group, or to specific
categories of Employees as well as junior professionals or university students, depending on the programs’ scope and objectives, as described
below:
Trainings
• The “Unconscious Bias” Training, introduced initially to Managers and Directors is a cornerstone of Group’s strategy to prevent
discrimination and promote diversity. It helps Employees recognize and understand unconscious biases that may influence their
decisions and interactions and equips them with practical tools to mitigate these biases and foster an environment of fairness and
respect. The program also strengthens the Employees’ understanding on the Group’s non-discrimination policies, ensuring alignment
with organizational values. The training is delivered on an ongoing basis, through interactive workshops, case studies, and real-life
scenarios that encourage meaningful dialogue and reflection.
• Code of Conduct Training: Approximately 90% of Alpha Bank Employees have completed the mandatory Code of Conduct training
programme. Delivered to all Employees on an ongoing basis, the programme supports the Bank’s efforts to prevent and address any
form of discrimination, harassment, or misconduct. It sets clear expectations regarding professional behaviour towards colleagues,
Customers, suppliers, and contractors, thereby promoting the Group’s values and its commitment to ensuring a safe, respectful, and
inclusive working environment.
Leadership Development Programs
• The Group’s leadership development initiatives play a critical role in strengthening an inclusive, high-performance culture and
supporting long-term organizational transformation. These programs, including the “Leading for Impact” initiative equip leaders with
the skills required to model and promote for inclusive behaviors, navigate complexity, collaborate across boundaries and driv e
sustainable change. Leaders are trained to recognize and address bias in workplace dynamics and decision-making processes, take
corrective actions where needed, and foster teams where Employees feel safe to express themselves without fear of unfair
treatment. “Leading for Impact” further aligns senior leaders with the Bank’s renewed Purpose, reinforcing coherence between
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leadership behaviours, organisational values and strategic direction, and serving as the foundation of a continuous, multi-year
leadership development framework.
Mentoring programs
• TAB Mentoring Program: Building on the inaugural cycle in 2021, the second cycle began in 2024 and runs through 2026. Thirteen
mentors (at Director level) are paired with twenty-six mentees from frontline and central services, participating in eight mentorship
sessions followed by project development.” This program strengthens leadership capabilities and professional networks, reaffirming
Alpha Bank’s commitment to gender equality and career development.
• The “Economy Class” program, took place for a second consecutive year and was addressed to female Employees of the Bank. It was
conducted in collaboration with the NGO “WHEN”, aiming to strengthen the financial resilience and confidence of the participa nts
through Financial Coaching. In 2025, the initiative offered four personalized sessions to 20 selected participants. For more
information the financial literacy programs undertaken by Alpha Bank please refer to “Entity-Specific Information” in the
Sustainability Statement.
• The “PosiDives” program was a key initiative within the Bank's DE&I strategy, exclusively addressed to female Employees. Designed
to empower women in managerial positions, the program fosters positive thinking, strengthens support networks, and cultivates a
collaborative culture. The inaugural 2024 cycle of PosiDives included 110 senior women Managers, Experts, and Branch Managers,
who were actively engaged in professional growth and leadership development for a multiple month-period. Conducted in
collaboration with an external partner, this included training sessions, inspiring talks from influential speakers, and interactive Q&A
sessions to encourage open discussions and shared learning. Notably, 68% of participants rated the overall value of the progr am at 9
or 10, and the program achieved an impressive average participation rate of 70%.
• “PosiTribes” program: Introduced in November 2025, PosiTribes expands empowerment to over 100 men and women, focusing on
leadership skills, positive mindset, resilience. Building on the success of PosiDives, this new ongoing program continues the mission
of empowering Employees by enhancing leadership skills and fostering a positive mindset throughout the organization. The program
includes 4 training sessions and 2 inspirational talks over 5 months, aiming to create a movement of positivity across Alpha Bank.
Acceleration programs
• Alpha Bank has integrated "Acceleration Programs" into its Talent Acquisition Strategy to attract young talent across various Lines of
Business. These ongoing programs are designed for individuals with little to no prior work experience, incorporating transparent and
highly reliable skills assessment methodologies to unlock candidates’ potential. All successful participants begin their journey with a
six-month probation period, which transitions into permanent employment upon consistent performance. In 2024 over 200 young
professionals participated in Retail and Wholesale accelerator programs. In 2025 the number of young professionals is 218 for Retail,
Wholesale, and CRO.
Internships
• Alpha Bank offers internships to both university graduates and undergraduate students, with durations ranging from 1 to 12 months,
tailored to individual needs, skills and area of interest. This ongoing initiative often serves as a pathway to future employment,
depending on organizational requirements. In 2024, 119 young professionals were benefited out of which 100 individuals were
under 30. By the end of 2025, the total number of active internships reached 115 individuals while the total number of hires up to 30
years old was 102 individuals. In addition to this, the Summer Internship Cycle in 2025 involved 29 students from the second year of
their studies, representing both Greek and international universities, with 11 participants coming from foreign institutions.
Building Connections with Universities
• The Group actively supports and participates in career events organized by universities to bridge the gap between the corporate
environment and students’ career development. Additionally, Alpha Bank hosts "Business Days" annually, inviting students and
graduates to engage directly with industry leaders. Alpha Bank’s "Business Days” have welcomed many participants for three
consecutive years. These events provide a valuable platform for participants to meet business leaders, gain insights into banking
operations, learn about work methodologies, and explore critical experiences that can shape their future careers.
To further enhance the effectiveness of its Policies, the Group has undertaken several key actions amongst which:
• Training and Development: Continuous training and development programs to enhance Employee skills and career growth.
• Employee Engagement: Regular Employee engagement surveys to gather feedback and improve workplace conditions.
• Diversity Initiatives: Programs’ launches to increase the representation of diverse groups within the workforce.
• Leadership Development: Establishing programs to cultivate future leaders within the organization.
Working Conditions
To support Employee physical and mental well-being, as well as to provide support for their family needs, the Group has established provisions
regarding:
• extra days of leave in cases of people with disabilities or family members with disabilities for Employees considered caregivers
• extra days of leave or reduced working hours for parental support (parent-teacher meetings etc.)
• extra days of leave in cases of hospitalization of family members, undergoing assisted reproduction processes, or mourning
• financial assistance in certain cases, and extension of said financial support in cases of child health issues or disabilities
• monthly welfare benefit for Employees and pensioners who are blind or suffer from kidney failure
• additional leave days for Employees attending undergraduate or masters programs
• free psychological support sessions and annual health check-ups
• the on-site presence of three health physicians
• childbirth allowance or specific cash benefits for Employees’ children (e.g., Christmas gift cards or gift cards at the begin ning of the
school period) as well as daycare benefits
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All provisions and benefits mentioned above have been adopted, based on international best practices and according to Group strategic
decisions, to enhance the working conditions and improve the well-being of all Employees. The implementation of these provisions is ongoing,
according to Group strategic plan and decisions, and are available to all Employees of the Group, based on their needs and family status, and
relevant information on specific requirements can be accessed in the Group’s Intranet, under the corresponding section.
Moreover, in collaboration with Generali Hellas Insurance, the Group provides the following programs to its permanent Employees, including
their family members, in Greece:
• Health and Life Insurance Plan
• Outpatient Insurance Plan
Health and Safety
Alpha Bank Group recognizes Health and Safety as an area of material impact on its workforce. Thus, a Strategy on Health, Safety and
Wellbeing has been approved, structured around the following three pillars, with launches and implementation of initiatives and actions
around them:
• mental health,
• modern workplace, and
• resilience and readiness
The Group fully complies with ILO requirements incorporated with European guidance and local regulations. To ensure compliance, as well as
meet and drive best practices in its sector, Alpha Bank Group implements, monitors and improves a certified, by an accredited body, Health
and Safety management system according to ISO 45001.
Alpha Bank Group also invests in mental health related initiatives to raise awareness and help initiate discussions around selfcare and
empowerment. Indicative actions include:
• A 24/7 psychological support hotline, aiming to improve response to mental health issues
• Increased free one-to-one sessions with psychotherapists
• An annual mental health campaign
• Workshops, videos, podcasts and other digital resources covering topics such as empowerment, psychological first aid, the
importance of sleep and nutrition for mental health, parenting burnout, digital detox and more, to improve resilience and strength
• Training sessions and workshops on stress management, resilience, and other essential soft skills
• Regular internal audits and inspections of buildings and infrastructure, to ensure a safe and risk-free workplace environment
• Environmental and health & safety assessments, including air and water quality, noise levels, lighting, and thermal comfort
• Pilot wellness programs at selected locations (e.g., Pilates sessions, equipped gyms with trainers), boosting physical and mental
health
• Workshops and training on ergonomics, the impact of sedentary lifestyles, and practical tools to improve workspace ergonomics,
aiming at preventing work related injuries
• On-site first aid training, to strengthen resilience
• ‘Stop Smoking’ clinics to support Employees, to improve the lives and health of Employees
The above initiatives are implemented on an ongoing basis, according to Group are available to all Employees of the Group strategic plan and
decisions, and related information or invitations are uploaded in the Group’s Intranet, where all Employees have access.
In addition, Alpha Bank Group launched, throughout 2025, several impactful initiatives under its DEI and sustainability pillars. These initiatives
and programs were designed to empower individuals, strengthen leadership, promote balance between personal and professional life as well
as embed sustainable habits into daily work practices. Below is an overview of key programs that reflect this commitment:
• “Parents’ month”: In June/July 2025, to celebrate Global Parents’ Day (June 1st), Alpha Bank Group introduced “Parents’ Month”, a
series of 10 webinars led by expert speakers. These sessions covered topics such as parenting challenges and practical tips,
emotional connection and safety, balancing roles as a professional, individual, and parent and Mental health topics (e.g.,
menopause, coping with internal pressure). The program attracted 2,553 total attendances with sessions providing valuable insights
to support both professional and personal growth, as well as reinforcing Employee wellbeing.
• “Do Good People” App: In 2025, Alpha Bank successfully rolled out the “Do Good People” mobile application to all Employees. T his
initiative stems from Alpha Bank’s collaboration with Do Good People, S.L., a Spanish company and one of the winners of FinQu est
2022 (3rd prize). Their innovative platform enables organizations to actively engage their workforce in sustainability through simple,
impactful daily actions. The “Do Good People” app offers an interactive experience that encourages Employees to adopt s ustainable
habits via engaging “Sustainability Challenges.” Through the app, participants:
o Complete actions aligned with Alpha Bank’s ESG goals.
o Share photos and experiences on the Bank’s internal “Wall.”
o Track both individual and team ESG impact in real time.
o Contribute to the UN Sustainable Development Goals (SDGs) through everyday choices.
Beyond action, the app fosters awareness about sustainability, promoting a sense of community, recognition, and fulfilment, while generating
long-term sustainable habits.
Effectiveness of actions for own workforce
The Group adopts a structured and holistic approach to monitoring and evaluating the effectiveness of its initiatives in generating positive
outcomes for its workforce. This includes tracking factors such as participation rates in programs, employee satisfaction levels, and overall
engagement, ensuring that initiatives deliver meaningful impact. Insights gathered through these measures allow for timely adjustments and
continuous improvement where needed.
The Group places strong emphasis on Employee training and engagement, implementing comprehensive programs that address key areas such
as regulatory compliance, anti-money laundering, and occupational health and safety. Engagement levels are regularly assessed through
structured Employee surveys, with the insights gained informing the continuous improvement of relevant policies and practices. Through these
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measures, Alpha Bank Group ensures that its initiatives effectively contribute to positive outcomes for both its workforce and broader
stakeholder community.
Current and planned actions for mitigating material risks and effectiveness of these actions
Alpha Bank Group has implemented a comprehensive set of actions to mitigate material risks related to its workforce and specifically areas of
Employee training and development. These actions have been designed to enhance workforce resilience, support business continuity, and
uphold ethical standards across all operations of the Group.
Mitigation Actions
• Continuous Learning & Development: Ongoing training initiatives, designed to strengthen Employee skills and adaptability,
facilitating a smooth transition into a digital era.
• Leadership Pipeline Development: Structured processes to identify and prepare future leaders, ensuring long-term business
continuity.
• Workplace Health & Safety: Targeted programs to promote a safe working environment and support both the physical and mental
health of Employees.
• Diversity & Inclusion Education: Training programs addressed to all Employees to highlight the significance of diversity in the
workplace and support the prevention of workplace discrimination.
• Performance Alignment: Employee performance alignment with organizational goals through a digital platform integrated with
Alpha Performance Dialogue (APD), with the use of scorecards to define objectives and reward achievements via bonuses and
incentives.
Effectiveness Measurement
To assess the effectiveness of these actions, the Group employs both qualitative and quantitative tools, focusing on areas where these
practices are expected to generate positive impacts. Key Performance Indicators (KPIs) include:
• Employee Turnover Rates: Used to identify retention challenges and evaluate the success of talent management strategies.
• Employee Satisfaction Surveys: Conducted regularly to measure engagement and satisfaction levels.
• Training Completion Rates: Monitored to ensure participation and effectiveness of learning programs.
• Health & Safety Incident Reports: Tracked to evaluate the safety of the working environment.
• Workforce Demographics: Analyzed to assess progress toward diversity and inclusion goals.
• Inclusion Surveys: Used to understand Employee perceptions of inclusivity within the organization.
• Cost-Benefit Analysis: Evaluates the financial impact of HR initiatives on organizational performance.
Data Privacy and Ethical Practices
The Group is committed to ensure that its operations do not cause or contribute to material negative impacts on its workforce, particularly in
areas such as procurement, sales, and data use. Specific measures to prevent such impacts include:
• GDPR Compliance: Strict adherence to data protection regulations ensuring that Employee data is collected, processed, and used
transparently and ethically.
• Responsible Procurement: The Bank performs thorough due-diligence and engages only with suppliers and service providers who
meet rigorous data privacy standards and respect its core values.
• Fair Sales Practices: Sales activities are designed carefully to ensure that Employees are not pressured to achieve unattainable goals
and that Employee and Customer data remain protected.
• Secure Data Use: Internal processes ensure responsible handling of Employee data, with clear consent and robust security protocols.
Cases of tensions between mitigating material negative impacts
In cases where tensions arise between mitigating risks and material negative impacts as well as other business pressures (e.g. privacy risks),
the Group maintains a balanced and principled approach, prioritizing the protection of its workforce and its Customers or wider stakeholders
(e.g. Employee data protection). This approach includes thorough and regular risk assessments and active engagement with Employees and
their representatives to co-develop solutions that are tailored to the Group’s needs.
Continuous Improvement
The Group’s commitment to continuous improvement is reflected in its systematic review and enhancement of internal policies a nd practices,
ensuring ongoing alignment with evolving privacy regulations and recognized best practices. To reinforce this commitment, the Group invests
in targeted training and awareness initiatives that cultivate a culture of accountability and ethical conduct, empowering Employees to
understand their rights and the safeguards in place to protect them. Transparency and accountability are foundational to these efforts,
supported by robust governance mechanisms and proactive risk management.
Alpha Bank Group demonstrates its dedication to maintaining a secure, equitable, and supportive working environment that prioritizes
Employee trust, safety, and well-being and acknowledges the pivotal role of Employee awareness and capability development in effectively
managing material sustainability impacts and as such, continuous training remains a strategic priority. These programs are designed to
empower Employees across all levels with the knowledge and skills needed to identify, understand, and address material impacts, focusing on
environmental stewardship, human rights, ethical business conduct, and regulatory compliance.
In addition, specialized training is provided to Employees in critical roles, enabling them to apply best practices and innovative approaches
within their areas of responsibility. By investing in targeted learning initiatives and cultivating a culture of continuous improvement, Alpha
Bank Group reinforces its commitment to sustainability, transparency, and stakeholder accountability. This integrated approach not only
strengthens risk mitigation and opportunity capture but also contributes to long-term value creation for the organization and its stakeholders.
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Resource Allocation
In managing material impacts, the Group has allocated significant resources to ensure that all potential risks are addressed in a structured,
efficient, and responsible manner. This includes a comprehensive framework supported by financial investments, specialized personnel, and
ongoing capacity-building programs designed to strengthen organizational expertise and resilience.
The Group has established dedicated teams and governance committees tasked with the identification, evaluation, and management of
material sustainability-related impacts. These units are equipped with the appropriate tools, systems, and resources to monitor performance,
implement remedial measures, and foster continuous improvement. Financial resources are strategically allocated to support key initiatives,
including sustainability programs, technological advancements, and collaborations with external experts and organizations, thereby enhancing
the Group’s capacity to manage sustainability impacts effectively.
[S1-5] Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and
opportunities
Alpha Bank Group has developed and included the following targets in its business plan, incorporating input from all internal stakeholders.
These targets are carefully monitored to assess the effectiveness of implemented measures and practices and provide quantitative
information on the Bank's progress in areas of key significance:
Table 46 Target tied to own workforce
Target description
Target level
Absolute / Relative
Baseline value
Baseline year
Target Year
Scope
2025
Maintain >40% of womens'
representation in managerial
positions
>40%
Relative
40%
2022
2027
Own operations
43%
Increase Youth employment
by 20%
20%
Relative
20%
2020
2027
Own operations
53%
Target: Maintain >40% of women’s representation in managerial positions
Alpha Bank Group is committed to maintaining a minimum of 40% representation of women in managerial positions, reflecting its dedication
to fostering an inclusive and equitable workplace. This target underscores its strategic focus on gender diversity as a driver of innovation,
balanced decision-making, and organizational resilience. Ensuring strong female representation in leadership roles not only promotes fairness
and equal opportunity but also enhances the Group’s ability to respond effectively to the d iverse needs of its stakeholders. By embedding this
target into its broader human capital and sustainability strategy, Alpha Bank Group reinforces its commitment to cultivating a culture of
meritocracy, empowerment, and long-term value creation.
Target: Increase Youth employment by 20%
The Group aims to increase youth employment by 20%, reflecting its commitment to empowering the next generation of professionals and
contributing to broader social and economic development. This target supports its strategic focus on talent renewal, innovation, and long-term
workforce sustainability. By actively creating opportunities for young individuals, Alpha Bank fosters fresh perspectives, enhances
organizational agility, and strengthens its capacity to adapt to evolving market dynamics. Moreover, thi s initiative aligns with the Group’s
broader ESG objectives, promoting inclusive growth, reducing unemployment among younger demographics, and reinforcing its role as a
responsible corporate citizen.
Both targets are currently monitored, and the relevant progress is presented annually. The overall target setting process included engagement
and consultations with various internal stakeholders. Although workforce representatives were not specifically included in the setting process
of the targets mentioned above, Employee feedback from other sources (e.g. internal surveys) was considered and the relevant annual
progress is available to all Employees. The Group remains committed to promoting and improving its practices related to material
sustainability topics.
Specifically:
• Tracking Effectiveness: robust processes are in place to monitor and assess the effectiveness of all targets. These processes include
regular internal reviews, stakeholder engagement, and data-driven assessments to ensure that Group’s actions align with its
objectives.
• Ambition Level: the Group has established a clear qualitative level of ambition that serves as a guiding framework for its efforts, with
measurable targets in developmental stage.
• Progress Measurement: the Group utilizes a combination of qualitative and quantitative indicators, carefully selected to reflect the
specific context and nature of the material impacts the Group addresses. Additionally, a baseline period is defined to measur e
progress consistently.
The Group has also acknowledged material impacts and risks related to “Contribution to Livelihood of own workforce”, “Trainin g and skills
development”, “Staffing and training issues”, “Contribution to health and safety of own workforce”, however, no specific targets have been
established yet for these. The Group remains fully committed to promoting and improving practices related to these material sustainability
topics.
[S1-6] Characteristics of Alpha Bank Group Employees
The workforce of Alpha Bank Group comprises a diverse group of Employees, reflecting a broad range of demographic and professional
characteristics. As of December 31, 2025, the total number of Employees stands at 6,992 encompassing various categories based on age,
gender, and employment type. The Group is committed to employ individuals across all age groups, ensuring a balanced mix of experience and
fresh perspectives. Gender representation is monitored to promote inclusivity and equal opportunity, while employment contracts include
both permanent and fixed-term arrangements, tailored to operational needs and strategic priorities. This structured and inclusive approach to
workforce composition supports the Group’s commitment to diversity, equity, and organi zational resilience.
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All data related to headcount are presented as of 31.12.2025 without including potential fluctuations throughout the year. During the
reporting period Employees of non-guaranteed hours, part-time Employees, as well as Employees of genders other than the ones presented
were not included in the workforce. All metrics are absolute numbers without significant assumptions or methodologies behind them and have
not been assured by an external third party.
Employees categories are defined as follows:
• Permanent Employees: individuals with employment contracts without a predefined end date.
• Temporary Employees: individuals hired for a specific period or project, under fixed-term contracts.
Table 47 Total Employee head count by contract type and gender
Headcount
Female
Male
Total
Female
Male
Total
Reporting Year
2024
2025
Total number of Employees
3,470
2,755
6,225
3,906
3,086
6,992
Number permanent Employees
3,370
2,664
6,034
3,756
2,953
6,709
Number of temporary Employees
100
91
191
150
133
283
The total number of employees by headcount, and breakdown by gender and by country for countries in which the undertaking has 50 or
more employees representing at least 10% of its total number of employees, can be found in the financial statements, on ‘staff costs’ note 10.
Table 48 Total Employee headcount in countries where the undertaking has at least 50 Employees representing at least 10%
of its total number of Employees.
Reporting Year
2024
35
2025
Country
Greece
Number of Employees (Headcount)
5,700
6,068
36
Country
Cyprus
Number of Employees (Headcount)
Ν/Α
815
37
Table 49 Number of Employees who left the Group and turnover rate
38
Reporting Year
2024
2025
Number of Employees who left the Group
748
565
Employee turnover rate (%)
12
8.1
[S1-8] Collective bargaining coverage and social dialogue
Alpha Bank Group recognizes the fundamental importance of collective bargaining and social dialogue in fostering a fair, inclusive, and
transparent working environment, which serve as essential pillars for promoting constructive engagement between the organization and its
Employees, ensuring that workforce-related decisions reflect shared interests and mutual respect. Through active participation in collective
agreements and open dialogue with Employee representatives, the Group supports the protection of labor rights, enhances workplace
relations, and contributes to long-term organizational stability and Employee well-being.
As of December 31, 2025, the majority of Alpha Bank Employees are covered by at least one of the applicable collective bargaining agreements
(i.e. national collective bargaining agreement, sectoral collective bargaining agreement and company-level collective bargaining agreement),
with the Alpha Bank S.A. Employees' Association serving as the primary platform for Employee representation. In 2025 thirteen (13) meetings
convened with both management team and union representatives present. Although the Group does not have specific agreements for
representation of Employees by the European Works Council (EWC), Societas Europaea (SE) Works Council, or Societas Cooperativa Europaea
(SCE) Works Council, their rights and input are represented and facilitated through the Alpha Bank S.A. Employees' Association. Alpha Bank
Group Employees outside the EEA, specifically in the United Kingdom, are not covered by collective bargaining agreements.
The following metrics are absolute numbers without significant assumptions or methodologies behind them and have not been assured by an
external third party.
Table 50 Employees who are covered by collective bargaining agreements and social dialogue
Type of coverage
Collective Bargaining Coverage
Social Dialogue
Coverage rate
Employees – EEA (for countries with >50 employees
representing >10% of total employees)
Workplace representation (EEA only)
(for countries with >50 employees representing >10% total employees)
Year
2024
39
2025
39
2024
39
2025
39
80 – 100%
Greece (100%)
Greece (100%), Cyprus (97%)
Greece (100%)
Greece (100%), Cyprus (100%)
Table 51 Share of total Employees who are covered by collective bargaining agreements
Type of coverage
2024
2025
Percentage of total Employees who are covered by collective bargaining agreements (%)
98%
98%
35
In 2024, Greece alone accounted for 10% of the total workforce, while Cyprus was considered non‑significant.
36
The above number consists of 2,685 male and 3,383 female Employees.
37
The above number consists of 339 males and 476 female Employees.
38
The Employee turnover rate (%) has been compiled with data on Employees who left the Group voluntarily and non-voluntarily, including dismissals,
resignations, voluntary separation schemes, fixed-term contract terminations, deaths in service, sabbatical leaves and other. In the turnover rate calculation, the
total Employee head count as of 31.12.2025 was used as the denominator.
39
As of 31.12.2024 only Greece satisfied the requirement of 50 employees representing more than 10% of the Group’s total employees, while as of 31.12.2025
this is also applicable for Cyprus.
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[S1-9] Diversity metrics
The Group is committed to promoting gender diversity and equal representation across all levels of the organization, including top
management. The table below presents the gender distribution in both absolute numbers and percentages, offering a transparent view of the
current composition of leadership roles.
Monitoring gender representation at the highest levels of decision-making is a key component of the Group’s broader diversity and inclusion
strategy, aimed at fostering balanced leadership, enhancing organizational performance, and ensuring that diverse perspectives are reflected
in strategic planning and governance.
The following metrics are absolute numbers without significant assumptions or methodologies behind them and have not been assured by an
external third party.
Moreover, top Management incudes all members of the Senior Leadership Team (SLT) defined as individuals with executive responsibilities,
responsible and accountable to the management body for the day-to-day management of the institution, including Key Function Holders
(KFHs). The following roles are included in the Senior Leadership Team:
• CEO
• Chiefs who are members of the Executive Committee (Chiefs-ExCo)
• Chiefs who are part of the SLT but not members of the Executive Committee (Chiefs Non-ExCo)
Table 52 Gender distribution in number and percentage at top management level
Gender distribution in number and
percentage at top management level
40
2024
(#)
2024
(%)
2025
(#)
2025
(%)
Female
14
20%
18
24%
Male
56
80%
57
76%
Alpha Bank Group monitors the age composition of its workforce as part of its commitment to diversity, inclusion, and strategic workforce
planning. The following table presents the distribution of Employees across three age groups: under 30, between 30 and 50, and over 50 years
old. This breakdown provides insights into generational representation within the organization, supporting efforts to balance experience with
innovation, tailor development initiatives, and ensure long-term organizational sustainability.
The following metrics are absolute numbers without significant assumptions or methodologies behind them and have not been assured by an
external third party.
Table 53 Distribution of Employees by age group
Distribution of Employees by age group
2024
(#)
2025
(#)
< 30 years old
479
667
30 to 50 years old
4,178
4,463
> 50 years old
1,568
1,862
[S1-11] Social protection
The entire workforce of Alpha Bank Group is covered by social protection provisions, as mandated by the applicable national legal framework,
enhanced by group-wide provisions in place which are in place to support Employees and their families. Indicatively, Alpha Bank Group has
established policies and practices to ensure extra days of leave or financial assistance in cases of:
• Employees with disabilities, caregivers or parents,
• sickness, maternity and paternity leave, Employees undergoing assisted reproduction
Moreover, in collaboration with Generali Hellas Insurance, the Group provides a Health and Life Insurance plan and an Outpatient Insurance
plan to its permanent Employees, including their family members, in Greece.
Lastly, alongside public benefits regarding retirement, the Group has also established:
• Voluntary Separation Schemes (VSS) which offer paid leave and severance packages for voluntary departures, ensuring financial
stability during transitions.
An Occupational Pension Fund Program (IORP – Institutions for Occupational Retirement Provision) that secures retirement benefits through
joint contributions as percentage of salary from Employees and Employer, with vesting period determined by age and enrolment years.
[S1-13] Training and skills development metrics
Employee training and development are central pillars of Alpha Bank Group’s strategic priorities, reflecting the Group’s comm itment to
fostering professional growth, enhancing skills, and ensuring long-term employability. Through targeted upskilling and reskilling initiatives,
Employees are equipped to adapt to evolving industry demands and contribute meaningfully to the organization’s success. All training
programs are systematically monitored to track participation and evaluate their effectiveness, ensuring continuous improvement and
alignment with business objectives.
Complementing these efforts, annual performance reviews are conducted to assess individual performance and contributions, provide
constructive feedback, and support career progression. These evaluations play a key role in identifying development opportunities and
reinforcing a culture of accountability and excellence across the organization.
The following metrics are absolute numbers without significant assumptions or methodologies behind them and have not been assured by an
external third party.
40
The top management level above refers only to Executive and Senior Management.
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Table 54 Percentage of Employees that participated in regular performance and career development reviews by gender (%)
Table 55 Average number of training hours per employee by gender
Gender
Female
Male
Reporting Year
2024
2025
2024
2025
Average number of training hours per employee (#)
42
35.2
43.8
32.0
41.3
[S1-14] Health and safety metrics
All data related to the percentage of people covered by a Health and Safety Management System are based to a headcount as of 31.12.2025,
without including potential fluctuations throughout the year. Health and Safety incident data are based on actual data from 1.1.2025 until
31.12.2025. The following metrics are absolute numbers without significant assumptions or methodologies behind them and have not been
assured by an external third party.
Table 56 Health and Safety Metrics
Reporting Year
2024
43
2025
Percentage of own workforce who are covered by health and safety management system (%)
N/A
97%
Number of fatalities in own workforce as a result of work-related injuries and work-related ill-health (#)
N/A
0
Number of recordable work-related accidents within own workforce
44
(#)
N/A
17
Rate of recordable work-related accidents within own workforce
N/A
1.59
Number of cases of recordable work-related ill health with regard to employees (#)
N/A
0
Number of days lost to work-related injuries and fatalities from work-related accidents, work-related ill
health and fatalities from ill health (#)
N/A
54
[S1-17] Incidents, complaints, and severe human rights impacts
Alpha Bank Group is committed to upholding the highest standards of ethical conduct and human rights across all areas of its operations. As
part of this commitment, the Group actively monitors and addresses incidents, complaints, and any severe human rights impacts that may
arise.
To reflect the Group’s dedication to transparency, stakeholder engagement, and the protection of fundamental rights the follo wing data
represents the total number of related incidents as well as the total amount of fines, penalties and compensation for damages as a result of
the incidents and complaints disclosed.
The following metrics are absolute numbers without significant assumptions or methodologies behind them and have not been assured by an
external third party.
Table 57 Total number of incidents of discrimination, including harassment reported in the reporting period
Reporting Year
2024
2025
Total number of incidents of discrimination, including harassment reported in the reporting period (#)
1
0
Number of complaints filed through channels for Employees to raise concerns (including grievance mechanisms) (#)
2
0
Number of complaints filed to National Contact Points for OECD Multinational Enterprises (#)
0
0
Number of severe human rights issues and incidents(#)
0
0
Total amount of fines, penalties, and compensation for damages as a result of the incidents and complaints disclosed
above
0
0
ESRS S4 - CONSUMERS AND END-USERS
[S4.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model in relation to
consumers
Customers constitute a key stakeholder group for Alpha Bank given their central role in the Group’s business model and value creation.
Detailed information is disclosed under [SBM-2] “Interests and views of stakeholders” in chapter ESRS 2. The scope of the disclosure under
ESRS 2 includes all relevant products and services, as well as all consumers and end
‑
users who may be materially impacted through the
Group’s operations, value chain, or business relationships.
The Group does not engage in the sale of products and services that are inherently harmful to individuals. Due to the nature of its operations,
the Group handles sensitive personal information, therefore there is an inherent risk of data breaches or misuse of personal information.
Furthermore, consumers depend on precise information concerning financial products and services, including loan terms, interest rates, and
fees. The Group offers its services and products to all consumers and end-users, without any form of discrimination and with respect to their
41
The percentage is calculated as the number of Εmployees that participated in regular performance and career development reviews divided by the total
headcount of Εmployees.
42
Average number of training hours per Εmployee by gender has been calculated as the number of training hours per Employee and by gender throughout the
year, divided by the total headcount of Εmployees by gender as of 31.12.2025.
43
Health and Safety metrics were not reported in 2024 and thus there is no available data.
44
Number includes 2 work related injuries, 9 pathological incidents and 6 commuting to and from work incidents.
Gender
Females
Males
Reporting Year
2024
2025
2024
2025
Percentage of employees that participated in regular
performance and career development reviews
41
(%)
91%
91%
90%
89%
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132 | ANNUAL FINANCIAL REPORT
freedom of expression. Therefore, all product-related information is transparent and readily accessible to prevent potential misuse or
misunderstanding of its products and services.
The types of consumers who are likely to be materially impacted by the Group’s products/services and business relationships a re:
• Ι ndividuals (i.e. private Customers),
• Corporate and
• SME Customers.
Individuals are people who use the Group’s products/services for personal needs, such as savings accounts, mortgages, and cre dit cards.
Corporate Customers are large businesses that have more complex needs, such as loans for operations, expansion, cash flow management,
and investments. SME Customers are small and medium-sized enterprises that require banking services to support their operations and
growth, including business loans.
Customers may include certain groups that could be particularly susceptible to negative impacts resulting from marketing and sales strategies
or privacy-related incidents, such as young and senior individuals and other financially vulnerable individuals (e.g., low-income borrowers). The
Group proactively takes steps to avoid material negative impacts on its Customers through initiatives, processes and targeted products and
services that are currently in place e.g. education loans, targeted credit products to other vulnerable groups, and others. For details on how
impacts, risks, and opportunities for consumers relate to the Group's strategy and business model, please refer to [SBM-3] Material impacts,
risks and opportunities and their interaction with strategy and business model.
Activities resulting in positive impacts on Customers
Alpha Bank is dedicated to ensuring equal access and seamless physical and digital access to its products and services, thereby enhancing the
inclusion and financial wellbeing of its Customers. The Group’s activities provide comprehensive and inclusive acc ess to financial services
through a range of high-quality financial products and services. These span across corporate and retail banking, financial services, investment
banking and brokerage services, insurance services, real estate management, hotel services in Greece, Cyprus, United Kingdom, Luxembourg,
Romania, Bulgaria, Serbia, Ireland. Continuous improvements are made to enhance the Group’s services and products, ensuring e ase of access
for Customers. More information about the business sectors, products and services of the Group is included in the Board of Directors’
Management Report within the Annual Report.
The positive impacts on Customers derive from the Group’s portfolio of products and services, which facilitate improved access to key sectors,
including Finance and Housing. Moreover, a broader socio-economic positive impact is created on Customers and broader society through the
Group’s products, services and business relationships, contributing to Healthy Economies.
In Greece, Alpha Bank S.A., which represents the largest share of the Group’s operations, offers a diverse range of products and services for
individual, corporate and SME Customers. These include:
Products and Services Supporting Retail Customers’ Access to Housing and Finance
Affordable Housing solutions
• Alpha Residence: a housing loan allowing Customers to purchase a home with the option to secure the loan against any property,
with a built-in flexibility in adjusting payment terms based on changes in income.
• Alpha First Home: a housing loan targeting first-time buyers between ages 18 to 50, providing financing for up to 90% of the
property’s value.
• Alpha Residence Renovation: a renovation loan available for home improvement projects, which can be secured with or without a
property mortgage.
• Exoikonomo 2023: a program funded by the Recovery and Resilience Fund to enhance the energy efficiency of homes by at least
three energy categories, achieving over 30% primary energy savings. Additionally, the investment includes specific incentives to
support low-income and vulnerable households, offering an increased grant rate and a dedicated budget of Euro 178 million.
• Exoikonomo – Anakainizo gia Neous (“Exoikonomo” Component): a program supported by the Recovery and Resilience Fund aimed
at promoting national and EU energy policies for energy conservation specifically designed to cater for young people needs.
Particular attention is given to supporting low-income and vulnerable households, with an increased grant rate and a dedicated
budget of €40 million.
• Reward Program for Consistent Mortgage Borrowers: introduced in response to the financial strain on households caused by
consecutive interest rate hikes due to Central Bank’s monetary policies. This program, available for 12 months, aims to suppo rt
borrowers who consistently meet their repayment obligations by reducing interest rates on variable rate mortgages and to protect
borrowers from potential future increases in benchmark rates.
In 2025, Alpha Bank launched four additional programs to address the housing affordability challenges and provide further access to Housing
and Finance for Customers in Greece:
• Exoikonomo 2025: a program supported by the Recovery and Resilience Fund aimed at advancing national and EU energy policies for
energy conservation. The program focuses on improving the energy efficiency of households, achieving over 30% primary energy
savings for each home, through an upgrade of at least three energy categories. The investment includes specific incentives to
support families with disabled members, those affected by the Thessaly floods (including the earthquake victims in the municipality
of Damasi, Municipality of Tyrnavos), earthquake victims in Arkalochori and Samos, families with three dependent children, and
vulnerable households, both through increased grant rates and a dedicated budget.
• “Exoikonomo – Anakainizo gia Neous” Program (“Anakainizo” Component): a grant program that is a complementary extension of
the “Exoikonomo gia Neous” Component expanding its scope beyond energy efficiency upgrades to include additional renovation
works that improve the functionality and aesthetics of homes undergoing energy refurbishment. It primarily targets young people up
to 39 years old.
• My Home II which is a co-financed housing loan designed for first-time homebuyers aged 25 to 50. This program aims to support
low-income individuals and those without the financial means to purchase their own primary residence through low-interest
mortgage offerings.
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• Upgrade My Home which is a co-financed loan program aiming to provide incentives to individuals for energy improvements to their
existing residences.
Accessibility to Finance
• Alpha Cash Collateral: an option to allow Customers to secure a loan without liquidating assets, providing financial flexibility while
maintaining investment portfolios.
• myAlpha Quick Loan: e-banking personal loans of up to Euro 3,000 to cover unexpected costs and routine spending with a fast and
paperless process.
• Alpha “Metron Ariston”: secured and unsecured personal loans with competitive interest rates and flexible repayment schedules.
• Alpha Green Solutions – Electric Car/Bicycle and Consumer Loan for the home: consumer loans especially designed to finance the
purchase of electric vehicles or the improvement of the energy efficiency of homes, with favorable fixed interest rates.
• Alpha Education Consumer Loan: loans for educational purposes with favorable fixed interest rates.
• Alpha All in 1: offering consolidation of outstanding credit card and consumer loan balances into a single, simplified loan program
with lower monthly payments.
• Alpha Epipleon – Overdraft Program: providing access to additional funds conveniently and affordably through Customers’ payroll
accounts, as needed.
• Car Financing and Consumer Goods Loans: through a wide network of car dealers and retailers, Alpha offers consumer loans for the
purchase of cars, motorcycles and consumer goods, with competitive fixed interest rates.
• myAlpha Benefit: 3 packages aiming to cut down monthly transaction expenses for Customers. MyAlpha Benefit base, myAlpha
Benefit Advanced and myAlpha Benefit Premium.
• Alpha Residence: housing loan offered to permanent residents in Cyprus for the purchase, construction, completion or renovation of
a property. For financed properties with an Energy Performance Certificate (EPC) of category A, or if renovated properties that
achieve EPC category B+ or higher following renovation, the borrower receives a discounted interest rate.
• Alpha Car: a car loan offered to individuals for the financing of a new or used car. For new eco-friendly vehicles, i.e. hybrid vehicles,
twin-propulsion vehicles and vehicles with carbon dioxide emissions of less than or equal to (≤) 75g CO2/km, a discount on the
interest rate is offered.
• Bonus Charity program: For the 17th consecutive year, the “Bonus Charity” program enabled customers to support a non-profit
organization of their choice by redeeming Bonus points. The Bank supplemented the value of the redeemed points, donating more
than double their worth to the participating institutions, supporting people in need and certified environmental organizations. In
2025, a total of 975 charity transactions were completed, resulting in donations of Euro 29,880. The 39 organizations currently
participating in the Program are listed on the Bank’s website.
Products and services that support Corporate and SME Customers’ access to Finance, and contribute to the development of Healthy
Economies
The Group’s products and services addressed to corporate and SME Customers include lending, leasing, real estate and factoring activities
aiming at enhancing their access to finance, house their operations and grow. The Group also supports through its products and services
sectors that are inherently positively associated with access to Housing and Finance and insurance activities, reinsurance and pension funding,
except compulsory social security. Through Alpha Bank S.A. other initiatives targeting corporate and SME Customers include:
• Financing solutions for Businesses (e.g., InvestEU co-funding program) and Large Corporate Customers including Letters of
Guarantee, Letters of Credit, and lending to the Division’ Customers by the Group Companies in Greece and abroad (excluding
Customer lending through the Subsidiaries Alpha Leasing S.A. and ABC Factors S.A.).
• Alpha Bank Gold Business: a service dedicated to delivering top-tier consulting services to its Gold Business Customers. This
commitment extends beyond identifying optimal financial solutions to include the development and implementation of new
business development standards.
• High-value investment projects in the Greek Hospitality Sector through bonds and loans.
• myAlpha Business Benefit Advanced: Introduction of a new transaction package tailored for professionals operating in the Airbnb
market.
• myAlpha Web for Business: In 2025, several enhancements were introduced to strengthen functionality and improve the overall
digital banking experience for corporate clients. These include the deployment of dedicated login page segmentation for individuals
and businesses, the integration of Ultimate Beneficiary details within IRIS e-commerce payments, and the extension of corporate
card transaction history to 18 months. Additional upgrades include the adjustment of daily purchase limits for corporate prepaid
cards, the public rollout of the eLG (electronic Letter of Guarantee) service, and the introduction of Verification of Payee (VoP) to
improve payment accuracy. Furthermore, the FX conversion transaction limit via Web FX was increased from USD 300,000 to USD
500,000, offering greater flexibility for high-value transactions. myAlpha Web for Business users can also issue certificates to certified
auditors, supporting streamlined financial verification processes.
• Support Female entrepreneurship: In 2025, the percentage of female Owners of Individual Businesses which were included in the
Segment of Small Businesses (Alpha Bank S.A. portfolio) out of total owners of individual businesses was 33.8%.
Alpha Bank supporting SMEs
• EIF Sustainability Portfolio Guarantee Product: A guarantee instrument that supports investments contributing to the green
transition of SMEs and Small Mid-Caps, while also providing financing for the working capital needs of “green” enterprises, with an
80% guarantee per financing facility.
• EIF Innovation & Digitalization Portfolio Guarantee Product: A guarantee instrument that supports investments in innovation and
digital transformation, enhancing access to finance for SMEs, Small Mid-Caps, and R&D-intensive beneficiaries. It also provides
financing for the working capital needs for the “Digitalization” of businesses, offering an 80% guarantee per financing facility.
• HDB Just Transition Co-Financing Loans Fund: A co-financing instrument offering working capital and investment loans, with 50% of
the principal provided interest-free by HDB. The program also provides an additional 3% interest rate subsidy for the first three (3)
years of the loan. The Just Transition Development (JTD) Fund is a strategic initiative of the Greek government designed to address
the economic and social impacts of de-lignitization in regions dependent on lignite activities. A key pillar of the Fund is the financial
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
134 | ANNUAL FINANCIAL REPORT
support of SME activities operating in the Just Transition Development Regions (Western Macedonia and specific areas of the
Peloponnese), as these businesses are essential drivers of economic growth and job creation. The regions supported by the JTD
Fund, designated as Just Transition Areas, include:
o Region of Western Macedonia (Regional Units of Kozani, Kastoria, Florina, Grevena)
o Municipalities of Tripoli, Megalopolis, Gortynia, and Oichalia in the Region of Peloponnese
o Islands with a population of up to 3,100 inhabitants in the Regions of North Aegean, South Aegean, or Crete
• HDB Just Transition Guarantee Fund: A guarantee instrument offering investment loans, with 80% guarantee per financing. The
program also provides an additional 3% interest rate subsidy for the first two (2) years of the loan.
• HDB Natural Disasters Recovery Microloans Fund: A co-financing instrument offering working capital loans, with 75% of the
principal provided interest-free by HDB. The program also provides grant for covering costs for mentoring services up to €900 per
beneficiary. The Natural Disasters Recovery Microloan Fund constitutes a strategic initiative of the Hellenic Government, aiming to
address the economic and social consequences in regions affected by natural disasters. It should be emphasized that all Micro and
Small Enterprises operating in the affected areas are eligible for financing, irrespective of whether they have suffered direct material
damages from extreme natural phenomena. This provision is based on the premise that, as a broader consequence of natural
disasters, the normal course of business activity in the region has been disrupted. The Fund will provide support to enterpri ses
operating in the Region of Thessaly (Regional Units of Larissa, Magnesia, Trikala, and Karditsa).
• HDB Green Co-Financing Loans – Business Growth Fund: A co-financing instrument that provided investment loans supporting the
green transition of SMEs, with 40% of the principal offered interest-free by HDB. The program also included an additional 3% interest
rate subsidy for the first two (2) years of the loan. The Program’s availability period ran until 30.06.2025.
• HDB Innovation Guarantee Fund: offers financing under favorable conditions, supported by an 80% guarantee. Additionally, there is
an option to subsidize up to 20% of the capital if the debtor meets specific innovation and ESG (Environmental, Social, and
Governance) criteria within three years of the initial loan disbursement. The Program’s availability period run until 31.12.2025.
• Recovery and Resilience Fund, Greece 2.0: providing comprehensive Banking Advisory services for the co-financing of SMEs, aimed
at implementing investment plans that include sustainability-promoting interventions.
• Training and support workshops program: This is a strategic initiative offers targeted training and technical support, featuring a
series of workshops delivered across Greece, with a particular focus on SME Customers. The program is designed to support
businesses with the implementation of their investment projects and transformation plans, leveraging Alpha Bank’s development
programs and financing solutions. In addition to the Customer workshops, which focus on business development and provide
practical guidance and thorough analysis of real case studies, the training program includes specialized workshops addressed to the
Bank’s network. These internal sessions aim to strengthen collective knowledge regarding financing solutions for SMEs, facili tate the
sharing of best practices and technical expertise, strengthen skills and gain an in-depth understanding of the financing solutions that
Alpha Bank offers to businesses.
• Ecosystem of Partnerships: a comprehensive suite of services is offered across all green entrepreneurship sectors, encompassing
sustainable investments, including specialist advisors, suppliers, and photovoltaic station construction contractors.
• Equal support for businesses: collaboration with the Hellenic Development Bank (HDB) and the European Investment Fund (EIF) to
offer favorable financing options for start-ups. In addition, Alpha Bank supports female entrepreneurship through its partnership
with the EIF, which has facilitated microcredit for micro-enterprises, including numerous women-owned sole proprietorships,
through the "Employment and Social Innovation (EaSI) Microfinance Guarantee Facility".
• Alpha Smart Hospitality: a service promoting sustainable development by providing financial resources to support the targeted
growth of Greek entrepreneurship. This approach involves methodical, substantial, and integrated planning within a sustainability
framework, considering available resources, goals, and emerging trends.
• Alpha Photovoltaic: a green financing solution for small businesses and farmers investing in photovoltaic systems up to 1MW in
Greece. This supports Greece’s growing renewable energy market, with lower technology costs and simplified licensing. Aligned with
Alpha Bank's sustainability commitments, the loan promotes sustainable development by offering competitive pricing and fostering
green entrepreneurship. This product helps investors capitalize on the growth of solar energy, reduce carbon emissions, and
contribute to Greece's energy transition.
• Alpha Sustainable Photovoltaic: a financing solution to support the construction of 400 kW photovoltaic power stations in Crete
and Peloponnese, exclusively for investors recommended by Alpha Bank’s Central Partners. The product provides tailored financ ing
packages under the State Aid Free Invest EU Sustainability Guarantee Facility, backed by an 80% guarantee, resulting in competitive
pricing. It includes Bridge Financing for Wholesale Banking and features specialized collateral requirements to offer favorable terms.
This solution aims to drive the growth of renewable energy projects while meeting sustainability objectives.
• Alpha Pre-Schooling Social Loan: a tailored working capital financing product designed to address short-term liquidity challenges
faced by private childcare providers (nurseries and kindergartens) in Greece. The product helps bridge cash flow gaps caused by
delayed government voucher payments at the start of the school year. Vouchers, issued by the Greek government under approved
social programs, are assigned by parents to childcare centers and can then be further pledged to the Bank as collateral to unlock
much-needed liquidity.
• Moreover, Alpha Bank Cyprus offers a similar suite of Sustainable business loans for green and social purposes, that meet the
Sustainable Finance Framework criteria. Green purposes include energy efficiency, green buildings, renewable energy, and
sustainable transport. Social purposes include access to essential services such as health and education.
Solutions addressed to Private Banking Customers
Alpha Bank ensures full transparency of sustainability-related information for all investment products (when available) distributed through its
channels. The Bank provides the standardized ESG disclosures and integrate sustainability considerations into product selection, advisory
processes, and Customer engagement. Activities include prioritizing SFDR and EU Taxonomy-aligned products, training advisors on ESG
integration, and providing necessary educational activities to enhance Customer understanding of sustainability impacts.
Private banking Customers have also access to another product with positive environmental impact through the Bank’s collabora tion with
'Reforest'Action', for which more details can be found on [E4-3] Actions and resources related to biodiversity and ecosystems. By embedding
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
135 | ANNUAL FINANCIAL REPORT
sustainability into its distribution strategy, the Bank mitigates regulatory and reputational risks while leveraging opportunities to strengthen
trust, differentiate competitively, and contribute to the EU’s climate-neutral objectives.
Progress is measured through key performance indicators such as the percentage of products with ESG disclosures, SFDR and taxonomy
alignment rates. 68% of the Mutual Funds (MFs) offered through Alpha Bank’s distribution channels in Greece promote environme ntal or
social characteristics (SFDR Article 8) and 5% of the MFs have a sustainable investment objective (SFDR Article 9). Among these Article 8 and
Article 9 products, 53% proceed to sustainable investments. Additionally, the majority (~68%) of all MFs consider ESG Principal Adverse
Impacts (PAIs), while around 2% of the MFs are aligned with the EU Taxonomy. Over 50% of products within the Discretionary Portfolio
Management service either have sustainable characteristics (SFDR Art 8), sustainable objectives (SFDR Art 9) or promoting responsible
investment strategies that are more resilient to long-term risks, thereby reinforcing client trust in Alpha Bank.
Products managed by Alpha Asset Management M.F.M.C.
In 2025, Alpha Asset Management M.F.M.C. reclassified four additional Mutual Funds from Article 6 to Article 8 under the Sustainable Finance
Disclosure Regulation (SFDR). As a result, assets promoting environmental and social characteristics increased significantly, from Euro 313
million at the end of 2024 to Euro 1.5 billion at the end of 2025, underscoring the Company’s strong commitment to ESG integr ation.
Digital solutions to enhance the accessibility of products and services to Customers
Innovation and digitalization demand a modernized branch network for the banking services, robust digital platforms and web services, and
the provision of widespread, inclusive access to financial services. Key imperatives of Alpha Bank’s digital strategy are the continuous
improvement in product and service quality, a modern and responsible approach to the Customers’ banking needs as well as the Bank’s
uninterrupted operation. Through digital initiatives such as e-banking and digital card wallets, the Group makes it easier and more secure for
all Customers to access its services and products. Among others, the solutions offered are:
• Digital Cards & Wallets: The cards enrolled in wallets (Apple Pay, Google Pay, Garmin Pay, Xiaomi Pay) and e-commerce platforms,
which Alpha Bank was the first to offer to its Customers, maintained in 2025 the positive trend with the number of active digitized
cards (tokens) exceeding 9.6 million. The digital card offering makes it easier and more secure for Customers to use their cards to
make payments.
• Account Opening & Onboarding (Individuals & Professionals):
o The ability to open a current account and obtain business e-Banking credentials through myAlpha Web for individuals is
available to the public. Individual Customers who have e-banking passwords were given the opportunity to start their
professional cooperation with the Bank, as Sole Proprietorships (including freelancers), through myAlpha Web Individuals.
o Retail Onboarding via myAlpha Mobile: The redesign of the process for starting a banking relationship through myAlpha
Mobile was made available to Individuals who wish to open their first account with the Bank. The process is carried out
entirely through a mobile phone, without document submission, using eGov-KYC verification and video-call identification
with a Bank representative. In just a few minutes, the Customer obtains an account, a debit card, and e-Banking access,
fully covering their banking needs.
o Ability to open a privileged account: private Customers who have e-Banking and wish to open a privileged account to be
served with their daily transactions can obtain it either through myAlpha Web or through myAlpha Mobile without visiting
a branch.
• Digital Payments & IRIS (QR generator): offering for freelancers and sole proprietorships, and optional 'mobile search' during the
Activation/Modification of the IRIS Payments service.
• Digital Lending & Certifications:
o Online mortgage pre-approval: The option to obtain a financial pre-approval for a mortgage loan online was launched
through myAlpha Web for Individuals, without submitting physical documents or visiting a branch.
o Online issuance of certificates: While the service that facilitates online requests for the issuance of specific Certificates for
bills and loans is offered since 2023, during the reporting year the offering includes the issuance of 2 additional certificates:
letters of guarantee and certificate for certified auditors.
• Smart Service & Self-Service:
o MAD Hybrid Self-initiation: This new feature enabled Customers to initiate requests through their e-Banking subscription
by completing a form and signing digitally, saving time and simplifying the process.
o In June of 2025, a new user role was introduced in myAlpha Web for Business, titled “myAlpha Documents Signatory”. This
role enables authorized individuals, whether internal or external to the company, to gain targeted access to the
“Documents” section for the purpose of digitally signing documents exchanged between the Bank and the business. This
new capability enhances corporate process workflows while strengthening transparency and security in the Bank–business
relationship.
• Appointments & Remote Service:
o myAlpha Rendez-vous: the service enables Customers to book appointments and receive assistance via video call, phone
call, or in person at a branch. The Remote Customer Collaboration System (RCCS) includes the “myAlpha Rendez-vous”
(available since 2022) and the appointment booking widget within the e-Banking environment (myAlpha WEB Personal and
Business and myAlpha Mobile Personal) (available since 2025). Since launch, these channels have generated more than
1,190,000 appointments (individuals and legal entities), with over 80% completed and only 20% cancelled either by the
customer or the Bank. Additionally, approximately 150,000 appointments have been registered through the Outbound
Application tool, used by the Bank’s Customer Service Department and Branches to assist customers who cannot book
independently or do not have an email address.
• Digital Support & Inclusion:
o e-Banking for Individuals Chatbot: The digital assistant, available through myAlpha Web and myAlpha Mobile, supports
Customers 24/7 with immediate guidance. By making information accessible at any time, it promotes digital inclusion and
empowers users of all ages and abilities to navigate banking services with confidence.
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o e-Banking Walkthrough: Customer training and continuous support contribute to a complete digital banking experience
and fostering valuable relationships. In this context, the e-Banking Walkthrough initiative continued in 2025, during which
specialized staff train Customers daily via personalized video-call sessions on how to use e-Banking and stay safe during
digital transactions, improving both accessibility and overall experience with our digital services.
• Paperless Banking & Automation: The provision of e-Statements: automated information on card transactions, accounts, loans, and
POS so that Customers who have e-Banking receive the relevant information online
• Security & Authentication (Business):
o Since March 2025, the “myAlpha Code service” is offered free of charge to myAlpha Web for Business users, following the
elimination of the annual fee of Euro 12 per user. Activation of the service is now mandatory for all new Business e-Banking
users. For existing users without an active subscription, activation is carried out through their servicing branch.
o At the same time, the use of the “myAlpha Code” hardware token has been discontinued. Six-digit authentication codes
are now delivered exclusively via Viber, with SMS provided as an alternative channel. The seamless integration of the
service into myAlpha Web for Business, at no additional cost, ensures enhanced security and streamlined access for
corporate clients to all transactions requiring strong Customer authentication.
Inclusive access to products and services
The Group enhances access to its financial services for all consumers, including persons with disabilities and vulnerable groups, through the
ongoing modernization of its physical facilities and digital channels. In more detail these include:
• Deaf & Hard-of-Hearing Customers- Access to Remote Banking Hub & Physical Branches:
o Customers can indicate the option “I have a hearing impairment” when scheduling an appointment via alpha.gr or through
Alpha Bank’s secure e-Banking platform. They are then served remotely via video call by trained Remote Hub agents, using
communication methods tailored to their needs, either through written chat or with the participation of a certified Greek
Sign Language interpreter employed by the Bank.
o In addition, the digital platform ‘’myAlpha Documents’’ enables the secure electronic exchange and signing of documents,
allowing customers to complete requests efficiently without requiring a physical branch visit.
o Where necessary, Remote Hub agents coordinate follow-up appointments at a physical branch, ensuring smooth service
continuity across channels.
o Alongside its remote service model through the Retail Remote Banking Hub, Alpha Bank provides accessible in-branch
banking solutions for Deaf and Hard of Hearing customers across its physical network.
o Customers may visit a branch accompanied by a sign language interpreter of their choice. Alternatively, they may use the
myIRIS mobile application, which offers free, on-demand remote sign language interpretation services provided by the
National Foundation for the Deaf, enabling effective communication with branch staff. When required, written
communication is also used to support service delivery.
• Customers with Visual Disabilities:
o Deployment of more than 300 audio-guided ATMs with tactile keypads and audio cues that provide full audio navigation
via headphones for safe, independent transactions, where Customer information is not displayed on the screen during
transactions for security.
o Screen-reader compatibility implemented for mobile notifications.
o WCAG -aligned colour contrast and typography across alpha.gr, MyAlpha Web, MyAlpha Mobile.
o Digital wallet support (Apple/Google Wallet) enabling secure, screen-reader–assisted transactions, with upcoming support
for ATM withdrawals via mobile devices
o Accessible video media with subtitles available on Alpha.gr.
o All Bank documents available in Braille, with a processing time of 7 calendar days.
o Assistance provided without the need for witnesses.
• Customers with Increased Mobility & Accessibility needs and senior citizens:
o Fully remote digital onboarding process.
o One-to-one educational video sessions provided by the dedicated “e-Banking walkthrough” team.
o Modernized facilities of Branches that are accessible to all.
o Accessible and ergonomic ATM height/placement standards applied across the network.
o Remote digital service channels (chat, Remote Customer Collaboration System , web) reducing need for physical travel.
o Digital signing and acceptance of documents (MAD) for frictionless operations.
• Customers with Cognitive or Learning Difficulties:
o Simplified content across MyAlpha Web and Mobile supports easier comprehension and reduces cognitive load.
o Guided chatbot interactions designed with plain language and step-by-step assistance to support task completion.
The websites are available in both English and Greek, and this bilingual approach extends to the Customer Service Call Centre. Customers
visiting the Branches can also receive assistance in English, and an English-language interface option is available at the Bank’s ATMs. The
Branch Network and ATMs form the cornerstone of traditional banking services, and as such, they have been given heightened attention to
ensure that all Customers can access financial services equitably in all countries and regions that the Group operates.
Looking ahead, Alpha Bank has initiated a coordinated accessibility program to ensure that its retail-facing digital channels, including the
mobile application and web banking, achieve accessibility compliance, aligned with WCAG 2.2 AA and the EU Accessibility Act.
During the first half of 2026, the new retail mobile application and the core retail web banking flows are targeted to achieve accessibility
compliance, with full retail web accessibility targeted by the second half of the year. Accessibility requirements will be embedded as a
standard practice to ensure that all newly launched retail digital services remain compliant by design. The programme includes the delivery of
accessible digital documents (PDFs and statements) and enhancements to video call interactions with Customers, including support for live
transcription and sign language interpreter participation upon request, particularly within digital onboarding and identification flows within
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2026Looking forward, Alpha Bank is launching a coordinated programme to achieve full accessibility compliance across all digital channels,
aligned with WCAG 2.2 AA and the EU Accessibility Act. Key priorities include enabling full screen-reader navigation across MyAlpha Web and
Mobile for both retail and business Customers, delivering accessible PDF documents, enhancing accessible product information, and
redesigning onboarding flows to support interpreter participation in eKYC video identification where needed. These improvements ensure that
all new digital projects—onboarding, product acquisition, everyday transactions, and service interactions—are designed from the outset to be
fully accessible and inclusive for every Customer.
Through the offering of these products/services, the Group and its subsidiaries deliver material positive impacts on its Customers. It is noted
that no negative material impacts that escalate into widespread or systemic harm against consumers/end
‑
users widespread or systemic
impact to consumers and end-users have been identified in the Double Materiality Assessment for the Group’s business activities and
relationships. The Group’s Sustainable Finance Framework targets specific groups of Customers s uch as socioeconomically disadvantaged
population living in rural areas or isolated islands with limited or inadequate basic infrastructure, undereducated, long-term unemployed and
working population vulnerable to losing their job due to the energy transition. Additionally, it focuses on elderly, youth, and other vulnerable
groups, including persons with disabilities, or those in need of medical attention. Please refer to the Policies section in [E1-2] and the Alpha
Bank website for additional information related to the Sustainable Finance Framework.
Material risks and opportunities related to Customers
Material risks and opportunities for the Group generally derive from impacts, dependencies, or other factors, such as exposure to climate
hazards or changes in regulation that address systemic risks. Dependencies arise from a reliance on consumers, such as that relating to
reputational damage. Other factors refer to systemic factors; for instance, regulatory changes in the financial services sector.
From a risk perspective, in the context of the Double Materiality Assessment performed in 2025, the Group concluded that regarding
consumers and end-users, “Privacy”, “Access to (quality) information” and “Responsible marketing practices” risks are conside red material in
the short-, medium- and long-term (from an inherent risk perspective). These risks relate to disclosure and data protection issues, unsuitable
promotion practices, fiduciary breaches, disputes over advisory activity, product suitability issues or inadequate disclosure of product terms
and they typically stem from the potential failure of internal processes and control mechanisms established to ensure data protection,
responsible marketing, and access to quality information.
While such risks may also indirectly affect the Group’s clients, their root causes and potential impacts are primarily linked to the Group’s
operational practices and governance framework. They are mainly connected with external factors, including evolving regulatory requirements
(e.g., related to GDPR), industry standards, and societal expectations, which can undermine trust and reputation and potentially result in
significant financial losses.
It is noted that, risks related to privacy, access to high-quality information, and responsible marketing practices are not specific to any
particular group of customers. Based on the Double Materiality Assessment process no material opportunities have been identified related to
the consumers and end-users.
[S4-1] Policies related to Customers
Material impacts on Wholesale and Retail Customers relate to Access to Finance and Housing, Healthy Economies, and risks relate to Privacy
and Access to (Quality) Information, Responsible Marketing Practices. Therefore, impacts and risks are being managed by the Group with a
comprehensive set of policies, including:
Alpha Bank Group’s Non-Financial Risks Management Policy
The Policy defines the main components of Non-Financial Risks Management framework. Indicative examples of risks covered in the policy are
among others: legal risk, operational risk, ESG risk and reputational risk. The policy also outlines the principles, definitions, governance
structure and risk management practices adopted by the Group for effectively managing its Non-Financial Risk exposures.
The policy is applied at Group level in order to manage and mitigate non-financial risks effectively at a consolidated basis. Certain policy
adjustments may be required at Group level, in accordance with local regulatory requirements, to ensure compliance. Accountability for the
implementation and oversight of the Non-Financial Risk Policy is assigned to Alpha Bank’s governance bodies. The Policy is communicated
internally and made accessible to all Employees through the Group’s intranet, thereby ensuring transparency.
Sustainable Finance Framework (SFF)
The SFF lays out the criteria to characterize specific loans as sustainable, including themes that contribute to the access to Finance and Healthy
Economies, Housing (i.e. access to credit and financing and affordable social housing). The process for monitoring the implementation of the
SFF includes a robust governance model as well as its integration into the Bank’s existing credit approval process. The SFF r elates to banking
and lending activities provided to individual, corporate and SME Customers. The scope of the SFF encompasses a variety of ESG lending
solutions in the Bank’s Wholesale and Retail banking portfolios. Additional credit products may be considered following an as sessment of
certain eligibility criteria. The related activities under the SFF focus on dedicated-purpose financing (Green/Social loans and RRF loans), general
purpose financing (Business Mix and Sustainability-linked loans). Access to credit and financing and contribution to Healthy Economies targets
females, rural populations focusing on agricultural production and agricultural value chains, excluded and/ or marginalized populations, and
economically disadvantaged groups through SME lending in emerging markets and Microfinance lending. Affordable social housing focuses on
the financing of construction, renovation and maintenance of houses destroyed or damaged by natural disasters, as well as the provision of
adequate, safe, and affordable housing for women, low
‑
income, and underserved populations. For further details on the key objectives of the
SFF, the integration of stakeholders’ views in establishing the SFF, and the online availability of SFF to affected Customers and Employees,
please refer to [IRO-1] Description of the process to identify and assess material impacts, risks and opportunities and [E1-2] Policies related to
climate change mitigation and adaptation.
Group Cybersecurity and Information Security Framework
The Group Cybersecurity and Information Security Framework sets out the Cybersecurity and Information Security principles, policies,
procedures, methodologies, technical security standards and guidelines for the management of Cybersecurity and Information Security risks,
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ensuring compliance with legal and regulatory framework and leading industry standards and best practices, while supporting the intent and
the direction of the Cybersecurity and Information Security Strategy.
It addresses the identified risk of “Disclosure and data protection issues” under the Double Materiality Assessment. The Fram ework relates to
all the Group’s activities, products and services and applies to all countries where the Group operates and to all Business Areas of the Bank and
Group subsidiaries. In addition, the Bank and Group subsidiaries also ensure that third-party service providers comply with the Group
Cybersecurity and Information Security Framework, where applicable, as well as other applicable ICT security standards.
The Framework is reviewed at least annually to meet the increased requirements arising from the relative regulatory framework (such as NIS
Directive, EU Cybersecurity Act, GDPR, EBA Guidelines on Cloud Services, EBA ICT Risk Guidelines, DORA, etc.), the operational and
technological environment as well as the applicable international standards and best practices. The Cybersecurity and Information Security
Business Area operates under Management Systems certified according to ISO standards, including ISO 22301 (Business Continuity), ISO 27001
(Information Security), ISO 27017 (Information Security Controls for Cloud Services) and ISO 27018 (Protection of Personally Identifiable
Information on Public Clouds), ISO 27701 (Privacy Information Management). The Business Area also leads the SWIFT CSP assessment and PCI
DSS recertification processes for the Bank.
The Group Cybersecurity and Information Security Framework is available to all Employees through the Group’s Intranet.
Electronic Fraud Management Policy
Systematic and effective actions to minimize electronic fraud incidents involving e-Banking and Card digital services are a standard practice to
ensure operational continuity, corporate reputation, and reduce financial and/or legal risks.
The Electronic Fraud Management Policy of Alpha Bank S.A
45
defines the structure and the operating principles for the prevention, timely
detection, and effective management of fraud incidents via e-Banking and Card Services with the aim of reducing them and continuously
improving the infrastructure, organization, and procedures for the effective combating of electronic fraud.
As a Financial Institution the Policy aligns with the requirements of the European regulatory framework, such as PSD2 and the EBA guidelines,
as well as with international payment security standards. Its purpose is to clearly define the principles, responsibilities, and methods for
preventing, detecting, and responding to suspicious activities. Potentially effected stakeholders can be informed through material that exists
on the Alpha Bank S.A. website (for
individuals
and
business
). More details are included in the Electronic Fraud Management Initiatives
section.
The creation and configuration of the rules for the Anti-Fraud systems are guided by its Business Strategy and the electronic fraud patterns
that are being identified through the daily analysis of fraud incidents. Additionally, the Fraud Alerts Management Team, which is a crucial part
of the Electronic Fraud Management Unit, is committed to operating on a 24-hour basis to ensure that the bank is always prepared to respond
promptly to any fraud incidents. In an environment where threats evolve daily, the policy serves as a stable point of reference, enabling the
Bank to stay one step ahead of emerging risks and to react quickly and effectively to any fraud incident.
Group Personal Data Protection Policy
The Group Personal Data Protection Policy aims to define the rules governing the organizational and technical measures for the effective
management and protection of personal data while ensuring the privacy of the data subjects (i.e. Natural Persons and Sole proprietorships).
Moreover, the policy seeks to enhance Customer confidence and preserve the Group’s reputation as well as its competitive pres ence in the
market. The scope of the policy applies to all Group subsidiaries and their respective Business Units, all Employees, and all third parties that in
any way process personal data on behalf of the Group subsidiaries, as data processors. The Group Personal Data Protection Policy is binding
for Group subsidiaries that operate in countries where GDPR is applicable and process personal data. The detailed policy is accessible to all
Employees on intranet, while the relevant Notice on the Processing of personal Data, is constantly available to the Customers on Alpha Bank's
website. The Policy has been developed to be in compliance with the General Data Protection Regulation (GDPR) and as such, has a strict set of
procedures inter alia it adheres to:
1. Privacy by Design and by Default
2. Record of Processing Activities
3. Data Protection Impact Assessment
4. Data Subjects Rights Management
5. Personal Data Breach Management
The “Privacy by Design and by Default” procedure ensures personal data protection throughout the entire lifecycle of a projec t, product, or
system, from initial development to operation and withdrawal. It applies to all projects involving organizational redesign or IT systems where
personal data is processed, either by the Bank or third parties. This procedure aligns with the Group Cybersecurity and Information Security
Framework and supports the procurement, development, and maintenance of information systems.
The "Record of Processing Activities" procedure documents all personal data processing activities within business areas in a central Record of
Processing Activities (RoPA). Its purpose is to ensure the RoPA is consistently updated with the information required under Article 30 of the
GDPR through regular or ad hoc reviews.
The Data Protection Impact Assessment is conducted when personal data processing may pose a high risk to the rights and freedoms of
individuals. Its purpose is to identify such high-risk activities and manage them by developing action plans with technical and organizational
measures to mitigate the risks. The “Data Subject Rights Management” procedure ensures that data subjects' requests are received, assessed,
and processed effectively within the required timeframe. It relies on the cooperation and coordination of all involved business units and third-
party data processors. The “Personal Data Breach Management” procedure ensures compliance with obligations to protect persona l data by
45
It is noted that Alpha Bank Cyprus is also aligned with the requirements of the European regulatory framework, such as PSD2 and the EBA guidelines
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identifying, managing, and responding to breaches promptly. It includes notifying the Supervisory Authority and affected individuals, when
necessary, in accordance with applicable legal requirements.
The Group Data Protection Policy is applicable since 2018, as well as other procedures that cover various obligations stemming from GDPR. To
monitor this policy, KPIs are determined and generated on a regular basis and are subject to periodical review to confirm the effectiveness of
the measures implemented and performance of the data protection program. No severe human rights issues and incidents connected to
consumers and/or end-users have been reported.
Group Outsourcing Policy
This Policy sets specific evaluation criteria for Outsourcing third party service providers, aiming to minimize potential risks for the Group and its
Customers. The Policy applies to all subsidiaries of the Group in Greece and abroad, and relates to outsourcing activities, on the basis of
Executive Committee Act No 178, as issued by the Bank of Greece (Session 178/2.10.2020), and the relevant guidelines of the European
Banking Authority (EBA Guidelines on outsourcing arrangements EBA/GL/2019/02). The policy covers Outsourcing service providers that may
be deployed regarding the offering of services to Customers and end-users, and does not apply to all third-party service providers, as per BoG
Act 178/5/2.10.2020. In addition, the Policy addresses the “Privacy” and “Access to Products and Services” in line with Double Materiality
Assessment performed by the Group.
Monitoring of the Outsourcing Policy is conducted on an ongoing and risk-based basis and includes, indicatively, the periodic review of key risk
indicators (KRIs), service performance indicators (KPIs), compliance assessments, incident reports, material changes, and findings arising from
internal audits or supervisory reviews. The ICT Third-Party Risk and Outsourcing Committee is responsible for supervising implementation of
the Outsourcing Strategy and receives regular reporting from the competent units and monitors adherence to regulatory requirements,
contractual obligations, service levels, and exit strategies, with particular focus on Critical or Important Outsourcing Arrangements. Any
material deviations, breaches, or emerging risks are promptly escalated to the BoD together with proposed remediation actions and timelines
for resolution. An annual comprehensive review of the Outsourcing Policy and its effectiveness is also performed, the results of which are
reported to the BoD.
All Business Areas and relevant subsidiaries as well as management bodies involved in the outsourcing lifecycle must comply with the
Outsourcing Policy (of which the Outsourcing Strategy is an integral part) and the relevant Procedures. The Policy is made available internally
on the Group’s intranet page.
Other information on policies related to Customers
Alpha Bank complies fully with all rules and guidelines established by the Communication Control Council, including the Greek Code of
Advertising and Communication,, however no specific policy is currently in place regarding responsible marketing practices and access to
quality information. Alpha Bank’s existing processes ensure that Customers are protected through responsible marketing practi ces and access
to high
‑
quality, transparent information. These established mechanisms adequately address the relevant material sustainability matter s
related to consumer needs, and therefore no additional policies have been deemed necessary at this time. Applicable regulations are reviewed
regularly to maintain alignment of the processes in place. Instructions from the Communications Committee and the Regulatory Compliance
Business Area are being followed on the promotional and advertising material of products and services in order to ensure compliance with a
variety of regulatory texts such as MiFID II, BoG Governor’s Act 2501/2002, PSDII, aiming at the full, transparent, timely an d non-misleading
information of existing and potential Customers. Explicit and sufficient information, regarding offered services and products is provided to all
Customers regardless of the distribution channels. These processes evidence that at Alpha Bank, transparency in promoting its services
throughout the business relationship with Customers is of the utmost importance.
In addition, aspects related to these matters, are integrated in the Code of Conduct and Ethics and the Corporate Responsibility Policy.
Particularly, for ensuring adequate controls against the generation of misleading financial information, as well as corruption, antitrust
violations, abusive contractual terms, insider dealing, conflicts of interest, money laundering, bribery and, towards its Customers, the Group
has set a Code of Conduct and Ethics. Regarding Customers, the Group ensures through the Code of Conduct and Ethics:
• The protection of Customer information confidentiality.
• The protection of personal data through secure and appropriate management thereof.
• The provision of explicit information regarding offered services and products, regardless of the distribution channels.
• The transparency in promoting its services throughout the relationship.
• The diligent resolution of complaints and measuring of Customer satisfaction.
• The protection of the Customers’ legitimate interests.
• The establishment of the appropriate organizational structure, policies and procedures for the avoidance of conflict-of-interest
situations.
Furthermore, through the Corporate Responsibility Policy, the Group prioritizes credibility, consistency, and efficiency in its banking services.
As in accordance with the Code of Conduct and Ethics and the principles of Corporate Governance, the Bank adheres to principles of best
banking and business practices. More specifically, the principles of integrity and honesty, impartiality and independence, confidentiality and
discretion with the aim to provide full, accurate, and truthful information to stakeholders.
More information on the Code of Conduct and Ethics is provided in [G1-1] Business conduct policies and corporate culture of the Sustainability
Statement, as well as on the Group’s website. The Corporate Responsibility Policy is described further on [S1-1] Policies related to own
workforce and the Corporate Governance Statement within the Annual Report 2025.
Through engaging with its key stakeholders, Alpha Bank S.A. has identified 3 areas that their Customers are prioritizing: 1) access to finance, 2)
data privacy, and 3) sustainable financing. Taking into consideration the interests of its Customers, the Bank has responded through setting the
SFF, as well as implementing transition plans for its Customers, developing ESG-related products and services, ecosystem of ESG partners, and
internal risks and controls.
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Significant changes in policies related to Customers in 2025
In 2025 the Complaints Management Policy was strengthened to enhance transparency, efficiency, and regulatory compliance in line with
Bank of Greece directives. The update reflects:
a) regulatory and supervisory requirements,
b) organizational and operational restructuring, and
c) the integration of corporate responsibility and ESG principles.
Key improvements include:
• A structured categorization process based on product, issue type, and applicable regulatory framework.
• A defined prioritization mechanism reflecting risk, complexity, and potential impact on the Bank.
• Clearly established response timelines, including internal targets for business areas (1–5 calendar days) and an overall resolution
timeframe of 10–15 calendar days, ensuring timely and consistent handling.
• A formal escalation framework for delayed or complex cases.
• Strengthened monitoring, reporting, and accountability mechanisms supporting transparency, continuous improvement, and
Customer trust.
The revised Policy ensures effective and lawful complaint handling, establishes a Central Complaints Management Team (CCMT) with clear
stakeholder roles, and promotes a unified, Customer-centric approach across all service channels. Monitoring, escalation mechanisms, a nd
root cause analysis support accountability and continuous service improvement.
Oversight of policies
Overall, the Board of Directors and its Committees are responsible for the approval of the policies and oversee their implementation. More
specifically:
• Alpha Bank Group’s Non-Financial Risks Management Policy: The Non-Financial Risks and Internal Control Committee is responsible
for reviewing the Policy at least on an annual basis, while any updates to the Policy are endorsed by the Risk Management
Committee prior to final approval by the Board of Directors, which retains ultimate accountability.
• Sustainable Finance Framework (SFF): The Group Sustainability Committee oversees the implementation of the SFF and reports to
the BoD.
• Group Cybersecurity and Information Security Framework: The Group Chief Information Security Officer is responsible for managing
the day-to-day operational execution of this policy and manages the multilayered security infrastructures and mechanisms for the
protection of the services provided. Finally, it is mentioned that the Group’s Cybersecurity and Information Security Strateg ic Plan is
monitored regularly and reported to the Non-Financial Risks and Internal Control Committee Executive Committee, and the BoD.
• Group Personal Data Protection Policy: The Group’s Data Protection Officer as well as the DPOs in the Group Companies are
responsible for the control and continuous monitoring of compliance and proper implementation of this policy.
• Group Outsourcing Policy: The ICT Third-Party Risk and Outsourcing Committee is responsible for supervising implementation of the
Outsourcing Strategy. It ensures that the BoD is duly and regularly informed on issues related to the overall implementation and
monitoring of the Outsourcing Strategy and Policy. All Business Areas of the Group as well as management bodies involved in the
outsourcing lifecycle must comply with the Outsourcing Policy (of which the Outsourcing Strategy is an integral part) and the
relevant Procedures.
• Electronic Fraud Management Policy: The Electronic Fraud Management Business Area is responsible for the oversight and
operational management of both e-Banking and Card Services Anti-Fraud systems, which feature a rule creation and customization
environment.
Adhering to principles for the protection of Human rights
The Group demonstrates its commitment and its general approach for respecting the human rights of consumers and/or end-users through
adhering to the following principles:
• As signatory of the United Nations Global Compact (UNGC), Alpha Bank operates in respect with “Principle 1: Businesses should
support and respect the protection of internationally proclaimed human rights”; and “Principle 2: make sure that they are not
complicit in human rights abuses.”
• Through the UNEP FI, the Group has committed to the 6 Principles for Responsible Banking (PRB) including “Principle 3: Clients and
Customers: “We will work responsibly with our clients and our Customers to encourage sustainable practices and enable economic
activities that create shared prosperity for current and future generations.”
It is noted that no standalone human rights policy is in place.
General approach for Customer engagement and measures to provide or enable remedy for human rights impacts
The Group continuously seeks to engage effectively with its Customers by establishing meaningful, two-way communication, building trust and
creating value. Through Customer engagement, the Group identifies and understands its Customer needs and expectations, continuously
improves the offering of products and services as well as updates and enhance its policies, mechanisms and processes to maintain trust and
build long-term relationships with its Customers.
The Group has a general approach for providing and enabling remedy for human rights impact, through the establishment of both proactive
and reactive measures. The protection of the legal interests and human rights of its Customers is outlined in the Bank’s Code of Conduct and
Ethics. In addition, the Group collaborates with its stakeholders (such as NGOs, and others) for facilitating effective remediation. It has also
established mechanisms and channels available to its consumers, that enable them to raise their concerns. Corrective actions are immediately
taken to mitigate potential risks for the affected Customers. Additionally, the Group undertakes actions to further improve and strengthen
existing technical and organizational measures to prevent the recurrence of such incidents. Please refer to [S4-3] “Processes to remediate
negative impacts and channels for consumers and end-users to raise concerns” for more information regarding the channels in place.
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Also you may refer to section [S1-1] for references on the alignment of the Corporate Responsibility Policy with internationally recognized
guidelines, principles and initiatives on sustainable development.
It is worth mentioning that no incidents of non-respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration on
Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises that involve consumers and end-users have been
recorded and reported in the Group’s downstream value chain. For more information on how the Group monitors compliance with policies,
please refer to [G1-1] Business conduct policies and corporate culture as well as to [S1-1] Policies related to own workforce.
[S4-2] Processes for engaging with consumers and end-users about impacts
The Group’s stakeholder engagement approach is founded on the principles of transparency, inclusivity, and accountability, ensuri ng that its
sustainability efforts align with stakeholder expectations and values.
The Alpha Bank Group aims to maintain ongoing dialogue and collaboration with these stakeholders to understand and address their
expectations, needs, concerns, and requests as much as possible. Recognizing the diversity among its stakeholders, the Bank has developed
tailored engagement and communication strategies to meet the unique needs and preferences of its consumers and end-users.
Alpha Bank prioritizes delivering an exceptional customer experience throughout the entire service cycle and the delivery of high-quality
products and services. The Digital Sales and Customer Experience Business Areas alongside the Customer Service Business Area are supporting
the efforts to achieve these goals. Systematic collection of customer feedback and analysis of customer insights are integral part of these
efforts. Flagship initiatives promoting the customer-centric culture for Alpha Bank S.A., the largest subsidiary of the Group, are enabled by the
“Voice of Customer” program. This includes, a series of surveys addressed to both Wholesale and Retail Customers measuring a number of
indices such as
• the Net Promoter Score (NPS) – measures the degree of recommendation of the bank based on overall relationship or specific
experiences across channels, products, or Customer journeys,
• the Customer Satisfaction (CSAT) - measures how satisfied a Customer is with their overall cooperation with the bank or specific area
of the business,
• the Customer Effort Score (CES) - measures a Customer’s level of effort while interacting with the brand or specific touchpoints,
products, and services.
Moreover, in 2025, Alpha Bank, launched the “close-the-loop” initiative, which involves monthly calls for individual Customers to deepen
feedback while addressing specific pain point by offering real-time support where possible.
In addition, Alpha Bank Cyprus was the first bank in Cyprus to introduce the “Customer Advocate” as an enabler to the “Voice of Customer”.
The Corporate Governance and Customer Advocacy Business Area ensures the fair handling of Customer complaints and monitors th e
implementation of corrective actions. In alignment with the above, the relevant Customer Complaints Management Policy has been revised
including reporting to the CEO and subsequently to the Board of Directors cases where the Bank’s response is deemed unfair.
The Group is dedicated to frequent engagement with its stakeholders, providing them with transparent and material information.
Furthermore, Relationship Managers collect and communicate Customer feedback. Communication with all stakeholder groups is co nducted
on an annual, bi-annual, quarterly, and ad hoc basis, and detailed information is available under [SBM-2] “Interests and views of stakeholders”.
Effectiveness of the Customer engagement
The effectiveness of the engagement with consumers and/or end-users is evidenced by identifying specific matters through workshops,
surveys with specific Customers, and feedback received through the existing channels for consumers to raise concerns and integrating their
expectations and needs in informing and initiating new initiatives, products and services. Alpha Bank has designed a Customer Experience
program comprising horizontal initiatives and IT investments designed to address identified customer pain points. The three
‑
year
implementation roadmap aims to improve service consistency, accessibility, and customer satisfaction, reinforcing responsible banking
practices and long
‑
term stakeholder value. It is mentioned that currently there is no specific process in place for engaging and for gaining
insight into the perspectives with consumers and/or end-users who may be particularly vulnerable to impacts and/or marginalized consumer
groups is in place. The general approach for consumer engagement applies to all consumers of the Group’s products and services. Please refer
to [GOV-1] The role of the administrative, management and supervisory bodies to see the relevant responsibilities on the organizational
structure.
Operational responsibility for ensuring the accomplishment of engagement and outcomes
For Retail Customers, operational responsibility for day‑to‑day engagement and the integration of key insights into products and services
resides with the Chief Retail Client Strategies Officer. The primary objective is to ensure Customer satisfaction and deliver high-quality
products and services. To achieve this, the Business Area actively gathers input through Customer surveys, relationship managers, and by
analyzing data from the Bank’s digital platforms to understand consumer behavior and preferences. The insights gathered from these
engagement activities are leveraged to inform Alpha Bank’s policies, practices, and product development, ensuring that Customer
expectations and concerns are addressed effectively. For Wholesale Customers, Relationship Managers (RMs) collect and transmit feedback to
the Wholesale Business Development Area, with Chief Wholesale Banking maintaining the operational responsibility.
[S4-3] Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
It is noted that no negative material impacts on Customers have been identified through the Double Materiality Assessment conducted in
2025. However, in the event of negative impacts to its Customers, the Bank has established specific mechanisms and processes for
contributing to the remedy of them.
Any actions that might have caused to the Customers, may be reported through the Whistleblowing mechanism, available on the website. The
Whistleblowing Policy ensures that anonymity of the Whistleblower that utilizes the mechanism, will be properly protected in order to avoid
any possible negative consequences, such as threats or attempts of retaliation, or discrimination or any other form of unfair treatment.
Submitted reports are communicated only to predefined persons, the number of which is narrowed to those responsible for carrying the
investigation and are entitled to act in discretion and confidentiality. By respecting the above would also result in protecting the identity of the
reported persons. Please see the [G1-1] Business conduct policies and corporate culture.
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In addition, through the “Notification on the Processing of Personal Data”, where GDPR is applicable, Customers are informed on how their
personal data is processed by Alpha Bank or third parties on its behalf and on how to exercise their rights as per the GDPR. It also entails the
purpose, sources, recipients, storage duration, and contact information regarding the Data Controller and Data Protection Officer.
The "Notification on the Processing of Personal Data" is available on Alpha Bank’s website. The respective “Notification” is also available on
each of the Group subsidiaries’ website. Furthermore, special privacy notices are provided to Natural Persons whenever necessary.
Furthermore, a Support Centre has been established to address Customer grievances. Under this mechanism, the Bank has a Customer Service
Call Centre, Merchants Customer Service Call Centre, and direct lines for different business units/subsidiaries. The main call center directs to
Alpha Bank S.A. with individual contact numbers listed for the Group’s services at Alpha Real Estate S.A., Generali, Alpha Le asing, AlphaTrade,
and Alpha Mutual Funds. Complaints are managed by the Customer Service Business Area at Alpha Bank. It tracks and monitors issues raised
and addressed through a Contact Form on the Bank’s website and listed contact numbers. The Bank aims to revert to Customer is sues with a
clear and substantiated reply in accordance with the applicable Regulatory and Legal provision. The Bank has established and maintains an
updated Complaints Management Procedure, ensuring the lawful, effective, and transparent handling of complaints in full compliance with the
applicable regulatory framework Upon receiving a complaint, the Customer Service Business Area undergoes a 4-step process:
1. Acknowledgement of receipt of the case
2. Investigation with cooperation of the competent Business Areas of the Bank
3. Resolution of the issue
4. Customer response
If the Customer disagrees with the proposed resolution or reply, they are provided with the option to decline the proposed resolution. In that
event, the consumer may revert to the Hellenic Financial Ombudsman (the contact information of which is provided on the Group’s website).
All the above information is provided on the Bank’s website, including the expected wait time and answers to Frequently Asked Questions.
Customers are updated throughout the process using the contact details they provided (by SMS, phone number, or letter).
These processes have been implemented by the Bank without the participation of third-party mechanisms.
The above processes refer to channels provided to Customers for raising their concerns, not only for the Bank’s activities, but as well for any
activities provided to them from the Bank with cooperation of business partners (i.e. suppliers and other external parties). Currently, no
particular assessment takes place for the effectiveness of the mechanisms and channels that the Group utilizes for its consumers to raise their
concerns.
2025 Complaints: Alpha Bank S.A. monitors and tracks the number of complaints submitted, independently of their nature. The number of
complaints received from consumers and/or end-users during 2025 were 19,242. Customer usage of these channels as a means of providing
feedback demonstrates that Customers feel empowered to raise concerns and trust the mechanisms for resolution disclosed above. Please
also refer to section [G1-1] Business conduct policies and corporate culture and section [G1-3] Prevention and detection of corruption and
bribery on how Customers become aware of and trust the processes as a way to raise their concerns.
[S4-4] Taking action on material impacts on consumers and end-users, and approaches to managing material risks and
pursuing material opportunities related to consumers and end-users, and effectiveness of those action
As described in [S4-2] “Processes for engaging with consumers and end-users about impacts” and [S4-3] “Processes to remediate negative
impacts and channels for consumers and end-users to raise concerns” the Group has not recognized any material negative im pacts on
consumers and/or end-users through its business activities. As a signatory to the Principles for Responsible Banking, Alpha Bank has adopted
the UNEP-FI Commitment for Financial Health and Inclusion since 2019 and is acting through its business activities to foster healthy social
paradigms and objectives. Thus, the implementation of the following actions contributes to the achievement of corresponding policy
objectives and, where applicable relevant targets.
Among the key actions that the Group performs to increase the positive impacts created to its Customers are reflected through its Sustainable
Finance Framework (SFF) and refer to:
• The development of Green and Sustainable financial products such as products for SME lending in emerging markets, Microfinanc e
lending, Financing of construction, renovation and maintenance of houses destroyed or damaged by natural disasters.
• The integration of sustainability criteria into credit and loan approvals.
The products are targeted especially to affected stakeholder groups, such as Female, Rural populations focusing on agricultural production and
value chains, Excluded and/or marginalized populations, financially, disadvantaged groups as referenced also in [S4-1] “Policies related to
Customers”, whereas under section [S4.SBM-3] “Material impacts, risks and opportunities and their interaction with strategy and business
model in relation to consumers” a detailed reference to the relevant financing products and services is provided. In addition, the SFF does not
currently set a defined time horizon regarding the number of products aligned to it, but it has a long-term view and has a Group application.
Identified risks through the Double Materiality Assessment pertain the topics of Privacy, Access to Quality Information and Responsible
Marketing Practices. The Group ensures that these risks are mitigated through key actions which are supported by robust internal control
mechanisms, processes that ensure ethical marketing communications, transparency, honesty, and compliance with regulatory standards.
These processes ensure that for every advertising project, a communication plan assessment is performed by the competent Business Areas
and, if required, by the Legal Services or the Regulatory Compliance Business Areas, to ensure objectivity when providing information.
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Advertisements include all necessary details to inform the public, as described in previous reference under “Other informatio n on policies
related to Customers”. Hence these actions ensure that there is no negative ramification for Customers due to manipul ation or misinformation
as the above processes serve to mitigate such outcome. When space or time constraints prevent full disclosure (such as in TV or radio spots),
Alpha Bank provides its website for more information. These practices apply in Greece for Alpha Bank S.A., but similar practices are also
established in other areas where the Group operates. Thus, Alpha Bank complies with the regulatory framework in force regardi ng
transparency in providing information to contractual parties, precontractual information, advertising as well as the terms of contracts with its
Customers.
The above actions do not have a defined time horizon for completion, but govern continuously the Group’s operations. Regardin g the progress
of the actions, regular monitoring takes place to ensure that no incidents of non-compliance with regulatory framework and marketing
practices have been occurred. Through the implementation of the above controls and processes, the Group also mitigates the risk to
consumers regarding Access to Quality Information through a review by the related Divisions prior to releasing information to consumers.
Through continuous training programs for Employees, the Group prevents any potential negative indirect impact on Customers, or realization
of risk that concern Privacy -related incidents. Trainings to mitigate the risk of privacy include the Cybersecurity Awareness Program,
Cybersecurity and Information Security training modules, and the electronic Fraud training program. These trainings improve the internal
capacity building to enhance service quality and delivery, leading to increased Customer satisfaction. Trainings are performed on an annual
basis.
GDPR training
Moreover, data protection training sessions are conducted throughout the year for all new Employees. During 2025, the following sessions
took place:
• Control and Risk Culture: boosting awareness in data protection with specialized training sessions to appr. 420 Bank’s Branch
Network Employees.
• Data Protection Institutional Framework: training session with the participation of approximately 170 Group Employees in Greece
that covered various data protection issues such as Artificial Intelligence, emerging regulatory obligations (e.g. DORA, NIS II) and
third-party assessment.
Data protection training sessions take place in Group Companies in Greece, and Cyprus, where GDPR is applicable.
The above actions are ongoing and thus, there is no timeframe of completion. The progress of these actions is regularly monitored to ensure
that no severe incidents of non-compliance with regulatory framework will take place. For this reason, to support the implementation of the
above, human resources are utilized and expected to continue to be utilized in the future time horizon such as through employee training and
consulting services to empower Employees’ knowledge and skills for sustainable projects, an d utilization of technological solutions, such as
digital tools.
Furthermore, it should be mentioned that the existing processes reassure not only that no material financial effects will affect the Bank but
also that no material negative impacts will be created to its Customers.
Cybersecurity training
Regarding the identification and reaction to Cybersecurity and Information Security risks, Employee awareness and training is a critical and
continuous activity. In addition to the program for new employee induction to Group Cybersecurity and Information Security Framework
principles, a sophisticated Cybersecurity Awareness Program is being structured at the beginning of each year and supported by an e-learning
platform. During 2025, the annual Cyber Awareness Program was completed successfully, with new Cybersecurity and Information Security
training modules introduced and successfully completed by 5,287 Employees at Group level. The main training objectives, the appropriate
training strategy as well as the initial planning of the trainings are determined at this stage. Training content is updated regularly to maintain
its relevancy and is adjusted to each role, within the Bank to achieve the necessary growth and development. The training program is reviewed
during the year and may be modified according to new needs that may arise. The training plan includes specialized training and certifications
for Managerial/Administration and Technical functions in Greece, and the other countries where the Group operates.
Other Cybersecurity and Information Security Initiatives
The Cybersecurity and Information Security initiatives consider international standards and frameworks and are aligned with the Non-Financial
Risks Management Policy. The Cybersecurity and Information Security Business Area directly supports Business Areas and Group subsidiaries in
conducting Information Classification and Cybersecurity and Information Security Risk Assessments (CISRA) for applications that support
critical business processes including cloud-based applications, as well as conducting the coordination and monitoring of the execution of
improvements and remediation of deviations. Continuous and real time identification of Cybersecurity vulnerabilities for critical systems is
performed via the deployment and configuration of dedicated software on the corresponding infrastructure.
The Alpha Bank Computer Security Incident Response Team (AB CSIRT) is certified as a full member of the global Forum of Incident Response
and Security Teams (FIRST) and the Financial Services Information Sharing and Analysis Centre (FS-ISAC) and cooperates with the National
CSIRT and the National Cybersecurity Authority to ensure continuous information exchange and response to cyber threats. During 2025, the
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AB CSIRT dedicated significant time and effort towards fostering growth across various and critical Threat Management domains. The Cyber
Threat Intelligence Framework has been formalized and included within the Group Cybersecurity and Information Security Framework.
The Cybersecurity and Information Security Business Area manages the multilayered security infrastructures and mechanisms for the
protection of the services provided (defense in depth). In 2025, replacements, upgrades and major improvements of critical Cybersecurity
infrastructures were performed and a major project for Network Security Redesign has been initiated.
Electronic Fraud training
In addition, Alpha Bank runs a dedicated annual electronic Fraud training program, which is supervised by Electronic Fraud Management Unit,
to ensure Employees remain fully aware of the latest fraud trends, digital scams, and emerging attack methods. By keeping Employees
informed and alert, the Bank enables them to quickly recognize red flags, guide Customers with confidence, and step in before suspicious
activity turns into actual loss. Training is delivered through an easy-to-use e-learning platform and is updated frequently so that Employees
always work with current, practical information In 2025 the program was completed successfully by 3,023 Employees of Alpha Bank S.A. Each
module focuses on real scenarios and common fraud patterns, helping staff respond more effectively in their daily interactions. By
strengthening Employee awareness, the Bank enhances its overall fraud-prevention capability, protects Customers more proactively, and
reinforces trust across all services. The program is reviewed throughout the year and enriched whenever new threats or operational needs
arise. In 2025 the Bank supporting the importance of electronic fraud training to its Employees, has created a dedicated slot during the "Alpha
First" Induction Programs, where all new Employees receive structured training on fraud awareness. We introduced the most common types
of electronic fraud to protect not only the Bank Customers, but also themselves.
Other Electronic Fraud Management Initiatives
Electronic Fraud Management has introduced additional measures to protect Alpha Bank’s Customers. Through myAlpha Web, retail
Customers are given the opportunity to temporarily lock their e-Banking subscription if they suspect interception or leakage of their passwords
or detect suspicious activity in their e-Banking. Changes were also made to the myAlpha Code guidelines to provide a more secure experience;
the registration of the 6-digit code is now requested in all transactions to third parties in subscriptions with the service activated as well as
during login. Access is blocked upon incorrect myAlpha Code entries via SMS OTP (one-time password). Also, the text messages are now
clearer and more explanatory.
Thus, the Bank continues to invest in enhancing Customer awareness and empowering them to recognize and respond to warning signs of
electronic fraud. The ongoing development of internal anti-fraud controls and system safeguards is critical for Alpha Bank, hence a series of
educational videos are being available on both the Bank’s website and YouTube channel. These resources present practical, real-life scenarios
to help Customers better understand common fraud techniques and how to avoid them. Customer security remains one of the Bank’s highest
priorities, and we are committed to providing the tools, information, and protections necessary to ensure their ongoing safety. On the other
hand, twice a year electronic fraud awareness updates are sent not only to our retail but also to our wholesale customers.
Please refer to [GOV-5] Risk management and internal controls over sustainability reporting for more information on the Group’s approach to
risk management.
Resources for managing material impacts
For managing the impacts, the Group utilizes several human resources across its Business Areas and Group subsidiaries, including: the Retail
and Wholesale Banking Business Areas, the Digital Sales and Customer Experience, the Customer Service, the Marketing and Public Relations
Business Areas, the Group Data Protection Office, the Cybersecurity and Information Security Business Area, the Non-Financial Risks Control,
and the Central Procurement Management and Outsourcing among others monitor impacts on the Group’s Customers and end users.
Due to the nature of the Group’s business activities, no significant operational (OpEx) and/or capital expenditures (CapEx) t hat relate to the
implementation of its actions towards the achievement of its actions have been specifically attributed.
Actions to enable and provide remedy
No negative material impact on consumers and end-users has been identified. Nevertheless, the Group has established a comprehensive
framework of policies, procedures and operational mechanisms designed to prevent, mitigate and, where necessary, enable remedy for
potential adverse impacts on consumers. This framework encompasses the design of consumer‑centric products that respond to customer
needs, a robust Risk Management for credit assessment and the prevention of fraudulent activities, the implementation of ethical business
practices, and the transparency of information. In addition, the Group fosters a culture of corporate responsibility among its employees,
supporting behaviors and decision‑making that uphold consumer protection and enable the prompt handling and remediation of any issues
that may arise. Please refer to [S4-1] “General approach for Customer engagement and measures to provide or enable remedy for human
rights impacts” for additional information.
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Other Customer-related initiatives
• “Green City” collaboration: In 2025, in collaboration with the largest recycling program in Greece, Alpha Bank S.A. supported
Customers of the Bonus app with e-coupons for enhancing their accessibility to goods, while promoting recycling. By recycling
household waste at specific Mobile Green Points, Customers earn “Green City” coins, which they can convert into Bonus points
through the Bonus app. In 2025, Bonus Customers have responded with great interest and have proceeded into 6,839 conversions of
green city coins into 17,097,502 Bonus points. The collaboration between Bonus and “Green City”, actively supports recycling since it
offers an extra benefit to Bonus Customers to recycle on a regular basis. More information can be found by visiting the website.
• “myAlpha Documents” service: In 2025, more than 10,000 requests from individuals and businesses were handled remotely by the
Alpha Bank’s Branch Network and Central Services through the “myAlpha Documents” electronic document exchange platform. The
use of the service has saved more than 200,000 pages of documents that have been distributed digitally. Through myAlpha
Documents, customers are able to manage a wide range of banking requests, upload supporting documentation, and sign documents
online, without visiting a branch.
• Innovation and Entrepreneurship Support: Part of its long‑term commitment to sustainable growth and digital transformation,
Alpha Bank continues to invest in initiatives that foster innovation, strengthen the start‑up ecosystem, and accelerate the
development of new technological solutions. Through strategic programs, partnerships, and open‑innovation activities, the Group
actively supports entrepreneurship and contributes to the evolution of the financial sector, enhancing the access to Finance for
Consumers.
• FinQuest by Alpha Bank – Driving Innovation in Financial Services: The Bank’s International Innovation Competition was held for the
fourth consecutive year in 2025 and has now become a well‑established mechanism for strengthening ties with the domestic and
international FinTech and start‑up ecosystem. The purpose of FinQuest is to accelerate digital innovation in the banking sector by
fostering collaboration with FinTechs and technology start‑ups. The objectives of FinQuest by Alpha Bank 2025 included:
o Identifying AI‑powered banking solutions: Attracting pioneering ideas that address real challenges or create new
opportunities in the financial sector.
o Exploring commercial adoption: Leveraging start‑up proposals to enhance products and services, improve internal
processes, or support entry into new markets.
o Strengthening start‑up entrepreneurship: Supporting the growth and visibility of innovative early‑stage companies.
o Deepening engagement within the FinTech ecosystem: Expanding the Bank’s role and influence in the innovation
community.
o Cultivating an internal culture of innovation: Encouraging creativity, experimentation, and continuous learning across the
organization.
The competition’s final event and winner selection took place in November 2025 as part of Alpha Bank’s Innovation Day, which was
a live-streamed open event, serving as a strategic platform for Alpha Bank to communicate its vision and leadership in the era of
Artificial Intelligence.
• Accelerating Pilot Programs with Start‑ups: In parallel with its flagship innovation events, Alpha Bank continues to enhance its
ability to rapidly design and implement pilot programs with innovative start‑ups. By adopting agile methodologies and streamlined
processes, the Bank ensures that promising ideas can be tested quickly and effectively, accelerating the transition from concept to
real‑world application. This approach supports the growth of early‑stage and scale up companies while enabling the Bank to
continuously integrate emerging technologies into its operations.
• Support Female entrepreneurship: In support of female entrepreneurship, Alpha Bank completed the "Alpha Females for
VentureGarden" program in collaboration with Anatolia College, for the second consecutive year. The programme directly relates to
consumers of Alpha Bank’s services, as it targets current and aspiring female entreprene urs who operate or intend to operate small
businesses and may become or already are Customers of the Bank. The programme enhances participants’ financial literacy, busi ness
planning capability and access to financing tools, thereby supporting their ability to establish, grow and sustainably finance their
enterprises. With the inclusion of structured entrepreneurial training, delivered through five themed workshops in Athens and
Thessaloniki, the programme is addressing areas such as business strategy, digital marketing, financing instruments and financial
management. In this context, the initiative contributes positively to financial inclusion and access to finance for women
entrepreneurs.
Through these initiatives, Alpha Bank reaffirms its role as a catalyst for innovation and entrepreneurship. By empowering sta rt‑ups, fostering
collaboration, and embracing new technologies, the Bank contributes to a more sustainable, competitive, and future‑ready financial
ecosystem.
[S4-5] Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and
opportunities
Regarding its material positive impacts to Access to products and services, and Contribution to Healthy Economies, Alpha Bank’s Strategic
Targets are aligned with SFF and enhance the positive contribution to consumers and end-users. The targets included below are specifically
related to consumers and end-users and as such, pertain to the downstream value chain. Progress against targets is monitored through
specific Key Performance Indicators (KPIs), as presented in the following table. Targets have been set at Group level (where no reference exists
in the table below), the largest Group entity Alpha Bank S.A. has reported progress and where relevant other Group entities will progressively
adopt them.
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Table 58 Targets relating to consumers and end-users
Target description
Target
level
Absolute/
Relative
Baseline value
Baseline
Year
46
Target
Year
Scope
Progress in 2025
KPIs
Increase access to
people with mobility
limitations to
85%
of our Branches
85% of
Branches
Absolute
80%
2023
2025
Downstream,
Alpha Bank S.A.,
Alpha Bank Cyprus
87%
47
Percentage of Branches
accessible (fitted with a
ramp or easily
accessible) by people
with disabilities (%)
Safeguard internal risk
controls that protect the
Customers’ data
N/A
Absolute
3
N/A
Ongoing
Downstream,
Alpha Bank S.A.
6
Personal Data breach
incidents (number of
incidents notified to
Personal Data
Protection Authorities)
Achieve ca. Euro 900
million of Retail
Sustainable Loans,
including loans to Small
Businesses
48
Euro 900
million
Absolute
Ν/Α
2025
2027
Downstream,
Alpha Bank S.A.,
Alpha Bank Cyprus
328.4
Total amount Euro
million
Launch new
sustainability-based
mortgage and consumer
loan products and credit
cards.
N/A
Relative
2 products
(Exoikonomo,
Ecolytiq)
2023
Ongoing
Downstream,
Alpha Bank S.A.
(Greece)
5
(My Home II,
Upgrade my
Home,Kotsovolos
Green Loans, New
Exoikonomo Cycles:
Exoikonomo 2025
& Exoikonomo –
Anakainizo gia
Neous)
Number of products
launched
Support financial
inclusion through
educational programs
addressed to teachers,
students, women and
people over 55.
N/A
Relative
4
(Alphabet of
Economics,
Circular
Economy in
Action,
Economy
lessons,
e-conomy for
all)
2023
Ongoing
Downstream,
Alpha Bank S.A.
(Greece)
4
Number of CSR
programs implemented
for the financial
inclusion addressed to
teachers, students,
women and people over
55.
Limited financing to
activities that can affect
health and well being,
including gambling,
production or trade in
tobacco and alcoholic
beverages
5%
Absolute
N/A
2017
Ongoing
Downstream,
Alpha Bank
S.A.(Greece),
Alpha Bank Cyprus,
Alpha Bank
London
1.42%
KRI- Financing provided
to gambling, tobacco
and alcoholic beverages
as % of total loan
portfolio
Please note that these metrics are absolute numbers and as such, there are no significant assumptions or methodologies behind them. It is
noted that the metrics described have not been assured by an external third party. Regarding the relative targets in the above table, the
methodologies used are indicated by the KPIs detailed in the relevant column. No other methodologies or assumptions were used.
It is noted that no interim targets or milestones have been set. The methodology for setting the targets includes the review of best practices,
peer benchmarking and understanding of the Group business model, utilizing also input from the Group’s stakehold ers, such as investors, and
clients, for detailed reference on stakeholders’ engagement regarding target setting please refer to [SBM-2] Interests and views of
stakeholders. Furthermore, targets have been set with the aim of aligning the Group business model and strategy with the contribution to the
UN Sustainable Development Goals. For setting the targets no critical assumptions were made.
In addition to the above, the Group has also the target increase digital sales by 30%. In 2025 the following were achieved:
• Digital sales 30.6%
• ~37% of cards were issued digitally in the like for like category
• families using myAlpha Vibe increased to > 7,000, and
• 3 out of 4 consumer loans were granted through digital channels.
46
Baseline year is the same with base year.
47
Alpha Bank S.A. 85% accessible (209 out of the 245) branches, Alpha Bank Cyprus: 100% accessible (25 out of 25) branches.
48
According to the 2025-2027 business plan.
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It is noted that currently, the setting of targets, the tracking of the performance against targets and the improvement of targets set, is
conducted with the involvement of internal stakeholders, and not with the participation or engagement of Customers. However, the Group
continuously seeks the engagement of Customers, for setting its policies, and respond to their needs, and will enhance further the integration
of their views into its decision-making and strategic actions.
It is noted that regarding Responsible Marketing Practices and Access to Quality Information, no specific measurable outcome-oriented target
has been set. Regarding these sustainability matters minimum safeguards apply. The overarching goal of the Group is not to cause or
contribute to significant harm of Customers through either its own operations or its business relationships. The Group will consider in the
upcoming years to review its strategic approach and enhance its performance with more outcome-oriented targets, where applicable. Please
refer to the [S4-Consumers and End Users] “Other information on policies related to Customer” and “Processes to remediate negative impacts
and channels for consumers and end-users”.
Entity-Specific Information
The effectiveness is monitored through specific Key Performance Indicators, that have been established from the Group as follows:
Access to (quality) information
Access to (quality) information has been identified as a material risk pertaining to the Group’s downstream value chain. This pertains to
potentially unsuitable promotion practices (CR), fiduciary breaches (miscellaneous, CR), disputes over advisory activity, and product suitability
issues / inadequate disclosures of product terms (CR).
Table 59 Number of incidents of non-compliance concerning product and service information and labelling
Alpha Bank Group
2024
2025
Number of incidents of non-compliance concerning product
and service information and labelling
49,50
0
0
This metric was calculated based on incidents of non-compliance with regulations resulting in a fine, penalty, or warning, and incidents of non-
compliance with voluntary codes. This metric excludes any incidents of non-compliance in which the Group was determined not to be at fault
as well as any incidents of non-compliance that relate to events in periods prior to the reporting period, if applicable.
Responsible marketing practices
The Group has identified Responsible Marketing Practices as a material inherent risk pertaining to its downstream value chain through its
products/services and business relationships with Customers. This is due to product suitability issues/inadequate disclosure of product terms
(CR), unsuitable promotion practices (CR), and miscellaneous fiduciary breaches.
Table 60 Incidents of non-compliance concerning marketing communications
Alpha Bank Group
2024
2025
Incidents of non-compliance concerning marketing
communications
50
,
51
0
0
This metric was calculated based on incidents of non-compliance with regulations resulting in a fine, penalty, or warning, and incidents of non-
compliance with voluntary codes. This metric excludes any incidents of non-compliance in which the Group was determined not to be at fault
as well as any incidents of non-compliance that relate to events in periods prior to the reporting period, if applicable. It is noted that the
metrics described have not been assured by an external third party.
Personal Data Protection
In 2025, the following personal data breach incidents were identified and reported. For these incidents corrective actions have been
immediately implemented in order to mitigate potential risks for the affected data subjects. Moreover, the Group Entities proceeded to
actions to further improve and strengthen the existing technical and organizational measures in order to avoid the recurrence of such
incidents.
49
GRI Standards, Disclosure 417-2
50
It is noted that the data has not been externally verified.
51
GRI Standards, Disclosure 417-3
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Table 61 Metrics to safeguard internal risk controls that protect Customers data
Alpha Bank Group
2024
2025
Personal Data breach incidents (number of incidents
notified to Personal Data Protection Authorities)
52
6
6
The assessment of all incidents is performed according to internal procedures and based on the provisions of Art.33 of GDPR and the relevant
guidelines issued by the European Data Protection Board. No significant assumptions have been made. It is noted that the metrics described
have not been assured by an external third party.
Access to products and services
IQonomy is a corporate social responsibility initiative designed to strengthen financial literacy and advocate for a circular economy, with the
overarching objective of tackling financial exclusion and fostering sustainable growth. It targets social groups identified by the OECD as
particularly susceptible to financial literacy challenges. IQonomy is fully aligned with the Greek national strategy for financial literacy launched
by the OECD and overseen by the Greek Ministry of Economy and Finance. The program aims to instill fundamental financial knowledge and
skills in students at all educational levels, empower women, and educate individuals aged 55 and above on navigating the digital landscape of
transactions. Comprised of four specialized programs:
• Alphabet of Economics
• Circular Economy in Action
• Economy Class
• e-conomy for all
These initiatives are carried out in partnership with Civil Society Organizations.
Table 62 FN-CB240a.4 Number of participants in financial literacy initiatives for unbanked, underbanked, or underserved
Customers
Alpha Bank Group
2024
2025
Alphabet of Economics
593 teachers and 6,693 students
599 teachers and 5,766 students
Economy Class
383 women Employees, Customers, general
public
53
169 general public
54
e-conomy for all
195 participants
101 participants
Circular Economy in action
235 teachers and 16,166 students
260 teachers and 17,712 students
The metrics described on “Table 62”, refer to absolute numbers of participants and as such, there are no significant methodologies behind
them. These, refer to 2025 as year of implementation. The scope of financial literacy is enabled by four programs covered under the IQonomy
initiative, through which students, teachers, women, and people over 55 can apply. All participants are considered as direct beneficiaries,
which the common practice for CR Programs. A Social Impact Assessment & Social Return on Investment Report (SIA/SROI) is conducted by a
third-party consultant and external body on behalf of Alpha Bank on annual basis for each program. In more detail:
Alphabet of Economics:
• Runs in collaboration with the non profit organisation ActionAid Hellas.
• The program runs during school year, is addressed to school teachers and students and is approved by the Institute of Educational
Policy (ΙΕΠ).
• Εducational method: train the trainer seminars for school teachers. In-class workshop for students aged 10-15 years old.
• An open call takes place before the beginning of each cycle and teachers can apply to participate to training seminars for free.
• The program is monitored through a report sent by ActionAid and shared with Alpha Bank upon the completion of school year.
• The SROI for the 2024 implementation (carried out during 2025) was: for every Euro 1 invested in the program, at least Euro 7.35 of
value is returned to society.
Economy Class:
• Runs in collaboration with NGO WHEN.
• Addressed to women 18+ from all over Greece.
• Training method: monthly on-one seminars. Runs during a period of 9 months.
• An open call takes place before the beginning of each cycle and women can apply to participate to training seminars for free.
• Monitored through two reports per year (a midterm and a final report) sent by WHEN and shared with Alpha Bank upon the
completion of each evaluation phase.
• The SROI for the 2024 implementation (carried out during 2025) was: for every Euro 1 invested in the program, at least Euro 12.83 of
value is returned to society.
52
GRI Standards, Disclosure 418-1(b)
53
The total number for 2024 includes 122 women Employees, 86 women Customers and 175 women from general public through the collaboration with Women
On Top Organization.
54
The total number for 2025 includes 169 women from general public through the collaboration with WHEN Organization.
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e-conomy for all:
• Runs in collaboration with NGO People Behind.
• Addressed to people 55+.
• Training method: physical or on-line seminars.
• NGO approach Municipalities that are interested to host the program and the seminars take place at the municipality’s Community
Center for Seniors (ΚΑΠΗ).
• Monitored through two reports per year (a midterm and a final report) sent by People Behind and shared with Alpha Bank upon the
completion of each evaluation phase.
• The SROI for the 2024 implementation (carried out during 2025) was: for every Euro 1 invested in the program, at least Euro 7.41 of
value is returned to society
Circular Economy in action:
• Runs in collaboration with NGO SciCo (Science Communication).
• Runs during school year (2 cycles per year), is addressed to school teachers and students and is approved by the Institute of
Educational Policy (ΙΕΠ). Educational method: train the trainer seminars (online and physical) for school teachers and in-class
workshop for students 12-17 years old.
• An open call takes place before the beginning of each cycle and teachers can apply to participate to training seminars for free.
• Monitored through a report sent by SciCo which is shared to Alpha Bank upon the completion of each cycle.
• The SROI for the 2024 implementation (carried out during 2025) was: for every Euro 1 invested in the program, at least Euro 8.94 of
value is returned to society.
Table 63 Metrics for Access to Finance and Housing
Alpha Bank Group
2024
2025
Disbursements of retail sustainable loans and consumer
green loans for housing purposes
55
Euro 39.1 million
Euro 305.2 million
Number of voice-directed ATMs for visually impaired people
299 of 1,193 (~25%)
300 of 1,199 (~25%)
56
The type of loans mentioned are aligned with Group’s Sustainable Finance Framework, in which sustainable criteria are clearly defined. It is
noted that the metrics described have not been assured by an external third party.
Please note that these metrics are absolute numbers and as such, there are no significant assumptions or methodologies behind them. It is
noted that the metrics described have not been assured by an external third party.
CONTRIBUTION TO HEALTHY ECONOMIES
By providing tailored financing solutions such as business loans, credit lines, and trade finance, the Group enables economic growth and
contribute to Healthy economies. More information about how the Group business model and strategy as well as the management of impacts
contribute to Healthy Economies can be found in the sections under ESRS S4 “Consumers and end-users” chapter. The following metrics relate
to new financing volumes achieved in 2025, hence reflect the Group’s actions towards the implementati on of its target to reach Euro 3.8
billion by 2027.
Table 64 New financing volumes to Retail Green and Social Loans, and Loans to small businesses
Alpha Bank Group
2024
2025
Disbursements of Retail Green and Social Loans and
Sustainable Loans to small businesses
57
(total amount in Euro million)
Euro 67.5 million
Euro 328.4 million
It is noted that these metrics are absolute numbers and as such, there are no significant assumptions behind them. The type of loans
mentioned are aligned with Group’s Sustainable Finance Framework, in which sustainable criteria are clearly defined. It is noted that the
metrics described have not been assured by an external third party.
55
Retail sustainable loans related to co-financed loans under state incentives programs such as, “EXOIKONOMO” and other social loans (e.g. education).
Consumer green loans for housing purposes and Mortgage Sustainable Loans (with EPC certificate’s grade A or higher for new properties and B+ or higher
for properties renovation).
56
As of 31.12.25, most of Alpha Bank's ATMs (>1,100) in Greece have had hardware sockets to support the voice guidance service. However, the Bank has
implemented this service in 300 ATMs as it has a total of 300 licenses for this software. The following factors were taken into account in the selection of
ATMs:
- coverage of as many counties as possible
- central points with high transaction volumes
- proposals of the Panhellenic Association of the Blind (high traffic points, e.g. near/opposite clubs)
The number of ATMs providing this service will increase with the approval of the purchase of additional software licenses.
57
Retail Green and Social Loans related to retail sustainable loans, consumer green loans for housing purposes and sustainable loans to small businesses, such as
EU RRF loans and other EU co-financed loans.
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Table 65 A maximum cap of 5% on specific financing activities
Alpha Bank Group
2024
2025
Financing provided to gambling, tobacco and alcoholic
beverages as % of total loan portfolio
58
N/A
1.42%
GOVERNANCE
ESRS G1 - BUSINESS CONDUCT
[G1-1] Business conduct policies and corporate culture
Alpha Bank Group is committed to conducting business according to applicable laws, rules, regulations, and the highest ethical standards. This
commitment is an essential element of the responsibility it bares towards its Customers, Shareholders, and other Stakeholders for the
protection of the reputation and long-term success of its business. The Group adopts a zero-tolerance approach towards illegal or other
actions which might negatively affect its reputation and credibility. These commitments are crucial pre-conditions for the maintenance of a
robust corporate culture which contributes to the highest standards of conduct with business issues.
Alpha Bank S.A. adheres to effective Corporate Governance, which pursues on an ongoing basis. Thus the Bank and its Group subsidiaries
consider the requirements of the institutional framework, the best practices at international and at European level, the interests of its
Shareholders as well as the expectations of its Stakeholders and the society.
Following a resolution of the Board of Directors and with reference to article 17 of Law 4706/2020, Alpha Bank S.A. adopted the Hellenic
Corporate Governance Code of the Hellenic Corporate Governance Council (the “Code”). The Alpha Bank S.A. adheres to the Code which is
available on its website.
The Board of Directors (BoD) is responsible for the management of Alpha Bank S.A.’s affairs, including the oversight of all m atters related to
business conduct. The BoD holds the ultimate and overall responsibility for Alpha Bank S.A. and defines, oversees, and is accountable for the
implementation of governance arrangements that ensure the effective and prudent management of the Bank. In this context, the BoD:
• ensures the integrity of the accounting and financial reporting systems, including the adequacy of financial and operational controls
and compliance with applicable laws and relevant standards,
• oversees the Bank’s disclosure framework and the effectiveness of communication processes,
• provides comprehensive oversight of senior management and monitors their performance in line with the Bank’s strategic
objectives.
Furthermore, the BoD retains the ultimate responsibility for all business conduct issues relevant to Alpha Bank S.A., including the prevention of
bribery and corruption, as well as the ongoing evaluation, reinforcement, and development of a robust corporate culture. Information on the
role of the administrative, management and supervisory bodies and their expertise on business conduct matters is disclosed under [ESRS 2]
“Board of Directors relevant experience”. Please also refer to the Corporate Governance Statement of the Annual Report for further details on
the BoD responsibilities and composition.
Fostering a Strong Corporate Culture
Alpha Bank Group’s Corporate Culture has been shaped by its positive contribution to the Economy and Society over the past 140 years.
Known for the strong financial expertise and stability, the Group maintains a corporate culture that leverages its Purpose and Values as a
compass and is supported by a robust set of policies disclosed in the following “Policies” section, which covers key areas of business conduct
topics that are material to Alpha Bank S.A. and central to its operational effectiveness.
Policies
All policies, procedures, and controls safeguard the prudent management of non-compliance risk with the applicable regulatory framework, as
well as the alignment of corporate culture with a robust business conduct framework
59
. The Group’s existing policies are structured to address
the risks identified through the Double Materiality Assessment.
This framework includes the Code of Conduct and Ethics, the Whistleblowing Policy, the Anti-bribery and Corruption Policy, the Anti-Money
Laundering and Counter-Terrorism Financing Policy, and the Policy on the Prevention of Conflicts of Interests. Additionally, fundamental Codes
and Policies and Compliance Regulations applied by Alpha Bank Group are provided in the Governance section of Alpha Bank’s we bsite. The
BoD is accountable for these policies, while the Compliance Business Area functions as the owner and is responsible for responding to any
concerns or questions from staff, as well as for monitoring their proper implementation through internal controls which cover all functions,
such as:
• second-line monitoring performed by the Compliance Business Area on adherence to regulatory and internal requirements,
• thematic compliance reviews and targeted monitoring activities based on identified risk areas,
• ongoing AML/CFT surveillance and transaction monitoring,
• monitoring of Policy implementation and identification of areas for enhancement,
• periodic reporting by the Compliance Function to Senior Management and the relevant Board Committee, and
58
Funding rule on specific activities as per the Group’s Exclusion List. The numerator of the KRI is the sum of outstanding balances recorded under both on-
balance-sheet and off-balance-sheet for the following activities: production or trade of alcoholic beverages (excluding beer and wine) tobacco, gambling,
casinos, and equivalent enterprises (betting platforms and stores) as of the respective reference date. The denominator of the KRI is the amount of the
gross loans as of the respective reference date. It is noted that the metrics described have not been assured by an external third party.
59
The Compliance Business Area, in conjunction with other Areas of the Bank, is responsible for managing the risk of non-compliance with the
applicable regulatory framework, in its role as a second line of defense and as part of the Internal Control System. In particular, it
identifies, assesses and manages the risk to which the Bank may become exposed in connection with the applicable regulatory framework.
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• follow-up of corrective actions arising from internal control findings to ensure timely implementation.
These Policies are addressed to all Employees of the Group, as well as to all Stakeholders related with it. They are designed to complement the
Personnel Regulation, Policies and Procedures of the Bank, which refer to the general duties of all Employees. Policies are in line with the
applicable national and European regulatory framework, the principles of the UN Global Compact and best practices within the European
Union. There is also alignment with the United Nations Convention Against Corruption Principles. Although the Group has not yet formally
endorsed the Convention, Alpha Bank is in the process of evaluating the steps required for formal alignment and endorsement. The Bank plans
to finalize its assessment and establish a formal action plan and timeline for implementation, ensuring full consistency with the Convention’s
requirements.
The following policies are made available to all potentially affected Stakeholders who may wish to use them and/or implement them through
the intranet (for internal stakeholders) and the public website (for external stakeholders), with a corresponding circular uploaded in the event
of a new or updated Policy.
The Group has not yet set specific targets related to anti-corruption and anti-bribery, aside from the metrics provided and trainings covered
per, as the enforcement of the policies described ensure compliance with a strong corporate culture and values.
Nonetheless, the Group has ensured to take all necessary actions needed to address the policy-objectives:
• Wide access of the relevant policies to all internal and external stakeholders
• Availability of appropriate channels for the handling of internal and external Whistleblowing reports
• Regular trainings covering the scope of the policies comprising sound business conduct
Code of Conduct and Ethics
The Code of Conduct and Ethics outlines the principles that Alpha Bank Group stands for, aiming to provide Personnel with ample guidance on
conducting business in an ethical manner. The Code applies to all persons linked with Alpha Bank and its Subsidiaries through an employment
contract and Board Members as well as individuals or legal entities connected to the Group or Group companies through a formal agreement
e.g., contractors, consultants etc. The Code is aligned with key international standards and voluntary initiatives to which the Group has
committed to, including the principles of the UN Global Compact and the OECD Guidelines for Multinational Enterprises.
The Code of Conduct and Ethics, continues to reflect comprehensive Group policies, clear expectations for ethical behavior, a strong risk
management culture, and compliance with regulatory and legislative framework. More information can be found in [S1-1] Policies related to
own workforce.
The Group conducts internal audits to monitor compliance with the regulatory framework and has put in place specialized control and
reporting systems, working closely with the competent Regulatory Authorities to combat money laundering and financial crime.
In order to ensure compliance with the Policies, the Compliance Function conducts periodic monitoring and control exercises, enabling the
Bank to identify business conduct irregularities and breaches. Depending on the severity of the incidents identified through this periodic
monitoring and control, the Audit Committee will be informed.
As at-risk functions the Group has defined those that interact directly with Customers, both natural persons and legal entities; those that
operate as part of the Alpha Bank Branch Network fall mostly under this category. Indicative examples of at-risk functions include:
Retail and Business Banking Relationship Managers, Corporate and Commercial Banking Customer Service Officers, Branch Customer Service
Officers, Front-office Tellers, SME and Corporate Lending Officers, and other roles with direct Customer engagement or decision-making
authority related to Customer onboarding, credit evaluation, transactions, and financial product distribution.
[G1-3] Prevention and detection of corruption and bribery
Whistleblowing Framework
A robust Whistleblowing Framework has been in place for several years, enabling Employees, Customers and Suppliers, or other Stakeholders
who become aware of serious irregularities, omissions, or offences, to report them in a reliable and confidential manner. The Whistleblowing
Framework is the main monitoring and reporting mechanism available to both internal and external stakeholders to report potential incidents
and allegations as those relate to the entirety of the Policies described herein (i.e. the Policy on the Prevention of Conflicts of Interest, the
Code of Conduct and Ethics, Anti-money Laundering, Counter-Terrorist Financing, and the Anti-Bribery and Corruption Policy).The Bank has set
a Whistleblowing Policy which complies with the requirements of the regulatory framework, as stipulated in the provisions of Bank of Greece
Executive Committee’s Act 243/2025, as well as of Directive (EU) 2019/1937 of the European Parliament and of the Council on “the protection
of persons who report breaches of Union law”.
The Policy constitutes a means of ensuring the integrity, internal governance, and reputation of the Bank. It contributes to the identification of
risks and to the adoption of the appropriate corrective measures, including but not limited to, enhancing the Internal Control System,
detecting in advance incidents of fraud or other serious offenses, applying the appropriate measures to liable parties and, when required,
notifying the competent Authorities, as the case may be.
Ensuring an environment of trust and safety for their Employees, Customers and Suppliers, the Bank encourages reporting in good faith of
illegal acts or serious offenses, which come to their attention.
An inviolable principle of the Policy is to protect anonymity and confidentiality of the personal data of Whistleblowers and, in case they are
Employees of the Bank, to safeguard that their professional evaluations are and will be performed impartially.
The whistleblowing procedure aims at strengthening transparency, which encourages the reporting of incidents that give rise to violations of
the Procedures and Policies of the Bank as well as the reporting of incidents of fraud, corruption, coercion, or other violations.
The Bank has set reporting channels which are available and easily accessible to all Personnel, Customers, Suppliers, and other Stakeholders.
Reports can either be submitted via phone, through which a 24/7 hotline is also available, or via a dedicated e-mail or by post, directly to the
Chief of Compliance. The reports can be submitted on an anonymous or eponymous basis. In all cases, the identity and anonymity of the
whistleblower is protected. The Whistleblowing Policy explicitly protects whistleblowers against retaliation, in line with Directive (EU)
2019/1937 and Law 4990/2022. Protection includes safeguarding identity, confidentiality, and ensuring that no adverse treatme nt,
discrimination or unfair evaluation occurs as a result of reporting as referenced in section [S4-3], which provides further detail on non-
retaliation safeguards.
All reports are submitted from Regulatory Compliance to the Whistleblowing Committee, and, upon request of the Whistleblower, the report
may also be submitted, by means of a physical meeting, with a member and the secretary of the Committee. The Members of the Committee
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152 | ANNUAL FINANCIAL REPORT
are the Chief of Compliance, Internal Audit, Legal and HR – as such, separate from the chain of management involved in the specific matter.
The Members designated to assess whistleblowing reports are senior Officers belonging to the Bank’s second- and third-line control functions,
each already subject to continuous regulatory and professional training requirements in their respective areas. Their role in the
Whistleblowing Committee requires familiarity with the applicable national legislation transposing D irective (EU) 2019/1937, the Bank’s
Whistleblowing Policy, confidentiality obligations, and non-retaliation safeguards whilst training on these elements is incorporated into the
broader compliance and governance training frameworks that apply to all senior control-function Officers. When a report is submitted to the
Whistleblowing Committee, a series of actions are undertaken to ensure it is treated appropriately. The Whistleblowing Committee carefully
examines the report’s content to determine the existence of irregularities, omissions, or offenses. In the case where those are present, the
Committee will then refer the report for further investigation to the Internal Audit Business Area or for any further necessary actions to the
competent Unit(s) of the Group Alpha Bank S.A., if required. Once these procedures are complete, the findings are referred to the
Whistleblowing Committee which will determine whether the issue has been resolved satisfactorily and if there is need for further
investigation and referral of identified violations to the Management of the Bank.
The Chair of the Committee submits, on a quarterly basis, an activity report, to inform the Audit Committee of the reports received and
handled during the reported period and is always informed of any significant events on a timely basis. In addition to the follow-up procedures
set out under Directive (EU) 2019/1937, Alpha Bank applies additional internal procedures for the handling of business conduct incidents.
Specifically, cases may be referred for independent investigation to the Internal Audit Division, escalated for disciplinary handling to HR
Operations, or submitted for decision to the Executive Committee or the Board of Directors depending on the seniority of the person
concerned. The Whistleblowing Committee also assesses cases originating from Regulatory Authorities and may handle matters outside the
formal scope of the Policy where independent handling is required. Such cases may be initiated, inter alia, through the compl aints’
management process, following requests of the Regulatory Authorities or through the grievances of Customers, Suppliers and Employees via
various communication channels. Furthermore, the Committee conducts annual reviews of the Policy, proposing amendments where
necessary.
Under the responsibility of the Regulatory Compliance Business Area, the Whistleblowing Policy shall be communicated to Employees and
posted on the Bank’s website in a separate, easily identifiable and accessible section available to potentially affected Stakeholders.
Information shall include the procedures applicable for reporting a case, and the way the Bank may request the Whistleblower to clarify
elements of the report, or to provide additional information, the timeframe for providing feedback and the type and content of such feedback,
as well as the nature of the follow-up over the reports.
In line with its firm and unwavering position against corruption, bribery and fraud, Alpha Bank S.A. has issued a Group Anti Bribery and
Corruption Policy and established relevant control mechanisms in order to mitigate the relevant risks.
Anti-bribery and Corruption Policy
As per previous mention, Alpha Bank has developed an Anti-bribery and Corruption Policy which applies to the entire Group. The Policy is
addressed to the Members of the BoD and its subsidiaries (including those of Special Purpose Vehicles), to Chief Executive Committee
Members, Directors, Employees of the Group Alpha Bank S.A., and other stakeholders such as suppliers of goods and/or services that transact
with the Group, Alpha Bank S.A., Public and Government Officials, Advisers, and Customers. The Policy is easily accessible to all internal and
external stakeholders through Alpha Bank S.A.’s website.
The Group’s Anti-Bribery and Corruption Policy (hereinafter the “Policy”) is in compliance with the applicable national regulatory framework,
the EU best practices and the 10 principles of the UN Global Compact. The provisions of this Policy are supplementary to any applicable laws in
force. This Policy is complementary to the following Policies and Procedures of the Bank and the Group:
• Code of Conduct and Ethics
• Personnel Regulation
• Anti-money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy
• Policy on the Prevention of Conflict of Interests
• Policy on Related Parties Transactions
• Whistleblowing Policy and Procedures
The Group applies a zero-tolerance approach towards bribery and corruption. To this end, it is strictly forbidden to offer, promise or accept
benefits or other privileges in general, to any person, directly or indirectly through a third party, for the purpose of (i.e., in return for):
• coercion to act in breach of a lawful duty,
• coercion to abuse their position,
• obtaining an improper advantage, contract, or other privilege.
Zero tolerance towards bribery and corruption is demonstrated throughout the corporate conduct and training provided to all Employees,
irrespective of their hierarchical level.
The Group Employees, in addition to the above, are strictly prohibited from receiving any payment, inducement of any kind or service or
benefits of any nature that could compromise their professional judgment, taking action, in order to circumvent controls in place to prevent
bribery, accepting facilitating payments in order to prioritize a Customer’s request, providing, accepting or promising, directly or indirectly, any
benefit or advantage to/from a Public or Government Official, seeking to advance personal or Group interest.
Services, hospitality, entertainment, and other types of offers are considered as gifts and are not acceptable, according to the Policy.
Exceptionally, gifts of small value may be accepted, to the extent that they are offered within the context of social occasions and traditions.
Group Employees shall report any breaches or suspected breaches of the Policy that come to their attention to the Regulatory Compliance
Business Area by using the means provided in the Whistleblowing Policy and Procedures.
Also, all Employees notify the Regulatory Compliance Business Area for any gift offered to them, to obtain approval for their acceptance.
The Compliance Function monitors all gifts and, upon assessment, provides guidance to the recipient for the acceptance, decline or
appropriate disposal of the gift.
When selecting and subsequently collaborating with Third Parties (e.g. providers, consultants, suppliers, etc.), Alpha Bank takes all necessary
measures to ensure that any new business relationship is based on the principles of business ethics.
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The Group has established dedicated reporting channels such as a direct telephone line, dedicated e-mail, and postal address to which
breaches of Anti-Bribery and Anti-Corruption Policy provisions can be addressed, which refer to instances to address allegations or incidents
corruption and bribery. These channels operate exclusively for receiving reports and are available 24 hours a day, seven days a week for all
Personnel, Customers and Third Parties.
The Regulatory Compliance Business Area shall review all requests submitted during a calendar year and report the conclusions to the Board of
Directors through the Audit Committee.
Through continued developments in Alpha Bank’s business ethics practices such as those disclosed above, Alpha Bank has been u pgraded by
MSCI to AA from a previous A rating making Alpha Bank on par with its global peers.
Policy on the Prevention of Conflicts of Interests
The Policy on the Prevention of Conflict of Interests applies to the Group Companies in Greece and abroad, notwithstanding ad-hoc policies
applying to one or more Group companies as a result of additional requirements imposed by the relevant national regulatory framework.
In particular, the Policy aims to:
• Prevent cases of conflict of interests, which may prove detrimental to the interests of Customers or potential Customers when
providing banking and/or investment services.
• Enforce procedures to manage cases of conflict of interests, which may include organizational and administrative measures for
handling such cases and safeguarding Customers’ interests.
• Establish control mechanisms, which allow an overall assessment of the efficiency of the conflict of interests’ prevention fr amework
as well as of the Bank’s level of adherence to the respective framework.
The Policy applies to a clearly defined set of internal and external Stakeholders, including Bank Employees at all hierarchy levels, Members of
the Board and external service providers within outsourcing arrangements. It is made available to all covered Employees through internal
governance channels and forms part of the mandatory policy framework that Employees must comply with.
New Employees are also informed during onboarding and are required to submit disclosures related to external interests or affiliations. When
recruiting new Employees, Alpha Bank takes into account any existing business, financial and other interests in accordance with the provisions
of the Policy on the Prevention of Conflict of Interests
The Policy covers conflict of interests cases, either potential or confirmed. The Bank’s Employees may seek advice from the Compliance
Division, in terms of assessing a potential conflict of interests’ case, as well as providing instructions on the appropriate remediation measures.
The policy adheres to the requirements of the regulatory framework, as stipulated among others in the relevant Law on société s anonymes, on
Corporate Governance Law, MiFID II, the Executive Committee Act 243/7.7.2025 of the BoG, as well as the Group’s Code of Conduct.
The monitoring of the Policy is performed through the Internal Control System, which establishes:
• the organizational structure, segregation of duties, dual control, and controlled information access,
• risk management processes to identify and assess risks related to activities, processes and systems,
• the periodic evaluation of the adequacy and effectiveness of internal control mechanisms, and
• the independent roles of the Risk Management, Regulatory Compliance and Internal Audit Business Areas.
In addition, the Policy outlines the procedures followed by the Regulatory Compliance for evaluating and managing reported conflicts of
interest, including documentation, investigation steps, corrective measures, escalation to Senior Management or the Audit Committee, and
maintaining a Conflict of Interest Register to ensure continuous monitoring and proper implementation of the Policy.
Policy on Related Parties Transactions
The Policy covers a set of principles and internal procedures aimed at mitigating the “conflict of Interest” risk, in cases where the “personal or
private interests” of the “Related Parties” may be in conflict with the interests of the Bank. This Policy ap plies to the entire Group. For Banks
and Branches headquartered abroad, the stipulations of this Policy may be adjusted accordingly, in cases where the local regulatory and legal
provisions prevail over the requirements of this Policy. Such differences must be communicated to the Bank’s Regulatory Compliance Division.
Group Companies may respectively adjust the limits of the transactions under examination, based on their size and on the type of their
activities, after submitting a relevant proposal to the Bank’s Compliance Division and obtaining the necessary approvals. The Policy is under
review in order to incorporate the Executive Committee Act 243/7.7.2025 of the BoG.
The monitoring of the Policy is carried out by the Regulatory Compliance Business Area, which maintains the register of Related Parties,
reviews transactions classified under the Policy to ensure they meet regulatory requirements and performs continuous oversight through
system-based monitoring. Findings and all related-party transactions are reported semi-annually to the Audit Committee and the Board of
Directors, ensuring systematic supervision and escalation where needed.
The Policy is implemented in accordance with the external regulatory and supervisory framework explicitly referenced in it, including Law
4548/2018 on corporate governance and related parties, Law 4261/2014, Executive Committee Act 243/7.7.2025, the Group Code of Conduct
and Ethics, IFRS (including IAS 24 Related Party Disclosures) and EBA Guidelines on internal governance.
In defining the Policy, the Bank considers the interests of its key stakeholders. This is reflected in safeguards ensuring equal treatment of
shareholders, arm’s-length execution of transactions, and the prevention of preferential or abusive practices involving Related Parties, thereby
protecting the Bank’s financial integrity as well as the interests of minority shareholders and Customers.
The Regulatory Compliance monitors on an on-going basis the Related Parties transactions and apply appropriate control, in order to identify
any deviations in the application of the Policy, or any transactions which entail significant Conflict of Interest risk.
More specifically, the Business Area reviews Related Parties transactions which have been concluded in order to verify conformity to the
principles and the processes applied with those stipulated under the Policy. In case indications of non-conformity with the provisions
stipulated in the Policy arise, the corresponding transactions are communicated to the Audit Committee, including any remediation actions
considered necessary.
Business Areas, including the Regulatory Compliance, credit functions, and supervisory bodies such as the Audit Committee and the Board
receive the Policy and its updates through formal internal communication channels. In addition, individuals identified as Related Parties are
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154 | ANNUAL FINANCIAL REPORT
informed of their obligations through mandatory declarations and periodic updates, ensuring they understand the requirements necessary for
the implementation of the Policy.
Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT)
Money Laundering/ Terrorist Financing (AML/CFT) Risk is the potential for a financial institution to be exploited for money laundering or
terrorist financing purposes. It involves identifying, assessing, and managing the likelihood that the institution’s p roducts, services, Customers,
or operations could be exploited for illegal financial transactions. The key components in assessing AML Risk include Customer risk, geographic
risk, product risk and channel risk.
ML/TF Risk forms an integral part of the ABG’s broader Compliance Risk framework, and it requires robust systems to assess, d etect, report,
and mitigate risks, aligning with international standards and regulatory requirements.
The AML/CFT Business Area develops and implements the evaluation framework for managing money laundering (ML) and terrorist financing
(TF) risks within the Bank.
Key responsibilities include:
• AML/CFT Policy Development & Implementation
• Monitoring & Transaction Surveillance
• Suspicious Activity Reports
• Training & Awareness
• Collaboration & Reporting
Alpha Bank has no relevant targets related to the aforementioned policies, however there are several actions that the Group undertakes and
tracks the effectiveness of its policies.
Actions
In 2025, the Group has performed several actions related to the “Contribution to Transparency and the Rule of Law” Impact and the AML/CFT
Risk recognized within the Double Materiality Assessment. The AML/CFT actions in particular focused on the following priorities:
KYC / Customer Due Diligence Improvements
• Policies and Procedures adaptation to Meet Regulatory Requirements,
• launch of Specialized Campaigns for Customers with KYC Deficiencies,
• establish Control Checkpoints for Monitoring KYC Activities in the 1st Line of Defense (1LoD),
• continuously Update and Enhance AML Training Materials,
• strengthen Systemic Controls for Existing Customers Acquiring New Products.
The comprehensive KYC/CDD improvements are designed to streamline certification and verification processes, reduce risks, and ensure
compliance across all client categories. This approach will contribute to more efficient Customer onboarding, better data quality, and
enhanced risk mitigation, while aligning with regulatory requirements. In addition, the updates will continue by 2026.
Transaction Monitoring & Suspicious Transactions Reporting Management
• Prioritization of alerts based on risk profiles,
• enhancing the accuracy and timeliness of suspicious activity detection.
The expected outcome for these actions is faster detection of potential suspicious activities and more efficient STR filing.
IT Systems & Data Analytics Enhancements
• Integrated new high-risk factors and calibrated existing ones to improve the CRR methodology,
• optimization of Sanctions Screening Tool (Siron Embargo) by introducing dual-control functionality for transactions with specific risk-
based criteria,
• aligned AML platforms and core banking systems with the new SEPA Instant Payments Regulation.
Enhanced risk mitigation and full compliance with the new regulation, while ensuring smooth processing of instant payments is taking place on
ongoing basis.
Governance, Control, and Assurance:
Expansion of second-line monitoring through more frequent and detailed reviews of KRI metrics, alongside the introduction of monthly
performance reviews with accountable Business Areas.
Increased oversight and a clearer understanding of risk levels across the organization, leading to faster identification and mitigation of
potential issues are taking place on ongoing basis.
Updated AML BWRA Methodology
Implemented a refined methodology for evaluating the business-wide risk assessment (BWRA), including deeper integration of internal
controls and risk mitigation strategies. Enhanced risk-based decision-making and a clearer focus on areas that require the most attention for
risk mitigation are happening on ongoing basis.
GAP Analysis for New EU AML Regulatory Package:
Comprehensive GAP analysis of the new EU AML regulations to evaluate current practices and identify required updates. This comes in full
alignment with the new regulatory framework, ensuring that all business units meet the latest compliance standards.
The analysis and initial action plans are expected to be completed by Q2 2026.
Trainings
Business Conduct Trainings
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All new Employees are made explicitly aware of Alpha Bank’s key internal Policies upon joining and are required to review them as part of their
onboarding process. Physical trainings are delivered by the Compliance Function to all new hires, irrespective of hierarchical level, covering
Compliance Culture, the Code of Conduct and Ethics, the Whistleblowing Policy, Conflict of Interest management, and Anti-Bribery and
Corruption principles. These sessions enhance awareness of reporting channels for irregularities, omissions, offences, and Policy breaches.
Further to the above, all Bank and Subsidiaries Employees participate in mandatory E-Learning training programs relating to Anti-Money
Laundering/Combatting the Financing of Terrorism (AML/CFT), the Code of Conduct and Ethics, the Anti-Bribery and Corruption Policy and the
Whistleblowing Policy. These trainings are conducted on an annual basis. Through the e-learnings, Employees have access to digital material,
interactive content, and comprehension questions designed to reinforce understanding and ensure full assimilation of regulatory and internal
requirements. The successful completion of these mandatory trainings was incorporated into the KPIs designed for the Business Units
balanced scorecards. Although no standalone Training Policy exists, however, relevant provisions are included within existing Policy
documents.
Regarding Conflict of Interest, the Compliance Function performs regular training to enhance Employees’ awareness of all the risks that may
arise from potential Conflict of Interests situations, as well as to ensure comprehension of responsibilities attached to Employees. Physical
trainings are conducted for all new hires/on boardings to raise the awareness for conflict-of-interest cases and Policy breaches through the
dedicated reporting channels. Additional training (E- Learning) is being designed covering the Policy and will be addressed to all Bank and
Greek subsidiaries Employees.
In relation to AML/CFT, the Bank and the Group Companies provide training programs, including web training to its Employees, while a
specialized training is delivered to the AML/CFT-related Business Area, as well as of the Money Laundering Reporting Officer and their deputy.
The training programs that are provided to the Employees include:
• Briefing Officers on the legislation and their obligations arising from the applicable provisions and the procedures adopted by the
Bank or the Group company, including those relating to issues such as the identification and verification of the Customers’ identities,
keeping records and internal reporting.
• The appropriate adjustment of the implementation time, duration and content of training programs, depending on the category a nd
job of Personnel.
• The repetition, at regular intervals, of training programs in order to ensure the knowledge of Personnel regarding their duties and
obligations and their update on all new developments.
The AML/CFT Compliance Officer is responsible for the design and implementation of Anti-Money laundering and terrorist financing training of
Employees.
During 2025, 4,226 employees across Alpha Bank and Greek Subsidiaries successfully completed the mandatory 2-hour “AML awareness” E-
learning which was launched in December 2023. It shall be noted that the aforementioned training was reviewed and updated according to
the changes in the AML/CFT Regulation and will be assigned to all Bank and Greek Subsidiaries Employees in 2026.
Also, 248 Bank Employees attended the “AML, Control and Risk Management” training, a tailor-made program for Branch network.
The updated Code of Conduct and Ethics continues to embed comprehensive Group Policies, ethical expectations, a strong risk management
culture, and adherence to the regulatory framework. The related training program is mandatory for all Personnel, and the Board of Directors
participated in a presentation of the updated Policy. During 2025, the relevant training was attended by 5,616 Bank and Greek Subsidiaries
Employees. Additional information is available in section [S1-1] Policies related to own workforce.
Lastly, during June 2025, launched the “Whistleblowing Policy and Procedures” e-learning. As of 31.12.2025, 3,943 Bank and Subsidiaries
Employees completed the course.
Anti-Bribery and Corruption (ABC) Trainings
A key component of the implementation of the Anti-Bribery and Corruption framework is the delivery of dedicated training programs. These
include both e-learning modules and physical sessions led by the Compliance Function.
In 2025, the Bank developed and implemented the Anti-bribery and Corruption e-learning program, which is mandatory for all existing Bank
and Greek subsidiaries Employees across all organizational levels. Furthermore, every new hire, upon on boarding, is required to successfully
complete the e-learning as well as the comprehension questionnaire which is included. In order to reinforce the training framework, the
successful completion of this mandatory training was incorporated into the KPIs designed for the Business Units balanced scorecards.
Physical trainings are conducted for all new Employees to raise the awareness for the respective Policy, as well as the Code of Conduct and
Ethics.
Various topics were covered such as defining bribery and corruption, the provisions of Alpha Bank Group’s Policy and the obli gations arise for
Group Personnel, issues regarding gifts and hospitality, interaction with public officials, the use of Corporate Cards, channels for reporting
irregularities and breaches of the Policy as well as the Group’s corporate culture towards bribery and corruption.
In terms of overall scope during the reporting year, Employees participated in ABC-related trainings, including:
• 657 managers,
• 59 administrative, management and supervisory body members, and
• 3,856 other Employees.
Training delivery consisted of 1 hour of in-class instruction, across a total of 11 training sessions and approximately 7 hours (in total) of
computer-based learning. Topics addressed included definitions of corruption, policy requirements, and procedures for suspicion and
detection.
There are no significant methodologies and significant assumptions behind the above metrics related to training.
[G1-4] Incidents of corruption and bribery
In 2025 Alpha Bank’s mechanisms recorded an internal fraud incident which led to the dismissal of two (2) Employees. Alpha Ba nk has not
faced any convictions or fines for violation of anti-corruption and anti-bribery laws.
Appendix
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Table 66 ESRS 2 General - Index table
Disclosure Requirement and related datapoint
GENERAL INFORMATION
[BP-1] General basis for preparation of sustainability statements
[BP-2] Disclosures in relation to specific circumstances
[GOV-1] The role of the administrative, management and supervisory bodies
[GOV-2] Information provided to, and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies
[GOV-3] Integration of sustainability-related performance in incentive schemes
[GOV-4] Statement on due diligence
[GOV-5] Risk management and internal controls over sustainability reporting
[SBM-1] Strategy, business model and value chain
[SBM-2] Interests and views of stakeholders
[SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model
[IRO-1] Description of the process to identify and assess material impacts, risks and opportunities
[IRO-2] Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement
ENVIRONMENTAL INFORMATION
Disclosures pursuant to Article 8 of Regulation 2020/852 (“EU Taxonomy Regulation”)
ESRS E1 CLIMATE CHANGE
[E1-1] Transition plan for climate change mitigation
[E1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model
[E1-2] Policies related to climate change mitigation and adaptation
[E1-3] Actions and resources in relation to climate change policies
[E1-4] Targets related to climate change mitigation and adaptation
[E1-5] Energy consumption and mix
[E1-6] Gross Scopes 1, 2, 3 and Total GHG emissions
[E1-7] GHG removals and GHG mitigation projects financed through carbon credits- N/A
[E1-8] Internal carbon pricing- N/A
[E1-9] Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
ESRS E4 BIODIVERSITY AND ECOSYSTEMS
[E4.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model
[E4-1] Transition plan and consideration of biodiversity and ecosystems in strategy and business model
[E4-2] Policies related to biodiversity and ecosystems
[E4-3] Actions and resources related to biodiversity and ecosystems
[E4-4] Targets related to biodiversity and ecosystems
[E4-5] Impact metrics related to biodiversity and ecosystems change- N/A
[E4-6] Anticipated financial effects from biodiversity and ecosystem-related risks and opportunities
ESRS E5- RESOURCE USE AND CIRCULAR ECONOMY
[E5-1] Policies related to resource use and circular economy
[E5-2] Actions and resources related to resource use and circular economy
[E5-3] Targets related to resource use and circular economy
[E5-4] Resource inflows- N/A
[E5-5] Resource outflows- N/A
[E5-6] Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
ESRS S1 OWN OPERATIONS
[S1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model
[S1-1] Policies related to own workforce
[S1-2] Processes for engaging with own workforce and workers’ representatives about impacts
[S1-3] Processes to remediate negative impacts and channels for own workforce to raise concerns
[S1-4] Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own
workforce, and effectiveness of those actions
[S1-5] Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
[S1-6] Characteristics of Alpha Bank Group Employees
[S1-7] Characteristics of non-Employees in the undertaking’s own workforce- N/A
[S1-8] Collective bargaining coverage and social dialogue
[S1-9] Diversity metrics
[S1-10] Adequate wages- N/A
[S1-11] Social protection
[S1-12] Persons with disabilities- N/A
[S1-13] Training and skills development metrics
[S1-14] Health and safety metrics
[S1-15] Work-life balance metrics- N/A
[S1-16] Remuneration metrics (pay gap and total remuneration)- N/A
[S1-17] Incidents, complaints and severe human rights impacts
ESRS S4 CONSUMERS AND END USERS
[S4.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model
[S4-1] Policies related to Customers
[S4-2] Processes for engaging with consumers and end-users about impacts
[S4-3] Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
[S4-4] Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities
related to consumers and end-users, and effectiveness of those actions
[S4-5] Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Entity-Specific Information
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157 | ANNUAL FINANCIAL REPORT
Contribution to Healthy Economies
[G1-1] Business conduct policies and corporate culture
[G1-2] Management of relationships with suppliers- N/A
[G1-3] Prevention and detection of corruption and bribery
[G1-4] Incidents of corruption or bribery
[G1-5] Political influence and lobbying activities- N/A
[G1-6] Payment practices- N/A
List of Abbreviations
AML/CFT: Anti-Money Laundering and Combating the Financing of Terrorism
BoD: Board of Directors
C&E: Climate and Environment
CGSNC: The Corporate Governance, Sustainability and Nominations Committee
CSR: Corporate Social Responsibility
CSRD: Corporate Sustainability Reporting Directive
DE&I: Diversity, Equity and Inclusion
DMA: Double Materiality Assessment
EBA: European Banking Authority
ESRS: European Reporting Sustainability Standards
GRI: Global Reporting Initiative
IEA: International Energy Agency
NGO: Non-Governmental Organization
NZBA: Net Zero Banking Alliance
PCAF: Partnership for Carbon Accounting Financials
RAF: Risk Appetite Framework
RCSA: Risk and Control Self-Assessment
SASB: Sustainability Accounting Standards Board
SFF: Sustainable Finance Framework
TCFD: Task Force on Climate-related Financial Disclosures
UNEP FI: United Nations Environment Program Finance Initiative
N/A: Not Applicable
Athens, February 26, 2026
THE CHAIRMAN
OF THE BOARD OF DIRECTORS
THE CHIEF
EXECUTIVE OFFICER
DIMITRIOS C. TSITSIRAGOS
ID No A 00808440
VASSILIOS E. PSALTIS
ID No A 02206685
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
158 | ANNUAL FINANCIAL REPORT
Corporate Governance Statement
A. INTRODUCTION
Laws
Pursuant to article 152 par. 1 and article 153 par. 3 of Law 4548/2018, Law 4706/2020 and the Hellenic Corporate
Governance Code, the Board of Directors’ Annual Management Report of Alpha Bank S.A. (the “Bank” or “Alpha
Bank”) includes the Corporate Governance Statement for the year 2025. The reference date of the Corporate
Governance Statement is 31.12.2025.
Items c), d), f), h), i) of article 10 of Directive 2004/25/EC of the European Parliament and of the Council, as they are
incorporated in items c), d), e), g), h) of article 4 par. 7 of Law 3556/2007, are analyzed in the Explanatory Report of
the Board of Directors, which is included in the Board of Directors’ Annual Management Report.
B. CORPORATE GOVERNANCE CODE AND PRACTICES
B1.
The Bank, following a resolution of the Board of Directors adopted the Hellenic Corporate
Governance Code of the Hellenic Corporate Governance Council (the “Code”).
The Bank adheres to the Code which is posted on its website
(https://www.alpha.gr/en/Group/Corporate-Governance/Corporate-Governance-Code).
The Corporate Governance, Sustainability and Nominations Committee (the “CGSNC”) of
the Bank: i) monitors the compliance of our Bank and the Group with the Code, ensuring
the appropriate application of the “comply or explain” principle required, and ii) pr ovides
oversight that the implementation of this principle aligns with the legislation in force, the
regulatory expectations and the international corporate governance best practice.
Statement of Compliance with
the Corporate Governance
Code
B2.
The Bank fully complies with the Hellenic Corporate Governance Code, without any
exception.
Explanation on issues of non-
compliance with the Hellenic
Corporate Governance Code in
the context of the “comply or
explain” principle
B3.
During 2025, the Bank revised the Charters of the Committees of the Board of Directors, i.e.
the Audit Committee, the Risk Management Committee, the Remuneration Committee and
the Corporate Governance, Sustainability and Nominations Committee. Additionally, it has
updated the Internal Governance Regulation.
Policies related to corporate governance have been reviewed and updated to ensure full
alignment with the current regulatory framework and the most recent best practices of
corporate governance. These Policies include the Suitability and Nomination Policy for the
Members of the Board of Directors and Key Function Holders, the Suitability and
Nomination Process for the Members of the Board of Directors, the Policy for the
Succession Planning of Senior Executives and Key Function Holders, the Remuneration
Policy for Alpha Bank and the other Companies of the Banking Group, as well as its
Update of Corporate
Governance Documents
during 2025
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159 | ANNUAL FINANCIAL REPORT
Annexes, the Remuneration Policy of the Members of the Board of Directors, the Policy for
the Evaluation of Senior Executives and Key Function Holders and the Expenses Policy for
the Non-Executive Members of the Board of Directors.
B4.
Throughout 2025, the Board Committees of our Bank met with the Board Committees of
the Subsidiaries. This collaboration was pivotal as we reviewed the Annual and Semi-Annual
Activity Reports of the Subsidiaries’ Boards of Directors and Committees, ensuring that
their responsibilities were being fulfilled effectively.
In addition to these reviews, we also embarked on discussions about the Board structure
and practices on corporate governance.
Corporate Governance at
Group Level
B5.
Appointment of two new Members of the Board of Directors
The Board of Directors of the Bank, based on a respective recommendation by the
Corporate Governance, Sustainability and Nominations Committee, at its meeting held on
27.2.2025, following the resignations of Messrs. Spyros N. Filaretos and Efthimios O. Vidalis
with effect as of the abovementioned date, appointed: (i) the Deputy CEO, Mr. Lazaros A.
Papagaryfallou as Executive Member in replacement of the Executive Member, Mr. Spyros
N. Filaretos and (ii) Ms. Annalisa G. Areni as Non-Executive Member of the Board of
Directors of the Bank, in replacement of the Non-Executive Member, Mr. Efthimios O.
Vidalis. The tenure of the elected Members has been set from 27.2.2025 until the
expiration of the remainder of the tenure of the Members whom they replace.
Furthermore, the Self-Convened Extraordinary General Meeting of the Bank held on
12.6.2025 resolved on the appointment of Mr. J.-H.-F.G. Umbgrove as an Independent Non-
Executive Member of the Board of Directors.
Completion of the merger between Alpha Services and Holdings S.A. and Alpha Bank S.A.
Alpha Bank informed the investors on 27.6.2025 that the merger by absorption (hereinafter
the “Merger”) of “Alpha Services and Holdings S.A.” (hereinafter the “Company”) by Alpha
Bnak pursuant to the applicable legislation, including, without limitation, the provisions of
articles 6-21 and 140 of Law 4601/2019, the provisions of article 16 of Law 2515/1997 and
the applicable provisions of Law 4548/2018, as in force, has been completed, as approved
pursuant to the resolution of the Self-Convened Extraordinary General Meeting of the
Bank’s Shareholder dated 12.6.2025 and the Extraordinary General Meeting of the
Shareholders of the Company dated 23.6.2025.
As a result, Alpha Bank was substituted ipso jure in its capacity as a universal successor, in
all assets and liabilities of the Company, while the latter was dissolved without liquidation
and ceased to exist, whereas its shares have been delisted from the Athens Stock Exchange
(hereinafter “ATHEX”). Alpha Bank’s shares issued in the context of the Merger were
admitted to trading to the Main Market of the regulated market of the ATHEX and the
Shareholders of the Company became Shareholders of Alpha Bank with the same number
of shares they held prior to the Merger.
For more information regarding the completion of the Merger and the commencement of
trading of the Bank’s shares please refer to the announcement on the website
https://www.alpha.gr/-/media/AlphaGr/Files/Group/Corporate-
Announcements/2025/20250627-etairiki-anakoinosi-en.pdf.
2025 Highlights
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UniCredit increases its stake in Alpha Bank S.A.
Following the relevant announcements of Alpha Bank dated 1.7.2025,
29.8.2025,30.10.2025 and 13.11.2025, in accordance with the provisions of Law 3556/2007,
Alpha Bank informed the investors on 9.1.2026 that, according to a notification received on
9.1.2026 from UniCredit S.p.A. , and in accordance with article 11 par.1 (b) of Law
3556/2007, on 5.1.2026, UniCredit exercised financial instruments, resulting in an increase
of its direct shareholding in Alpha Bank to 689,860,498 common registered shares with
voting rights, representing 29.796% of the total voting rights of Alpha Bank. (For more
information please refer to the announcement on the website https://www.alpha.gr/-
/media/AlphaGr/Files/Group/Corporate-Announcements/2026/20260109-etairiki-
anakoinosi-en.pdf.
Completion of the acquisition of FlexFin Ltd
Further to its Announcement of 28.1.2025, Alpha Bank announced on 5.8.2025 that its fully
controlled subsidiary Alpha Holding S.A. completed the acquisition of 100% stake in FlexFin
Ltd, 100% parent company of FlexFin S.M.S.A.
It was also announced that Alpha Bank intend ed to merge its Greek factoring operations
undertaken by ABC FACTORS and Flexfin, both fully controlled subsidiaries of Alpha
Holding, under one corporate entity, subject to obtaining all necessary regulatory approvals
and consents.
Alpha Bank S.A. announced the completion of the acquisition of AXIA Ventures Group Ltd
Alpha Bank together with its wholly owned subsidiary Alpha Finance Investment Services
S.M.S.A. (“Alpha Finance”), announced on 16.12.2025 the successful completion of the
acquisition of 100% of the issued share capital of AXIA Ventures Group Ltd (“AXIA”),
following the satisfaction of all customary conditions, including the receipt of the applicable
regulatory approvals.
Following the completion of the transaction, AXIA will be combined with Alpha Finance and
Alpha Bank’s Investment Banking unit, forming a leading Investment Banking and
Capital Markets platform in the region. AXIA’s senior management assumes long-term
leadership roles within the combined platform and the Group, ensuring continuity and
strong strategic alignment. The transaction is fully aligned with Alpha Bank’s strategy to
expand fee-generating activities, enhance its investment banking and capital markets
capabilities, and
further strengthen its offering to corporate and institutional Customers.
Acquisition of AstroBank’s assets and liabilities
Alpha Bank announced on 3.11.2025 that its indirect wholly-owned subsidiary Alpha Bank
Cyprus Ltd, along with other entities of the Group of Alpha Bank, completed the acquisition
of substantially all of AstroBank’s assets and liabilities as well as of its Personnel.
B6.
As we look ahead to 2026, some of the key Corporate Governance priorities that we will be
focusing on are shared below. These priorities will guide our efforts to enhance our
governance practices and ensure that we remain aligned with the latest regulatory
developments.
2026 Priorities
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First and foremost, during 2026 the election of
Bank’s Board of Directors will take place, given that
its tenure is quadrennial, in accordance with article
9 of the Bank’s Articles of Incorporation, as set by
the resolution of the Extraordinary General
Meeting of the Bank held on 22.7.2022, and may be
extended until the termination of the deadline for
the convocation of the next Ordinary General
Meeting and until the adoption of the relevant
resolution.
Furthermore, we will be working to further
enhance the diversification within our Board of Directors and the Management team.
We will also be reviewing our Bank’s Corporate Governance documents to ensure they
reflect the latest regulatory changes and developments. This will help us maintain
compliance and stay ahead of any potential challenges.
Another important priority is to provide further specialized training to the Members of the
Board of Directors. This ensures that they remain equipped with the necessary skills and
knowledge to make informed decisions and lead our Bank effectively.
We will be closely monitoring the adoption of corporate governance practices by our
Subsidiaries to ensure consistency and alignment across the Bank.
Additionally, we are committed to transparency regarding our overall strategy, board
composition and effectiveness, remuneration practices and sustainability initiatives. We
will continue placing emphasis on board Members and executive succession planning and
continue to monitor the implementation of the Succession Policy. This will ensure that we
have a robust plan in place for leadership continuity.
We will continue to strengthen our Remuneration Framework with the objective of
attracting and retaining top executive talent, while ensuring that our remuneration
practices are consistent with our performance objectives and aligned with international
best practices.
Furthermore, we remain committed to engaging proactively with our Shareholders and
Investors through targeted roadshows. These sessions will focus on critical areas such as
Strategic Overview, Corporate Governance (including Board Structure, Board Effectiveness
and Remuneration) and Sustainability. Our goal is to incorporate stakeholder feedback into
our practices and to ensure that our standards meet or exceed their expectations.
C. INTERNAL CONTROL SYSTEM (ICS)
The Internal Control System comprises all mechanisms and procedures relating to all the activities of the Bank at an individual
and a Group level and is designed to ensure among others:
−
the consistent implementation of the business strategy with effective utilization of the available resources,
−
the identification and management of all risks undertaken to achieve business objectives,
−
the completeness and the reliability of the data and information required for the accurate and timely determination
of the financial situation of the Bank and the generation of reliable Financial Statements,
−
the compliance with the current regulatory framework, the internal regulations, the rules of ethics,
−
the prevention and avoidance of erroneous actions that could jeopardize the reputation and interests of the Bank,
the Shareholders and those transacting with it,
−
the effective operation of the IT systems in order to support the business strategy and the secure circulation,
processing and storage of critical business information.
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The Internal Control System is structured along the Three Lines of Defense Model: the business and operational or support
Units (first line), the risk management and compliance Units (second line) and the Internal Audit Unit (third line).
The Audit Committee is responsible for the monitoring of financial reporting processes, the effective operation of the internal
control and risk management systems as well as for the supervision and monitoring of the performance and independence of
the Statutory Certified Auditors.
The Audit Committee cooperates with the Risk Management Committee regarding the oversight of certain key areas of risk
and capital management and their repercussions on the Internal Control System.
The evaluation of the adequacy and effectiveness of the Internal Control System of the Bank is conducted:
a.
On a continuous basis through the review of audits conducted by the Internal Audit Unit at Group level, following a
risk-based audit plan, and the activities performed by the Compliance Unit as well as the Risk Management Unit.
b.
Regularly by the Audit Committee, on the basis of the relevant data and information received through the year from
the Internal Audit Unit, the Compliance Unit and the Management as well as on the basis of the findings and
observations from the External Auditors and the Regulatory Authorities.
c.
Periodically by external auditors, other than the Statutory Certified Auditor, who are highly experienced in the field
of internal control and are independent of the Group.
With regard to the financial reporting and accounting processes in particular, the Bank has in place policies and procedures
established in accordance with the current legislation and the accounting standards in force, as defined in the International
Financial Reporting Standards (IFRS), that have been adopted by the European Union, pursuant to Regulation (EC) No
1606/2002 of the European Parliament and of the Council of 19 July 2002. The primary procedures followed by the Bank in
order to ensure control effectiveness and to prevent errors and fraud include the segregation of duties and the four-eyes
principle, based on shared responsibilities for key processes to more than one person or Units and on the approval of certain
activities by at least two people.
The accounting system of the Bank and the Group is supported by appropriate IT systems which have been adapted to the
business requirements of the Bank and the requirements of the accounting standards.
Accounting and control procedures have been established in order to ensure the completeness, correctness and accuracy of
the entries in the accounting books as well as the completeness and validity of the Financial Statements.
C1.
The purpose of the Internal Audit Unit is to strengthen Alpha Bank’s ability to create,
protect, and sustain value by providing the Board of Directors and Management with
independent, risk-based and objective assurance, advice, insight and foresight.
The Internal Audit Unit enhances Alpha Bank’s:
• Successful achievement of its objectives.
• Governance, risk management and control processes.
• Decision-making and oversight.
• Reputation and credibility with its stakeholders.
• Ability to serve the public interest.
Alpha Bank’s Internal Audit Unit is most effective when:
• Internal auditing is performed by competent professionals in conformance with
the Institute of Internal Auditors (IIA)’s Global Internal Audit Standards
TM
(the
“Standards”) which are set in the public interest.
• The Internal Audit Unit is independent with direct accountability to the Board of
Directors.
Internal Audit Unit
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• Internal auditors are free from undue influence and committed to making
objective assessments.
The Internal Audit Unit adheres to the Standards of the IIA’s International Professional
Practices Framework (IPPF) and considers the Topical Requirements in conjunction with
the relevant regulatory framework, as required. The Chief of Internal Audit reports
periodically to the Board of Directors and to the Senior Management regarding the
Internal Audit Unit’s conformance with the Standards, as assessed through a quality
assurance and improvement program. Furthermore, it applies the relevant regulatory
framework, including the Executive Committee Act 243/07.07.2025 of the Bank of Greece,
which incorporates the EBA guidelines on internal governance under Directive
2013/36/EU section 22 on the Internal Audit Unit, as well the relevant internal Policies,
Processes and Charters.
The Chief of Internal Audit is appointed by the Board of Directors following a proposal by
the Audit Committee and reports functionally to the Board of Directors, through the Audit
Committee. For solely administrative purposes the Chief of Internal Audit reports to the
Chief Executive Officer. The Chief of Internal Audit is in charge of managing the
independent Internal Audit Unit. The performance of the Chief of Internal Audit is reviewed
and evaluated by the Board of Directors through the Audit Committee. The Audit
Committee may consult with the CEO and others on this purpose.
The Chief of Internal Audit has unrestricted access to the Board of Directors and the Audit
Committee and communicates and interacts directly with them, including in private
meetings without Executives of the Management, when necessary. This should not
prevent the Chief of Internal Audit from reporting within the regular reporting lines as
well. Whenever required, the Chief of Internal Audit shall have unrestricted access to and
may report directly to the Non-Executive Members of the Board of Directors, in order to
express any concerns and to alert them when the Bank is or may be affected by any
developments.
The Board of Directors authorizes and the Audit Committee supports the Internal Audit
Unit to:
− Have unfettered institution-wide, full, free and unrestricted access to all functions,
records, documents, information, buildings, property and Personnel of the Group
pertinent to carrying out any engagement, subject to accountability for
confidentiality and safeguarding of records and information. This should include
access to the Management Information Systems and the Minutes of the meetings
of all Committees and decision-making bodies.
− Have sufficient resources and ensure that the qualification of the Internal Audit
Unit’s staff members and resources, in particular its auditing tools and risk analysis
methods, are adequate for the Group’s size and locations, as well as for the
nature, scale and complexity of the risks associated with its business model,
activities, risk culture and risk appetite.
The Internal Auditors maintain an unbiased attitude that allows them to perform
engagements objectively and in such a manner that they believe that no quality
compromises are made in their work product and that they do not subordinate their
judgment on audit matters to others. The Internal Auditors are independent of the auditees
and the Management and must be objective during the execution of their work. They have
no operational responsibility for or authority over any of the activities audited.
Furthermore, they are not related to the activities they are assigned to audit from an
organizational perspective. The Chief of Internal Audit confirms to the Board of Directors
and to the Audit Committee, at least annually, the organizational independence of the
Internal Audit Unit.
The scope of Internal Audit activities encompasses, but is not limited to, objective
examinations of evidence for the purpose of providing independent assessments to the
Audit Committee and to the Board of Directors on the adequacy and effectiveness of
governance, risk management and control processes for the Bank.
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The Chief of Internal Audit has among others the responsibility to:
− Submit, at least annually, a risk-based Internal Audit Plan on the basis of the
annual risk assessment process for approval to the Board of Directors following
the endorsement thereof by the Audit Committee.
− Ensure the completeness of the Audit Universe at Group level.
− Coordinate accordingly with the Heads of Internal Audit of significant subsidiaries
in order to ensure appropriate and complete communication with the Audit
Committee regarding the Internal Audit Plan, Internal Audit activity and results
and the implementation of the Internal Audit Charter at Group level.
− Review and adjust the Internal Audit Plan, as necessary, in response to changes in
the Bank internal and external business risks, operations, programs, projects,
systems and controls.
− Communicate to the Board of Directors and to the Audit Committee any significant
changes to the Internal Audit Plan for approval.
− Ensure the execution of the Internal Audit Plan, including the establishment of
objectives and scope, the assignment of appropriate and adequately supervised
resources, the documentation of work programs and testing results and the
communication of engagement results and recommendations to the appropriate
stakeholders.
− Inform, in writing at least quarterly, the Board of Directors, through the Audit
Committee, and the General Management about the significant audit findings and
recommendations, the progress on their implementation and the extent to which
the Internal Control System meets its objectives.
− Follow up the engagement findings and the corrective actions and submit regularly
to the Board of Directors and to the Audit Committee written reports on major
identified deficiencies as well as any corrective actions not effectively
implemented.
− Ensure that the Internal Audit Unit applies and upholds the principles of integrity,
objectivity, competency, due professional care and confidentiality and reports
conformance with the Standards periodically to the Board of Directors and the
Audit Committee.
− Ensure that the Internal Audit Unit collectively possesses or obtains the
knowledge, skills and other competencies needed to meet the requirements set by
the Internal Audit Charter.
− Communicate to the Board of Directors and to the Audit Committee the impact of
resource limitations, if any, on the Internal Audit Plan.
− Ensure that emerging trends and successful practices in internal auditing are
considered.
− Establish and ensure adherence to policies and procedures designed to guide the
Internal Audit Unit.
− Ensure adherence to the Bank’s relevant policies and procedures, unless such
policies and procedures conflict with the Internal Audit Charter. Any such conflicts
will be resolved or otherwise communicated to the Board of Directors and the
Audit Committee.
− Ensure conformance of the Internal Audit Unit with the Standards, with the
following qualifications:
a. If the Internal Audit Unit is prohibited by law or regulation from conformance
with certain parts of the Standards, the Chief of Internal Audit will ensure
appropriate disclosures and conformance with all other parts of the
Standards.
b. If the Standards are used in conjunction with requirements issued by other
Supervisory Authorities, the Chief of Internal Audit will ensure that the
Internal Audit Unit conforms with the Standards, even if it also conforms with
the more restrictive requirements set by other Supervisory Authorities and
local laws and regulations.
− Report periodically and be directly accountable to the Board of Directors and the
Audit Committe as to the evaluation of the overall effectiveness and efficiency of
the Bank’s and the Group’s Internal Control System.
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− Confirm to the Board of Directors and the Audit Committee, at least annually, the
organizational independence of the Internal Audit Unit.
− Disclose to the Board of Directors and the Audit Committee any interference and
any possible implications in determining the scope of internal auditing, performing
work, and/or communicating results.
The CV of the Chief of Internal Audit is available on the Bank’s website
(https://www.alpha.gr/en/Group/advocating-sound-governance-
practices/management/management).
The Internal Audit Unit among others:
− Verifies the integrity of the processes ensuring the reliability of the Bank’s methods and
techniques, and the assumptions and sources of information used in its internal models
(e.g. risk modelling and accounting measurements). It also evaluates the quality and
use of qualitative risk identification and assessment tools and the risk mitigation
measures taken.
− Examines, audits and assesses:
a. the adequacy and integrity of financial and other information, risk management,
regulatory compliance and the Articles of Incorporation in force; the implementation of
the internal regulation and the system of internal controls, in particular as regards the
adequacy and integrity of the financial and non-financial information provided, risk
management, regulatory compliance and the corporate governance code adopted by
the Bank;
b. the quality assurance mechanisms;
c. the corporate governance mechanisms and
d. the use of capital raised through public offerings in accordance with information
released to the public and business plans.
− Ensures that sufficient procedures are in place so that the reports from the audit
engagements are appropriately disseminated.
− Ensures that it complies with sound internal auditing standards and with the Code of
Conduct and Ethics.
− Upon decision or instruction from any competent authority, carries out specific audits
in cases where there are indications that the interests of the Bank or its Subsidiaries are
compromised.
− Assesses:
• the appropriateness of the Bank’s governance framework;
• whether existing policies and procedures remain adequate and comply with the
legal and regulatory requirements and with the risk strategy and the risk appetite
of the Bank;
• the compliance of the procedures with the applicable laws and regulations and
with the resolutions of the Board of Directors;
• whether the procedures are correctly and effectively implemented (e.g.
compliance of transactions, the level of risk effectively incurred, etc.); and
• the adequacy, the quality and the effectiveness of the controls performed and the
reporting by the first and second line functions.
C2.
The Compliance Unit is responsible for the monitoring of the Compliance Risk at the level of
the Bank and the Group, as per the duties and responsibilities included in its Charter.
Being part of the Second Line of Defense, the Compliance Unit is responsible for identifying
and assessing compliance risk and for informing the competent bodies accordingly as well
as for proposing appropriate measures to address the identified weaknesses and for
monitoring their implementation.
Compliance Risk is the risk that affects the business model, the reputation and the financial
status of the Bank, due to the failure to comply with the regulatory framework applicable
to the Bank, the regulatory Acts issued by the Authorities, the Code of Conduct and Ethics
as well as the internal policies and procedures.
Compliance Unit
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In terms of governance, the Compliance Unit shall be administratively independent of the
business lines and the internal units it controls. The Chief of Compliance, while reporting
administratively to the Chief of Corporate Center and General Counsel, shall report
functionally to the Audit Committee, which shall refer accordingly to the Board of Directors.
Furthermore, the Audit Committee is responsible for the evaluation of the performance of
the Chief of Compliance. The Committee discusses the performance of the Chief of
Compliance and the relevant objectives as well as reviews, amends, if required, and
approves the Evaluation Scorecard and goals of the Chief of Compliance, in accordance with
the provisions of the Bank’s “Policy for the Evaluation of Senio r Executives and Key
Function Holders”. The Compliance Unit constitutes an independent function and is
empowered with unrestricted access to data and information necessary to carry out its
mission. The Management ensures the availability of the required resources which enable
the Compliance Unit to perform its duties.
The Compliance Unit is subject to audits or reviews carried out by the competent
authorities and supervisors [Single Supervisory Mechanism (SSM), Bank of Greece, Hellenic
Capital Market Commission] and by the Internal Audit Unit.
The Compliance Unit is responsible for:
• Representing the Bank to Supervisory and other Authorities regarding compliance
matters;
• Ensuring the timely and complete management of the relevant compliance risks,
by following a systematic methodology and by proposing mitigating actions in
cases of discrepancies. To this end, the Unit uses appropriate methodologies and
risk indicators, in order to measure the Compliance residual risk and to frame the
Compliance Risk Appetite;
• Reporting to the Management regarding the status of the compliance risk of the
Bank and proposing actions for enhancing adherence of the Bank and the Group to
the regulatory framework;
• Establishing and implementing appropriate and up-to-date policies and
procedures, with a view to achieving the Bank’s compliance with the applicable
regulatory framework;
• Assessing the complexity and nature of the Bank's activities, including the
development and promotion of new products and business practices, when
introducing relevant policies and procedures;
• Overseeing the Compliance Units of the main Subsidiaries, through the monitoring
of the implementation of the Annual Objectives and Action Plans and ensuring the
adoption of the Group Compliance Policies, thus facilitating a harmonized
compliance approach among them.
• Ensuring the continuous training of the Employees, through compliance-oriented
training programs.
The Compliance Unit drafts the Annual Compliance Program which is reviewed by the Audit
Committee for endorsement and is subsequently submitted for approval to the Board of
Directors.
It cooperates, inter alia, with the Internal Audit, the Legal, the Risk Management Units and
other Business Areas, when appropriate, to deal with compliance matters under a common
approach.
The Chief of Compliance is the Group Compliance Officer and is responsible for:
− assessing the Bank’s level of compliance with the requirements of the legal and
regulatory framework and with the internal policies and procedures;
− supervising the employees who perform tasks involving Compliance matters and
ensuring their adequate training and updated information on relevant
developments;
− continuously monitoring trends, best practices, laws and regulations on
Compliance matters;
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− supervising the Subsidiaries’ Compliance units;
− reporting to the Board of Directors through the Audit Committee and informing
the competent authorities on Compliance matters;
− ensuring the proper organization and operation of the Compliance as well as the
organization and coordination of the Compliance Units and the Compliance
Officers of the Subsidiaries, providing respective guidelines.
C3.
The Bank is committed to achieving a strong control environment and a distinctive risk
management capability in order to meet its performance objectives and to achieve
continuous improvement in the area of risk management.
The Risk Management Unit is independent from any executive activities and Units.
All Risk Management Policies and Frameworks are approved by the competent Committees
and are based on the following guiding principles.
• risk-appetite driven;
• an integral part of the business strategy and the decision-making;
• responsibility driven;
• transparent through clear communication lines;
• documented appropriately, ensuring that all risk identification, assessment,
monitoring, reporting, control/mitigation, activities and systems perform as
required;
• structured appropriately, ensuring that adequate information and reporting
mechanisms are provided to all levels of the Management.
The Risk Management Framework, Policies and Procedures are reviewed annually. The Risk
Management Framework is based on an extensive set of risk policies. The main objective of
the Risk Management Framework in place is to ensure that the outcomes of risk-taking
activities are consistent with the Grou p’s strategy and risk appetite and that there is an
appropriate balance between risk and reward in order to maximize shareholder returns.
The Risk Appetite Framework, which constitutes a major component of the Risk and Capital
Strategy, allows the Bank to combine the corporate and business strategy with the financial
and capital planning.
The risk analysis is integrated into the Bank’s annual strategic planning process, and the
strategic plan goals are reviewed on the basis of the risk policy.
Risk management is spread across three different levels, in order to create a Three Lines of
Defense Model. The duties and responsibilities of all lines are clearly defined and separated
and the relevant roles are sufficiently independent. The Risk Management Unit is
responsible for both supporting – this entails guiding in identifying, analyzing and
monitoring risks associated with the tasks they undertake – as well as challenging the
Business Functional Areas in 1
st
Line of Defense in implementing internal controls and
processes.
Τhe Chief Risk Officer reports to the Risk Management Committee and, through the latter,
to the Board of Directors. Moreover, he has overall responsibility for all the risk issues
outlined in the relevant risk policies and, additionally, supervises and coordinates the risk
management activities of the Bank.
The main responsibilities of the Chief Risk Officer are as follows:
Risk Management Unit
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• Ensures that appropriate risk management policies are in place and in line with the
Group’s risk management strategy, risk appetite and business objectives and oversees
the risk policies implementation;
• Ensures that there are appropriate risk management tools and methods in place,
including the models for risk identification, assessment, monitoring, controlling,
reporting and stress testing;
• Ensures that the Bank adequately embeds all risk types in the risk appetite statement
and framework, business strategy and risk management framework;
• Ensures compliance with all internal and regulatory risk limits as well as that any
deviations from the risk appetite are timely communicated to the Risk Management
Committee;
• Ensures that the Bank holds adequate economic and regulatory capital;
• Participates in the evaluation of the Bank’s economic and regulatory capital by the
regulatory authorities;
• Monitors the troubled assets portfolio and recommends impairment levels;
• Provides the Risk Management Committee, on a regular basis, with adequate reporting
in order to enable it to properly advise the Board of Directors on the Group’s exposure,
profile and strategy;
• Submits to the Board of Directors annually, through the Risk Management Committee,
reports in relation to the Bank’s risk management activities across risk types.
The Bank has fully complied with the provisions of the institutional framework with respect
to its troubled assets..
The Audit Committee and the Risk Management Committee, convening in joint sessions,
oversee certain key areas of risk and capital management and their repercussions on the
Internal Control System and review issues relevant to the remediation plans related to
supervisory assessments, operational risk and other issues of importance and common
interest.
C4.
The Bank has established and implements policies and processes that ensure that the
Board of Directors has sufficient information to base its decisions on transactions with
related parties, including transactions of its Subsidiaries with related parties.
In particular, the Bank has adopted the “Policy on Related Parties Transactions” which
describes the method with which the Bank handles issues regarding transactions with
Related Parties, in order to identify, evaluate, approve and properly disclose the
transactions it performs with the Related Parties taking into consideration the applicable
legal and regulatory framework, including articles 99-101 of Law 4548/2018.
All set processes and procedures aim to ensure that the Related Parties transactions
conform with the relevant principles.
Related Parties Transactions
C5.
The Bank has endorsed the Policy and Procedure for the External Periodical Assessment of
the Internal Control System, according to the respective legal and regulatory framework
(Law 4706/2020, article 14).
The abovementioned Policy aims at setting the standards for the assessment perimeter,
the external auditor assessment procedure, the characteristics required from the auditors,
the audits’ periodicity, the assessment report contents and recipients. The Aud it
Committee is responsible for monitoring the Internal Control System Policy and
Procedures.
The Internal Control System assessment is carried out every three years by independent
external auditors and, upon the conclusion of the assessment, a Report is prepared, where
the auditors’ findings are outlined along with their analysis and conclusions. Grant
Thornton is currently conducting an assessment covering the period 2023-2025.
Periodical Assessment of the
Internal Control System
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D. SHAREHOLDERS
D1.
The General Meeting of Shareholders (the “General Meeting”) is the supreme governing body of our Bank
and it plays a crucial role in resolving all corporate affairs in accordance with the applicable legislation. It is
essential to note that the resolutions passed during the General Meeting, when in accordance with the law,
are binding upon all Shareholders, including those who are absent or dissenting.
The General Meeting is convened by the Board of Directors or as otherwise stipulated by the applicable
legislation. The meeting takes place at the Bank’s registered office or in the district of another municipality
within the prefecture of the registered office or in a contiguous municipality to the registered office.
Alternatively, it may be held at the registered office of the Athens Exchange, where the Bank’s shares are
listed for trading. Furthermore, following a resolution by the Board of Directors and in compliance with the
applicable legislation, the General Meeting may also be conducted via teleconference. This decision ensures
that all Shareholders have the opportunity to participate in the meeting, regardless of their physical location.
The General Meeting is held at least once during the fiscal year, no later than the tenth calendar day of the
ninth month following the end of the fiscal year (Ordinary General Meeting). Additionally, meetings may be
convened on an ad hoc basis as necessary.
The General Meeting is initially presided over by the Chair of the Board of Directors. During this provisional
period, the Chair appoints provisional secretaries and ballot collectors. This arrangement continues until the
list of Shareholders with the right to participate in the General Meeting is ratified. Following this, the regular
Presidium, including the permanent Chair, secretaries and ballot collectors, is elected by the General
Meeting.
It is noted that only those who hold Shareholder status on the record date, as defined by the legislative
framework, are entitled to participate in the General Meeting. It is crucial for Shareholders to timely and
properly comply with the provisions of the law and the relevant invitation to the General Meeting. Should
there be any deviations from these guidelines, participation in the General Meeting is only permitted upon
receiving approval from the General Meeting itself.
Shareholders are welcome to attend the General Meeting either in person or by proxy. In the case of minors,
individuals under judicial guardianship and legal entities, representation must be in accordance with the
applicable legislation. The appointment, revocation or replacement of representatives should be done in
writing, through either a private or a public document. Additionally, upon resolution by the Board of
Directors, this can also be accomplished via electronic mail or other electronic means of communication, as
detailed in the Invitation to the General Meeting.
Moreover, upon a resolution by the Board of Directors, it may be resolved that Shareholders may participate
in the General Meeting through a Mail Vote, which can be submitted either by mail or electronically prior to
the meeting. This process is conducted in accordance with the relevant legislation and the instructions
provided in the Invitation.
It is important to note that the Members of the Board of Directors and the auditors of the Bank are allowed
to attend the General Meeting. Additionally, other individuals who do not possess shareholder capacity may
also be allowed to attend, upon permission of the Chair of the General Meeting.
During 2025, three General Meetings of Shareholders were held.
Extraordinary General Shareholder Meeting on 30.4.2025
The sole item of the agenda is presented below:
General
Meeting of
Shareholders
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ITEM
AGENDA
Sole
item
Admission to listing of all common, registered shares of the Bank on the Regulated Market (Main
Market) of the Athens Exchange.
The sole item of the agenda w as approved by the Extraordinary General Shareholder Meeting.
Ordinary General Shareholder Meeting on 21.5.2025
The items of the agenda are presented below:
ITEM
AGENDA
1
Approval of the Annual Separate and Consolidated Financial Statements of the financial year 2024
(1.1.2024 - 31.12.2024), together with the relevant reports of the Board of Directors which are
accompanied by the Statutory Certified Auditors’ Report.
2
Approval of the distribution of Net Profits for the financial year 2024 (1.1.2024 - 31.12.2024)
through dividend distribution of an amount of Euro 70,259,328.43 in cash. Granting of
authorization to the Board of Directors.
3
Approval of the distribution of an amount of Euro 13,402,212 from the Bank’s Net Profits for the
financial year 2024 (1.1.2024 - 31.12.2024) to the Bank’s Staff. Granting of authorization to the
Board of Directors.
4
Approval of the overall management for the financial year 2024 (1.1.2024 - 31.12.2024) as per
article 108 of law 4548/2018 and discharge of the Statutory Certified Auditors for the financial year
2024, in accordance with article 117(1)(c) of law 4548/2018.
5
Appointment of Statutory Certified Auditors for the statutory audit of the Financial Statements and
the assurance of sustainability reporting for the financial year 2025 (1.1.2025 - 31.12.2025) and
approval of their fee.
6
Submission of the Activity Report of the Audit Committee for the year 2024, in accordance with
article 44 of law 4449/2017 (non-voting item).
7
Announcement on the election by the Board of Directors of two (2) new Members of the Board of
Directors in replacement of the Members who have tendered their resignation (non-voting item).
8
Approval of the Members of the Board of Directors’ remuneration for the financial year 2024
(1.1.2024 - 31.12.2024).
9
Approval, in accordance with article 109 of law 4548/2018, of the advance payment of
remuneration to the Members of the Board of Directors for the financial year 2025 (1.1.2025 -
31.12.2025).
10
Approval, in accordance with article 86 of law 4261/2014, of an increase of the maximum ratio
between the fixed and variable components of remuneration.
11
Amendments to articles 8, 10, 11, 17, 18 and 22, deletion of articles 27 to 30 of the Articles of
Incorporation and codification thereof.
12
Approval of the Remuneration Policy of the Members of the Board of Directors in accordance with
articles 110 and 111 of law 4548/2018.
13
Approval of the Suitability and Nomination Policy for the Members of the Board of Directors and
Key Function Holders.
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14
Endorsement and continuation of the Stock Option Plan, as established and implemented by Alpha
Services and Holdings S.A. under article 113 of Law 4548/2018, and granting of authorization to
the Board of Directors in relation to the Plan.
15
Announcement to the Ordinary General Meeting of the Bank, according to article 97 par. 1(b) of
law 4548/2018, of any cases of conflict of interest and agreements of the financial year 2024 which
fall under article 99 of law 4548/2018 (non-voting item).
16
Granting of authority, in accordance with article 98 par. 1 of law 4548/2018, to the Members of
the Board of Directors and the General Management as well as to Directors of the Bank to
participate in the boards of directors or in the management of companies having purposes similar
to those of the Bank.
All the items of the agenda were approved by the Ordinary General Shareholder Meeting.
Extraordinary General Meeting of Shareholders on 12.6.2025
ITEM
AGENDA
1
Approval of (a) the merger by absorption of the société anonyme under the corporate name
“ALPHA SERVICES AND HOLDINGS S.A.” by the Bank, in accordance with article 16 of law
2515/1997 and articles 7 to 21 and 140 of law 4601/2019, as currently in force; (b) the Draft
Merger Agreement; and (c) the Merger Documentation. Share capital increase and decrease by
reason of the Merger.
2
Amendment of article 5 of the Articles of Incorporation of the Bank and
codification thereof. Granting of authorizations.
3
Establishment of a Share Buyback Program, in accordance with article 49
of law 4548/2018, and granting of authorization to the Board of Directors
for its implementation.
4
Establishment of a Stock Award Plan, in accordance with article 114 of law 4548/2018, and granting
of authorization to the Board of Directors for
its implementation.
5
Decision on the appointment of an Independent Non-Executive Member of
the Board of Directors.
6
Determination of the number and qualifications of the Audit Committee’s
Members as per article 44 par. 1 case b) of law 4449/2017.
7
Granting of authorizations regarding the Merger.
All the items of the agenda were approved by the Extraordinary General Shareholder Meeting.
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D2.
Communication
with
Shareholders,
Investor
Roadshows and
Corporate
Governance
Meetings
In order to enhance the active participation of the Shareholders in the General Meetings and the genuine
interest in issues relating to its operation, our Bank applies procedures of active communication with them
and establishes the appropriate conditions so that the policies and strategies adopted are based on a
constructive exchange of views.
To strengthen our relationships with proxy advisors and investors, particularly those focused on corporate
governance, we have been actively engaging to support their decision-making processes. Throughout the
year, we have conducted bilateral meetings with representatives of proxy advisors, analysts and investors to
discuss corporate governance and sustainability issues.
In 2025, we organized roadshows with investors and international proxy advisors, with the participation of
the Chairs of the Corporate Governance, Sustainability and Nominations Committee, the Remuneration
Committee as well as our Executives. During November and December 2025, several meetings with investors
were held. Those roadshows focused on several key areas: Strategic Overview, Corporate Governance
(including Board Structure, Board Effectiveness and Remuneration) and Sustainability.
D3.
Shareholder
structure
On 31.12.2025, Alpha Bank’s Shareholder base included approximately 98,500 investors.
The breakdown of Shareholders as at 31.12.2025 was, for descriptive (non-regulatory) purposes, as follows:
It is noted that, on 9.1.2026 Alpha Bank, pursuant to the provisions of Law 3556/2007, announced that,
according to a notification received on 9.1.2026 from UniCredit S.p.A. and in accordance with article 11 par.1
(b) of Law 3556/2007, on 5.1.2026, UniCredit exercised financial instruments, resulting in an increase of its
direct shareholding in Alpha Bank to 689,860,498 common registered shares with voting rights, representing
29.796% of the total voting rights of Alpha Bank (from 9.768%).
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E. ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG)
Alpha Bank Group remains firmly committed to operating in a responsible and sustainable manner. ESG integration is among
the key drivers of long-term value creation, financial resilience and sustainable competitiveness. It also enables the Group to
deliver stable performance and respond to the evolving regulatory requirements, market developments and stakeholder
expectations.
The Group has adopted a comprehensive ESG framework aligned with its Sustainability
Strategy. This framework aims to mitigate material negative impacts from its services
and products and own operations, enhance positive impacts on the environment,
society and the economy and promote strong corporate and responsible business
conduct.
The Sustainability Strategy is structured around three core commitments:
• Supporting the transition to an environmentally sustainable and climate-resilient
economy.
• Fostering healthy economic and societal progress, including financial inclusion and responsible customer outcomes.
• Ensuring robust, transparent and ethical governance.
These commitments are embedded in Alpha Bank’s business model, lending and investment activities, risk appetite and
internal control systems, reinforcing the link between sustainability performance and long-term competitiveness.
Importantly, they are supported by measurable targets and Key Performance Indicators (KPIs), which are presented in the
“Targets and Metrics sections” of the Sustainability Statement in the Annual Report 2025 and other public sustainability
disclosures.
Alpha Bank Group’s governance framework emphasizes active engagement with stakeholders to understand their evolving
expectations on ESG matters and to integrate those into its corporate strategy and operations. In line with international
guidelines, applicable laws and the Group policies, the Sustainability Strategy identifies four primary Stakeholder groups:
• Investors
• Customers
• Employees and Society
• Regulatory and Supervisory Authorities
Material ESG and Other Non-Financial Matters
In accordance with the Hellenic Corporate Governance Code and the applicable EU regulation, the Group identifies, assesses
and manages material ESG and other non-financial matters. These are determined through a structured double materiality
assessment, which is performed on a recurring basis in the short, medium and long-term horizon, and are integrated into the
Group’s strategic planning, risk identification and decision-making process. Please refer to the “General Disclosures, SBM-3-
Material impacts, risks and opportunities and their interaction with strategy and business model” of the Sustainability
Statement for the year 2025 in the Annual Report for the detailed material topics.
Environmental and climate-related matters constitute a key area of materiality for the Group. These include climate change
mitigation and adaptation, financed emissions, transition and physical climate risks affecting counterparties and collateral,
biodiversity, circular economy and the environmental footprint of own operations. Alpha Bank’s Transition Plan, net-zero
commitments, the Sustainable Finance Framework and the systematic integration of climate and environmental risk drivers
into its Risk Appetite Framework address those environmental and climate-related matters.
Specifically, Alpha Bank has developed a comprehensive Transition Plan for climate change mitigation that aligns with the
European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD) and
prudential expectations (including EBA guidelines), integrating climate and environmental considerations into strategy,
governance, risk management, credit processes and portfolio steering.
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In line with the EU Climate Law and its net-zero commitments, Alpha Bank is committed to achieving net zero greenhouse gas
emissions across its lending and investment portfolio by 2050 and therefore has established interim 2030 targets. In 2024, th e
first wave of decarbonization targets was introduced for four carbon intensive sectors (Power Generation, Oil and Gas,
Cement, Iron and Steel), with a second wave of sectoral targets expected to be finalized in 2026, subject to regulatory and
methodological developments.
Progress against climate targets and related risk indicators is monitored through the Risk Appetite Framework and reported
regularly to the Senior Management and the Board of Directors. Please refer to chapter “E1-1- Transition plan for climate
change mitigation” in the Sustainability Statement for the year 2025.
Social matters involve talent development, Diversity, Equity, and Inclusion (DEI), employee well-being, financial inclusion,
access to housing, customer protection and privacy, responsible marketing practices, supplier code of conduct and the
positive impact on local communities. These matters are managed through Group-wide policies and programs aligned with
internationally recognized standards, legal requirements and targeted community initiatives.
The Group operates based on a set of policies relating to its own workforce, Customers and Suppliers as well as to society.
Please refer to “Policy sections of chapters S1- Own Workforce and S4- Consumers and End Users” in the Sustainability
Statement for the year 2025.
Employee development and well-being remain key priorities and are supported by initiatives that foster a healthy working
environment, enhance skills and enable innovation. To strengthen capability across the Organization, the Group continues to
provide ESG training and upskilling opportunities to its Employees. Community engagement forms a cornerstone of the
Bank’s social impact, including initiatives supporting economic resilience and financial inclusion, circular economy and acce ss
to cultural life and h eritage. Please refer to the “Actions section of chapter S4- Consumers and End Users” in the Sustainability
Statement for the year 2025 and the “Society” section of the Alpha Bank Group website.
Governance matters pertain to ethical business conduct, Board effectiveness, regulatory compliance and business integrity,
transparency, risk management and the effectiveness of internal control systems. These matters are addressed through the
Group’s Corporate Governance Framework, the Group Code of Conduct and Ethics and associated policies and procedures,
escalation mechanisms and clearly defined roles and responsibilities across governance bodies.
Alpha Bank has established a governance framework for ESG oversight and implementation at Board, Executive Management
and Operational levels.
• At Board level, the Corporate Governance, Sustainability and Nominations Committee (CGSNC) acts as the principal body
responsible for ESG oversight.
• At Executive Management level, the Group Sustainability Committee oversees ESG topics and the implementation of the
Sustainability Strategy, supporting the Board of Directors in overseeing Climate and ESG risks and Sustainability more
broadly.
• At Operational level, the ESG Working Group, led by the Group ESG Coordinator, supports the implementation of key
initiatives and provides direction across the Group, while the Governance and Sustainability Business Area drives the ESG
agenda and internal adoption of best market practices. Close coordination is maintained with the Climate, ESG and
Enterprise Risk Management Business Area on ESG and climate-related topics, including methodologies, risk integration,
questionnaires and assessments, and risk input to supervisory processes and submissions. Please refer to the General
Disclosures “GOV-1- The role of the administrative, management and supervisory bodies” in the Sustainability Statement
for the year 2025 for the detailed responsibilities, oversight and controls over sustainability.
ESG Integration into the Risk Management Framework and the Remuneration Policy
The Group recognizes ESG risks, including climate and environmental risks, as transversal risk drivers influencing traditiona l
financial and non-financial risk categories. ESG considerations are integrated into the Alpha Bank’s Risk Management
Framework, including credit risk, operational risk, reputational risk and strategic risk, as well as into the Internal Capital
Adequacy Assessment Process (ICAAP), stress testing and capital planning processes.
In addition, ESG and sustainability considerations are incorporated into Alpha Bank’s Remuneration Policy. Variable
remuneration for senior executives includes ESG-related performance indicators, ensuring alignment between incentive
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structures and the long-term sustainability goals. Please refer to the General Disclosures “GOV-3- Integration of sustainability-
related performance in incentive schemes” in the Sustainability Statement for the year 2025.
Sustainability Statement preparation
The Sustainability Statement within the Annual Report 2025 has been prepared in accordance with the Corporate
Sustainability Reporting Directive (EU) 2022/2464, considering also the “quick-fix” Commission Delegated Regulation (EU)
2025/1416 of 11 July 2025 and the applicable national transposition legislation (Greek Law 5164/2024), as in force. Data
stemming from other legislative requirements have been incorporated including, indicatively, the Regulation (EU) 2020/852
(the Taxonomy Regulation); Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on
prudential requirements for credit institutions and investment firms (“CRR”), specifically information relating to Pillar III
reporting requirements; Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021
establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999,
as transposed in the Greek National Climate Law (Law 4936/2022). Furthermore, the widely accepted sustainability reporting
standards part of the Global Reporting Initiative (GRI 2021) and the Sustainability Accounting Standards Board (SASB) have
been leveraged (please refer to the Section “Sustainability reporting resulting from other legislation and standards” in the
Sustainability Statement of the Annual Report 2025).
Future Outlook
Looking ahead, the Bank and the Group will continue to strengthen the integration of ESG considerations across its strategy,
governance, risk management, products and services. Focus will be on the implementation and ongoing refinement of its
Transition Plan for climate change mitigation.
Priorities include the progressive alignment of lending and investment portfolios with net-zero pathways and the expansion of
sustainable finance solutions to support Customers’ transition through effective engagement. Climate and ESG risk drivers will
be further embedded in the Risk Appetite Framework, the ICAAP and stress-testing processes. At the same time, the Group
will continue to enhance data quality, methodologies and systems and expects to expand sectoral decarbonization targets in
line with regulatory and methodological developments. Strong governance and oversight will remain central to the Group’s
activities, supporting compliance with the CSRD requirements and supervisory expectations. Through these actions, the
Group aims to safeguard long-term financial resilience and create sustainable value for all stakeholders.
F. BOARD OF DIRECTORS AND COMMITTEES
F1.
The Board of Directors (the “Board”) is responsible for the management of our Bank’s affairs and its
representation vis-à-vis third parties. It bears the ultimate responsibility for our Bank and ensures effective
and prudent management. Here is a breakdown of some key responsibilities:
a. It has the overall responsibility for the Bank and approves and oversees the implementation of the
Bank’s strategic objectives, risk strategy, ESG strategy and internal governance.
b. It ensures the integrity of our accounting and financial reporting systems, including financial and
operational controls and compliance with the law and relevant standards.
c. It oversees the process of disclosure and communications.
d. It is responsible for providing effective oversight of the Senior Management.
The Board consists of no fewer than nine and no more than fifteen Members, with odd numbers being the
norm. An even number of Members can be accepted temporarily for a justified reason. The Board includes
Executive and Non-Executive Members, in accordance with the provisions of the applicable legislation. It is
noted that a legal entity may also participate in the Board as a Member, pursuant to article 77 par. 4 of Law
4548/2018. Additionally, Independent Non-Executive Members are not less than 50% of the total number of
Members.
The tenure of the Members of the Board is quadrennial. This tenure may be extended until the termination
of the deadline for the convocation of the next Ordinary General Meeting and until the respective resolution
has been adopted.
Board of
Directors
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The Board of Directors meets whenever required to properly discharge its responsibilities. At the beginning
of each calendar year, we adopt a calendar and a work plan, which may be reviewed and adjusted as needed
throughout the year.
Meetings are convened either by the Chair of the Board of Directors or at the request of at least two
Members. We also accommodate meetings via videoconference or teleconference, providing, in such cases,
the necessary information and instructions for participation.
A quorum is achieved when at least half of the Members plus one are present or represented. There must
always be a minimum of six Members present, whether physically, by videoconference or teleconference.
For meetings concerning the drafting of Financial Statements or requiring decisions by the General Meeting
with special quorum and majority as per Law 4548/2018, at least two Independent Non-Executive Members
must be present. Should an Independent Member be absent without justification from two consecutive
meetings, they are considered to have resigned and the Board will proceed with their replacement.
Resolutions are passed by an absolute majority of the Members present or duly represented, unless
otherwise specified by our Articles of Incorporation or the law. If no unanimous decision is reached, the
minority views are recorded in the Minutes.
Lastly, the specific duties, responsibilities, principles and the framework for the proper operation of the
Board are outlined in our Charter, which is available on the Bank’s website.
(https://www.alpha.gr/en/group/corporate-governance/administrative-structure/board-of-directors).
During 2025, the following changes took place with regard to the composition of the Board and its
Committees:
During the Board of Directors Meeting on 27.2.2025, following the previously expressed intention of Messrs.
S.N. Filaretos and E.O. Vidalis to resign from their position and taking into consideration the respective
recommendation by the Corporate Governance, Sustainability and Nominations Committee, the Board of
Directors resolved on:
- the appointment of Mr. L.A. Papagaryfallou as new Executive Member of the Board of Directors in
replacement of Mr. S.N. Filaretos, with such appointment taking effect as of 27.2.2025;
- the appointment of Ms. Α.G. Areni as new Non-Executive Member of the Board of Directors in replacement
of Mr. E.O. Vidalis, with such appointment taking effect as of 27.2.2025. Ms. A.G. Areni has been proposed as
a candidate for the position of the Non-Executive Member of the Board of Directors by UniCredit within the
framework of the Group’s strategic partnership with the latter.
The fit and proper assessment process for these appointments has been completed successfully by the
European Central Bank (ECB) and in particular by the Single Supervisory Mechanism (SSM). During the same
Board meeting, Ms. A.F. Palimeri, an Independent Non-Executive Member, was appointed as Chair of the
Remuneration Committee with effect as of 27.2.2025. She replaced Mr. D.C. Tsitsiragos, Independent Non-
Executive Member of the Board of Directors and Chair of the Board of Directors as of 1.1.2025, who
continued to serve as a Member of the Committee.
Following the resolution of the Extraordinary General Meeting of the Bank dated 12.6.2025, Mr. J.-H.-F.G.
Umbgrove was appointed as an Independent Non-Executive Member of the Board of Directors (having
served as a Non-Executive Member since 2018) following a relevant recommendation by the Corporate
Governance, Sustainability and Nominations Committee and the assessment of the fulfilment of the
suitability and independence criteria set by the regulatory and legislative framework.
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The Corporate Secretariat and Governance Policies Business Area supports the functionality of the Board, its
Committees and its Members. This includes coordinating communications among the Members of the Board,
the Management and the Subsidiaries to ensure the effective flow of information to and from the Board.
The CVs of the Members of the Board of Directors are presented below and are also available on the Bank’s
website (https://www.alpha.gr/en/group/corporate-governance/administrative-structure/board-of-
directors/biografika-melon#2).
F2.
Dimitris C. Tsitsiragos
Independent Non-Executive Member
Chair of the Board of Directors since 1.1.2025
Current appointments
Dimitris C. Tsitsiragos is the Chair and an Independent Non-Executive Member of the Board of Directors of
Alpha Bank. He has been a Board Member since July 2020.
He is also a Member of the Remuneration Committee.
Moreover, he is a Member of the Board of Directors of Titan Cement International and of the Alpha Bank
Cultural Foundation.
Past appointments
Member of the Advisory Board, Chicago Atlantic Trident Fund (2024)
Senior Advisor, Emerging Markets, Pacific Investment Management Company (PIMCO), London, UK (2018-
2022)
Independent Non-Executive Board Member, Infrastructure Development Finance Company (IDFC), India
(2003-2011), and Commercial Bank of Ceylon (CBC), Sri Lanka (2003-2004)
He worked for 28 years at the International Finance Corporation (IFC), World Bank Group:
Vice President Investments/Operations, Istanbul/Washington D.C. (2014-2017) and Vice President, EMENA
Region, Istanbul, Turkey (2011-2014)
Director positions for the departments of South Asia, New Delhi, India; Global Manufacturing and Services,
Washington DC, USA; and Middle East, North Africa (Cairo, Egypt) and Southern Europe, overseeing IFC’s
global and regional investment operations (2002-2011)
Progressive positions, including Manager, Oil and Gas, and Manager, Manufacturing and Services, for the
department of Oil, Gas and Mining and the department of Central and Eastern Europe, Washington D.C., USA
(1989-2002)
Studies
• MBA, George Washington University, Washington D.C., USA
• BA in Economics, Rutgers University, New Jersey, USA
• World Bank Group Executive Development Program, Harvard Business School, Boston, Massachusetts,
USA
CVs of the
Members of
the Board of
Directors
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Other information
Nationality: Greek
CEO
Vassilios E. Psaltis
Executive Member
Member of the Board of Directors since November 2018 and Chief Executive Officer since January 2019
Experience and contribution
Vassilios E. Psaltis is the CEO and an Executive Member of the Board of Directors of Alpha Bank. In his
capacity as a Board Member since November 2018 and CEO since January 2019 he actively contributes to
implementing Alpha Bank’s strategic plan. In 2023 h e promoted a multilevel milestone deal with UniCredit.
This strategic partnership has unlocked the profitability potential of Alpha Bank’s international business,
while creating upside potential for the rest of the Group.
With over 25 years of experience in the banking industry, he has been appointed to key positions at Alpha
Bank since 2007. Through these posts he has significantly reinforced the position of Alpha Bank. He
spearheaded capital raisings from foreign institutional shareholders, diversifying the Bank’s shareholder
base, as well as significant mergers and acquisitions that contributed to the consolidation of the Greek
banking system.
On top of his duties at Alpha Bank, he has also been serving as a Member of the Board of Directors and the
Executive Committee of the Hellenic Federation of Enterprises (SEV) since July 2021 and as a Member of the
Board of Directors of the Hellenic Bank Association (HBA) since October 2021. In 2019 he was appointed
member of the Institut International d' Études Bancaires (IIEB).
He holds a PhD and MA in Business and Banking from the University of St. Gallen, Switzerland.
Current and past appointments
▪ CEO, Alpha Bank (2019 - today)
▪ General Manager, Alpha Bank (2012-2018)
▪ Group Chief Financial Officer (CFO), Alpha Bank (2010-2018)
▪ Senior Manager, Corporate Planning and Controlling, Alpha Bank (2007-2010)
▪ Deputy (acting) Chief Financial Officer, Emporiki Bank (2002-2006)
▪ Senior management positions, ABN AMRO Bank’s Financial Institutions Group, London (1999-2001)
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Lazaros A. Papagaryfallou
Executive Member
Deputy CEO (since 23.7.2024)
Member of the Board of Directors since 27.2.2025
Current appointments
Lazaros A. Papagaryfallou is an Executive Member of the Board of Directors of Alpha Bank. He has been a
Board Member since February 2025, and Deputy CEO since July 2024. He joined Alpha Bank in 1998.
He is a member of the Executive Committee of Alpha Bank.
Past appointments
• Alpha Bank Group, Chief Financial Officer (CFO) (2019)
• Alpha Bank, Appointed Executive General Manager of the Bank (2013-2019), Manager of the Corporate
Development, International Network and Strategic Planning Divisions (1998-2013)
• Alpha Bank Group, Chairman and Member of the Boards of Directors of various Group Companies, both
in Greece and abroad, in the banking, insurance, financial services, industrial and real estate sectors
Through these posts he contributed to implementing the Group’s Restructuring Plan, as well as
designing and closing mergers, acquisitions and portfolio transactions, and strengthening the Bank’s
capital.
Work experience: Citibank, ABN AMRO
Studies
• MBA in Business Administration, Finance, University of Wales, Cardiff Business School
• Degree in Business Administration, Athens University of Economics and Business
Other information
Nationality: Greek
Annalisa G. Areni
Non-Executive Member
Member of the Board of Directors since 27.2.2025
Current appointments
Annalisa G. Areni has been a Non-Executive Member of the Board of Directors of Alpha Bank since February
2025.
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Since September 2022 she has been serving as Head of Client Strategies (Italy) at UniCredit SpA. She is also a
member of the National Council of Associazione Bancaria Italiana (Banking Association in Italy – ABI).
Past appointments
• Member of the Board of Directors, CNP Vita SpA (2017-2024)
• Regional Manager of Southern Italy, UniCredit SpA (2019-2022)
• Head of Retail – Lombardy Region, UniCredit SpA (2016-2019)
• Area Manager – Brescia and Province, UniCredit SpA (2016)
• Area Manager – East Milan, UniCredit SpA (2013-2015)
• Head of Customer Satisfaction – Lombardy Region, UniCredit SpA (2010-2012)
• Regional Co-Director – East Lombardy, UniCredit SpA (2008-2010)
• Market Manager – Milano, Cordusio, UniCredit SpA (2002-2008)
• Since 1994, she has held various positions at Credito Italiano SpA, including the role of Head of Personal
Banking Segment – Lombardy Region (2000-2002)
Studies
• Master’s Degree in Banking and Financial Communication, Università Cattolica del Sacro Cuore, Milan,
Italy
• Business Leaders for Transform and Lead Change Programme at IMD Business School – International
Institute for Management Development, Lausanne, Switzerland
• Degree in Business and Economics, Università Cattolica del Sacro Cuore, Milan, Italy
Other information
Nationality: Italian
Elli M. Andriopoulou
Independent Non-Executive Member
Member of the Board of Directors since January 2022
Current appointments
Elli M. Andriopoulou is an Independent Non-Executive Member of the Board of Directors of Alpha Bank. She
has been a Board Member since January 2022.
She sits on the following Committees:
➢ Audit Committee, Member
➢ Corporate Governance, Sustainability and Nominations Committee, Member
Moreover, since 2020 she has been the Managing Director of the Stavros Niarchos Foundation Cultural
Center (SNFCC).
Past appointments
• Chairwoman of the Board of Directors, SNFCC (2020-2023)
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• Co-Chief Operating Officer, SNF (2013), Chief Operating Officer, SNFCC (2014-2015) and Grant Manager,
SNFCC (2016-2020)
• Sales Development Manager, Branch Expansion Project Manager, Strategy and Development Manager,
Customer Interaction Unit Head, Customer Advocacy and Segment Management Head and Marketing
Director, Citibank International Plc, Greece (2004-2012)
• Consultant, Mercer Management Consulting (currently Oliver Wyman), USA (2000-2003)
• Service Quality Assistant, Quality Associate, and Quality Officer, Citibank ΝΑ, Greece (1996-1999)
Studies
• ΜΒΑ, Kellogg School of Management, Northwestern University, Evanston, Illinois, USA
• BA in Psychology, American College of Greece (Deree College)
Other information
Nationality: Greek
Aspasia F. Palimeri
Independent Non-Executive Member
Member of the Board of Directors since July 2022
Current appointments
Aspasia F. Palimeri is an Independent Non-Executive Member of the Board of Directors of Alpha Bank. She
has been a Board Member since July 2022.
She sits on the following Alpha Bank Committees:
➢ Remuneration Committee, Chair
➢ Risk Management Committee, Member
Moreover, she has been a Non-Executive Member of the Board of Directors at the Foundation for Economic
and Industrial Research (IOBE) since 2021.
Past appointments
• Country Manager for Greece, Cyprus and Malta, responsible for market share growth and the strategic
development of these markets, Mastercard (2016-2022)
• Deposit and Investment Products Senior Director, Piraeus Bank, Greece (2013-2016)
• Cards Business Manager, Marfin Egnatia Bank, Greece (2010-2013)
• Marketing Manager (2005-2010) and Group Product Manager for Loans (2002-2005), Eurobank Cards
SA, Greece
• Junior Engagement Manager supporting strategic projects for leading Greek banks and corporates (2001-
2002) and Associate Consultant (2000-2001), McKinsey & Company, Greece
• Special Projects Manager, Eurobank Cards SA, Greece (1996-1998)
• Financial Analyst, Citibank NA, Greece (1995-1996)
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Studies
• MBA in Finance and Marketing, Columbia Business School, Columbia University, New York, USA
• BA in Accounting and Finance, American College of Greece (Deree College)
Other information
Nationality: Greek
Panagiotis I.-K. Papazoglou
Independent Non-Executive Member
Member of the Board of Directors since July 2023
Current appointments
Panagiotis I.-K. Papazoglou is an Independent Non-Executive Member of the Board of Directors of Alpha
Bank. He has been a Board Member since July 2023.
He sits on the following Committees:
➢ Audit Committee, Chair
➢ Remuneration Committee, Member
He is a Deputy Chairman of the Executive Committee of the Foundation for Economic and Industrial Research
(IOBE), a Member of the Board of Directors of Aims International Hellas SA (since 2023), the Vice-Chair of the
Citizens’ Movement for an Open Society, and a Board Member of BrainRegain, as well as an Independent
Non-Executive Member of the Audit Committee (not a Board Member) of Helleniq Energy.
Past appointments
• Certified Auditor in Greece and in Romania (until 2023)
• Member of the Supervisory Council of the Institute of Certified Public Accountants of Greece (until 2023)
• Member of the Board of Directors of the American-Hellenic Chamber of Commerce (until 2023)
• Senior Advisor, EY Greece (until 2023)
• Accounts Leader for Central, Eastern and Southeastern Europe and Central Asia, EY Greece (2015-2021)
• Managing Partner for Greece, Romania, Bulgaria, Cyprus, Albania, Malta, Kosovo, FYROM, Moldova, EY
Greece and Southeastern Europe (2010-2022)
• Head of Assurance, where he led a number of major assurance and advisory audit projects for
international clients, EY Romania, Bucharest (2008-2010)
• Country Managing Partner and Head of Assurance, EY Bulgaria, Sofia (2005-2007)
• Engagement (signing) Partner in a number of large Group audits and the audit of a number of large
shipping groups, preparing them for listing on the US and the UK stock markets (2000-2005)
• Qualified Accountant, Ernst & Whinney (renamed Ernst & Young) (1988)
Studies
• MBA in Finance and Management, Aston University, Birmingham, UK
• MA in Economic Theory and Policy, Athens University of Economics and Business, Greece
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• BSc in Economics, Athens University of Economics and Business, Greece
• EY Journey to the Boardroom program issued by Harvard Business Publishing
Other information
Nationality: Greek
Jean L. Cheval
Independent Non-Executive Member
Member of the Board of Directors since June 2018
Current appointments
Jean L. Cheval is an Independent Non-Executive Member of the Board of Directors of Alpha Bank. He has
been a Board Member since June 2018.
He sits on the following Committees:
➢ Risk Management Committee, Chair
➢ Audit Committee, Member
Moreover, he is a Member of the Board of Directors and a Member of the Audit and Risk Committee of EFG-
Hermes in Egypt, a Member of the Board of Directors, as well as Chair of the Board Risk Committee of Natixis
Algérie and Chairman of the Natixis Foundation for Research and Innovation. Furthermore, he is a non-voting
board observer (censeur) of GIFI.
Past appointments
• Senior Advisor to Natixis’ CEO (2017-2022), while chairing the Credit Risk Committee and supervising the
main restructuring operations (impaired assets) (2017-2022); second Dirigeant effectif, alongside the
CEO, Head of Finance and Risk (2012-2017) and Head of the Structured Asset Finance Department of
Natixis (2009-2012)
• Member of the Board of Directors, HME-SAUR (2013-2018)
• Head of France, Bank of Scotland (2005-2009)
• Chair and CEO, Banque Audi France (2002-2005)
• Chair, Banque Audi Suisse (2002-2004)
• Various senior management positions, including Chief Economist, Head of Corporate Planning, Head of
Asset-based Finance and General Manager, Banque Indosuez-Crédit Agricole (1983-2001)
• French public sector (1978-1983)
• Consultant, BIPE (Bureau d’Information et de Prévisions Économiques)
Studies
• DES (Diplôme d’Études Spécialisées) in Economics, University of Paris I, France
• DEA (Diplôme d’Études Approfondies) in Statistics, University of Paris VI, France
• DEA in Applied Mathematics, University of Paris VI, France
• Engineering, École Centrale des Arts et Manufactures (now CentraleSupélec), Paris, France
Other information
Nationality: French
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Elanor R. Hardwick
Independent Non-Executive Member
Member of the Board of Directors since July 2020
Current appointments
Elanor R. Hardwick is an Independent Non-Executive Member of the Board of Directors of Alpha Bank. She
has been a Board Member since July 2020.
She sits on the following Alpha Bank Committees:
➢ Corporate Governance, Sustainability and Nominations Committee, Chair
➢ Risk Management Committee, Member
Moreover, since 2018 she has served as a non-executive member of the Board of Directors of specialty
(re)insurer Axis Capital, also a member of the Human Capital and Compensation Committee as well as Chair
of the Corporate Governance, Nominating and Social Responsibility Committee. Since 2024 she has served as
an independent non-executive member of the Board of Directors of Euroclear SA/NV, is a member of the
Audit and Risk Committees, and since January 2025 chairs the newly-formed Technology Committee. Ms.
Hardwick is also an external member of the Audit Committee of the University of Cambridge as of January
2021.
Past appointments
• Member of the Supervisory Council, Luminor Group (April 2022 - October 2023)
• Non-Executive Member of the Board of Directors, Itiviti Group AB (July 2020 - May 2021)
• Chief Digital Officer, UBS (2019-2020)
• Head of Innovation, Deutsche Bank (2016-2018)
• Founding member and CEO, Credit Benchmark FinTech startup (2012-2016)
• Global Head of Professional Publishing and Global Head of Strategy, Investment Advisory, Thomson
Reuters (now London Stock Exchange Group) (2005-2011)
• Strategy consultant with Booz Allen Hamilton’s Tech, Media and Telco practice (1997-2000) and with the
Institutional Equity Division of Morgan Stanley (2002-2005)
• Department of Trade and Industry, UK Government, focusing on the Communications and Information
Industries policy (1995-1997)
Studies
• MA (Cantab), University of Cambridge
• MBA, Harvard Business School, USA
Other information
Nationality: British
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
185 | ANNUAL FINANCIAL REPORT
Diony C. Lebot
Independent Non-Executive Member
Member of the Board of Directors since July 2023
Current appointments
Diony C. Lebot is an Independent Non-Executive Member of the Board of Directors of Alpha Bank. She has
been a Board Member since July 2023.
She sits on the following Committees:
➢ Risk Management Committee, Member
➢ Corporate Governance, Sustainability and Nominations Committee, Member
She is a Non-Executive Member of the Board of Directors and Chair of the Audit Committee of EQT AB as well
as an Independent Non-Executive Member of the Board of Directors and a Member of the Board’s
Sustainability Committee of Barclays Plc.
Past appointments
• Non-Executive Member of the Board of Directors (2023-2025) and Chair of the Board of Directors (2020-
2023), Ayvens (former ALD Automotive)
• Senior Advisor to the CEO, Société Générale (2023-2024)
• Deputy Group Chief Executive Officer, Société Générale (2018-2023)
• Chair of the Board of Directors, SOGECAP (2020-2023)
• Group Chief Risk Officer, Société Générale (2016-2018)
• Deputy Group Chief Risk Officer, Société Générale (2015-2016)
• Deputy Global Head of Coverage and Investment Banking, Société Générale, and CEO, Société Générale
Corporate and Investment Banking for Western Europe (2012-2015)
• CEO, Société Générale Americas (US, Canada, Latin America), and CEO, Société Générale American
Securities (2007-2012)
• Head of Coverage Europe (Large Corporate and Institutional Clients of SGCIB), Société Générale (2004-
2007)
• Global Head of Asset Finance, Société Générale (2001-2004)
• Deputy Global Head of Société Générale Financial Engineering (1998-2001)
• Head of Big Ticket Leasing and Asset based Finance, Société Générale (1997-1998)
• Vice President and Director in Asset based and Project Finance, Société Générale (1987-1997)
Furthermore, she has held main Board positions over the last 10 years in Franfinance, Société Générale
Bank and Trust (SGBT), Société Générale Factoring (previously CGA) and TCW (Asset Management
company based in LA, California).
Studies
• MSc in Finance and Taxation, University of Paris I - Panthéon-Sorbonne, Paris, France
• MA in Management, University of Paris I - Panthéon-Sorbonne, Paris, France
Other information
Nationality: French and Greek
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
186 | ANNUAL FINANCIAL REPORT
Johannes Herman Frederik G. Umbgrove
Independent N on-Executive Member
Member of the Board of Directors since April 2018
Current appointments
Johannes Herman Frederik G. Umbgrove is an Independent Non-Executive Member of the Board of Directors
of Alpha Bank. He was a Non-Executive Member from April 2018 until June 2025 (representative of the
Hellenic Financial Stability Fund until November 2023).
He sits on the following Committees:
➢ Audit Committee, Member
➢ Remuneration Committee, Member
➢ Corporate Governance, Sustainability and Nominations Committee, Member
Moreover, he is an Independent Member of the Supervisory Board (SB) (since 2019) and the Chair of the SB
Risk and Audit Committee of Lloyds Bank GmbH (since 2022). He is also the Chair of the SB (since 2018), the
Chair of the SB Nomination and Remuneration Committee, and a Member of the SB Risk and Audit
Committee and the Related Party Transactions Committee of DHB Bank N.V. [former Demir-Halk Bank
(Nederland) N.V.].
Additionally, he is a Member of the Board of Directors of the Parel van Baarn Foundation and a member of
the Management Committee (International Director – Europe) of the Aston Martin Owners Club Ltd.
Past appointments
• Risk Advisor, Sparrenwoude B.V. (2014-2016)
• Member of the Supervisory Board, DHB Bank N.V. [former Demir-Halk Bank (Nederland) N.V.] (2016-
2018)
• Group Risk Officer, Alfa Bank Group Holding (2011-2013)
• Chief Risk Officer and Member of the Management Board, Amsterdam Trade Bank N.V. (2010-2013)
• Chief Credit Officer Central and Eastern Europe, Middle East and Africa (CEEMEA) of the Global Markets
Division, The Royal Bank of Scotland Group (2008-2010)
• Various senior management positions, ABN AMRO Bank N.V. (1986-2008)
Studies
• MBA, INSEAD (The Business School for the World), Fontainebleau, France
• LL.M. in Trade Law, Leiden University, Netherlands
• IN-BOARD Non-Executive Directors Program, INSEAD, Fontainebleau, France
Other information
Nationality: Dutch
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
187 | ANNUAL FINANCIAL REPORT
Eirini E. Tzanakaki
Secretary of the Board of Directors since December 2021
Corporate Secretariat and Governance Policies Director
She has more than 20 years of professional experience in the investment banking industry in Greece, having
participated in a large number of international and domestic capital market transactions including
privatizations, Mergers and Acquisitions, tender offers and corporate restructurings.
Past appointments
• Assistant Manager, Secretariat of the Board of Directors (now Corporate Secretariat and
Governance Policies Business Area), Alpha Bank (2020-2022)
• Associate Director, Corporate Finance Division, Alpha Bank (2006-2020)
• Investment Banker, Alpha Finance (1999-2006)
• Senior Credit Officer, Corporate Banking Division, Geniki Bank (1997-1999)
Studies
• MSc in Finance and Banking, Athens University of Economics and Business
• MBA, Cyprus International Institute of Management
• BSc in Mathematics, University of Crete
Other information
Nationality: Greek
F3. Professional commitments of the Members of the Board of Directors
Professional commitments of the Members of the Board of Directors
(Based on the composition of the BoD on 31.12.2025)
Position
Principal outside activities
Chair (Independent Non-Executive Member)
Dimitris C. Tsitsiragos
Member of the BoD of Titan Cement International
Member of the BoD of Alpha Bank Cultural Foundation
Executive Member
Vassilios E. Psaltis
CEO
Member of the Institut International d'Études Bancaires (IIEB)
Member of the BoD and of the Executive Committee of the Hellenic Federation of Enterprises (SEV)
Member of the BoD of the Hellenic Bank Association
Non-Executive Member
Annalisa G. Areni
Head of Client Strategies – Italy at UniCredit S.p.A
Member of the National Council of ABI (Banking Association in Italy)
Independent Non-Executive Members
Elli M. Andriopoulou
Managing Director of the Stavros Niarchos Foundation Cultural Center (SNFCC)
Aspasia F. Palimeri
Non-Executive Member of the BoD of the Foundation for Economic and Industrial Research (IOBE)
Panagiotis I.-K.
Papazoglou
Deputy Chairman of the Executive Committee of the Foundation for Economic and Industrial Research (IOBE)
Member of the BoD of Aims International Hellas SA
Vice-Chair of the Citizens’ Movement for an Open Society
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
188 | ANNUAL FINANCIAL REPORT
Professional commitments of the Members of the Board of Directors
(Based on the composition of the BoD on 31.12.2025)
Member of the BoD of BrainRegain
Independent Non-Executive Member of Audit Committee (not a BoD Member) of Helleniq Energy
Jean L. Cheval
Member of the BoD and Member of the Audit and Risk Committee of EFG-Hermès (Egypt)
Member of the BoD and Chair of the Board Risk Committee of Natixis Algérie
Chairman of the Natixis Foundation for Research and Innovation
Non-voting BoD observer (censeur) of GIFI
Elanor R. Hardwick
Non-Executive Member of the BoD, Member of the Human Capital and Compensation Committee as well as
Chair of the Corporate Governance, Nominating and Social Responsibility Committee of specialty (re)insurer
Axis Capital
Independent Non-Executive Member of the BoD, Member of the Audit and Risk Committees and Chair of the
Technology Committee of Euroclear SA/NV
External member of the Audit Committee of the University of Cambridge
Diony C. Lebot
Non-Executive Member of the BoD and Chair of the Audit Committee of EQT AB
Independent Non-Executive Member of the BoD and Member of the BoD’s Sustainability Committee of
Barclays Plc
Johannes Herman Frederik
G. Umbgrove
Independent Member of the Supervisory Board (SB) and Chair of the SB Risk Committee and Audit
Committee of Lloyds Bank GmbH
Chair of the SB, Chair of the SB Nomination and Remuneration Committee, Member of the SB Risk and Audit
Committee and of Related Party Transactions Committee of DHB Bank N.V. [former Demir-Halk Bank
(Nederland) N.V.]
Member of the BoD of the Parel van Baarn Foundation
Member of the Management Committee (International Director – Europe) of the Aston Martin Owners Club
Ltd
F4. Profile of the Board of Directors and Committee Membership for the year 2025 and shares of the Bank owned on
31.12.2025
Board of Directors
Gender
Tenure
(in years)
Term ends
Shares owned
31.12.2025
Committees
Number
of
shares
% of
the
share
capital
Audit
Risk
Management
Remuneration
Corporate
Governance,
Sustainability
and
Nominations
Chair (Independent Non-Executive Member)
Dimitris C. Tsitsiragos
M
5
(C since
1.1.2025)
2026
0
0
-
-
M
(since
27.2.2025)
C
(until
27.2.2025)
-
Executive Members
Vassilios E. Psaltis
CEO
M
7
2026
430,872
0.019
-
-
-
-
Lazaros A.
Papagaryfallou
Deputy CEO
since 27.2.2025
M
1
2026
385,321
0.017
-
-
-
-
Spyros N. Filaretos
Chief of Growth and
Innovation
until 27.2.2025
M
20
27.2.2025
-
-
-
-
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
189 | ANNUAL FINANCIAL REPORT
Board of Directors
Gender
Tenure
(in years)
Term ends
Shares owned
31.12.2025
Committees
Number
of
shares
% of
the
share
capital
Audit
Risk
Management
Remuneration
Corporate
Governance,
Sustainability
and
Nominations
Non-Executive Members
Annalisa G. Areni
since 27.2.2025
F
1
2026
0
0
-
-
-
-
Efthimios O. Vidalis
until 27.2.2025
M
10
27.2.2025
-
-
M
(until
27.2.2025)
M
(until
27.2.2025)
Independent Non-Executive Members
Elli M. Andriopoulou
F
3
2026
0
0
M
-
-
M
Aspasia F. Palimeri
F
3
2026
0
0
-
M
M
(until
27.2.2025)
C
(since
27.2.2025)
-
Panagiotis I.-K.
Papazoglou
M
2
2026
24,050
0.001
C
-
M
-
Jean L. Cheval
M
7
2026
0
0
M
C
-
-
Elanor R. Hardwick
F
5
2026
0
0
-
M
-
C
Diony C. Lebot
(Member in charge of
coordinating the Data
Governance Framework
activities)
F
2
2026
0
0
-
M
-
M
Johannes Herman Frederik G.
Umbgrove
M
7
2026
0
0
M
-
M
M
C: Chair
M: Member
-: The Member does not participate in this Committee
F5. BOARD AND COMMITTEES
ATTENDANCE
During 2025, the Board convened 25 times, with an average participation rate of 98%. This
high level of engagement demonstrates the dedication and commitment of our Members.
The Non-Executive Members of the Board convened seven times during the year,
significantly exceeding the minimum requirement. This proactive approach has greatly
contributed to our governance.
It is worth noting that all four Committees of the Board of Directors are chaired by
Independent Non-Executive Members, with all Members being Independent Non-
Executive Members. Their leadership and support have been instrumental in assisting the
Chairs in fulfilling their duties and responsibilities.
The Corporate Governance, Sustainability, and Nominations Committee (CGSNC) observed
that there were no Member absences from Board meetings without a valid reason. Those
Members who were unable to attend had informed the Bank in advance of the relevant
reasons. For your reference, the table of attendance rates for the Members of the Board
of Directors is posted on the Bank’s website https://www.alpha.gr/en/Group/advocating-
sound-governance-practices/management/board-of-directors.
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
190 | ANNUAL FINANCIAL REPORT
F6. 2025 Board Members’ Individual Attendance Rates at Meetings
Board of
Directors
Audit Committee
Risk Management
Committee
Remuneration Committee
Corporate Governance, Sustainability
and Nominations Committee
Number of meetings
25
16
18
17
16
Chair (Independent Non-Executive Member)
Dimitris C. Tsitsiragos
100%
(25/25)
-
-
100%
(17/17)
C
(until 27.2.2025)
M
(since 27.2.2025)
-
Executive Members
Vassilios E. Psaltis
CEO
100%
(25/25)
-
-
-
-
Lazaros A. Papagaryfallou
Deputy CEO
(since 27.2.2025)
95%
(21/22)
-
-
-
-
Spyros N. Filaretos
Chief of Growth and
Innovation
(until 27.2.2025)
100%
(3/3)
-
-
-
-
Non-Executive Member
Annalisa G. Areni
(since 27.2.2025)
91%
(20/22)
-
-
-
-
Efthimios O. Vidalis
(until 27.2.2025)
100%
(3/3)
(until
27.2.2025)
-
-
100%
(3/3)
(until 27.2.2025)
67%
(2/3)
(until 27.2.2025)
Independent Non-Executive Members
Elli M. Andriopoulou
100%
(25/25)
88%
(14/16)
-
-
94%
(15/16)
Aspasia F. Palimeri
100%
(25/25)
-
100%
(18/18)
100%
(17/17)
Μ
(until 27.2.2025)
C
(since 27.2.2025)
-
Panagiotis I.-K. Papazoglou
100%
(25/25)
100%
(16/16)
C
-
100%
(17/17)
-
Jean L. Cheval
100%
(25/25)
100%
(16/16)
100%
(18/18)
C
-
-
Elanor R. Hardwick
96%
(24/25)
-
78%
(14/18)
-
94%
(15/16)
C
Diony C. Lebot
100%
(25/25)
-
89%
(16/18)
-
100%
(16/16)
Johannes Herman Frederik
G. Umbgrove
100%
(25/25)
94%
(15/16)
-
94%
(16/17)
100%
(16/16)
C: Chair
M: Member
-: The Member does not participate in this Committee
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
191 | ANNUAL FINANCIAL REPORT
F7.
The Suitability and Nomination Policy for the Members of the Board of Directors and Key
Function Holders sets out the principles and the framework for the selection, appointment,
re-appointment and replacement of Members of the Board of Directors as well as th e
criteria to be used in the assessment. It also addresses the appointment and re-
appointment of the Key Function Holders of the Bank, i.e. the Chief Financial Officer, the
Chief Risk Officer, the Chief of Internal Audit and the Chief of Compliance.
The Policy is supplemented by the “Suitability and Nomination Process for the Members of
the Board of Directors”, which provides for the specific process to be followed mainly by
the CGSNC, to which accountability is attributed in this Policy.
The Policy complies with the legislative and regulatory framework in force, including the
relevant Joint ESMA/EBA “Guidelines on the assessment of the suitability of members of
the management body and key function holders” (hereinafter the “ESMA/EBA Guidelines”),
the Bank of Greece Executive Committee Act No. 224/21.12.2023 and the European Central
Bank (ECB) Guide to fit and proper assessments as well as with European best practices in
corporate governance.
The objectives of the Policy are to:
• Set general principles that provide guidance to the CGSNC and its Chair on selecting,
vetting and proposing candidates to the Board of Directors as well as on the
replacement and renewal of the Members of the Board of Directors.
• Provide criteria, including diversity criteria, for the selection and suitability assessment
of the Board of Directors candidates.
• Set criteria for the assessment of the ongoing individual suitability of the Members of
the Board of Directors as well as of the collective suitability of the Board of Directors.
• Set criteria for the selection and the appointment of Key Function Holders.
• Establish a transparent, effective and time-efficient suitability assessment and
nomination process.
• Set out the communication channel with the competent authorities (i.e. Bank of
Greece, ECB).
• Set out how the assessment is documented.
The Policy and its implementation are monitored and reviewed annually by the CGSNC and
approved by the Board of Directors and in case amendments are material they are
submitted for approval to the General Meeting of Shareholders. The Policy and every
material amendment thereto enters into force from the approval thereof by the General
Meeting of Shareholders. Material are the amendments that provide for derogations or
significantly change the content of the said Policy in particular as to the applied general
principles and criteria. Any changes thereto are approved by the Board of Directors upon
proposal of the CGSNC. In preparing, amending or reviewing the Policy, the CGSNC and the
Board of Directors shall take into account recommendations or findings of other Board
Committees and competent Functions, such as Legal Services, Human Resources or/and
Internal Control Functions. Internal Control Functions should provide effective input for
the review of the Suitability and Nomination Policy for the Members of the Board of
Directors and Key Function Holders in accordance with their roles. Notably, the Compliance
Function should analyze how the abovementioned Policy affects the Bank’s compliance
with legislation, regulations, internal policies and procedures and should report all
identified compliance risks and issues of non-compliance to the Board of Directors through
the CGSNC.
The CGSNC will propose candidates whom it deems suitable to become Members of the
Board of Directors according to the criteria set out in the applicable regulatory framework
and in this Policy. Suitability is determined in relation to the Policy’s criteria for candidates
(fit and proper and general suitability) and the current composition needs. For the purposes
of this Policy, it is defined as the degree to which an individual is deemed to have good
repute and to have, individually and collectively with the other Members of the Board of
SUITABILITY AND
NOMINATION POLICY FOR THE
MEMBERS OF THE BOARD OF
DIRECTORS AND KEY
FUNCTION HOLDERS
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
192 | ANNUAL FINANCIAL REPORT
Directors, adequate knowledge, skills and experience to perform his/her duties and a clear
understanding of the Bank’s culture, values and overall strategy. Suitability also covers the
honesty, integrity and independence of mind of each Member and his/her ability to commit
sufficient time to perform his/her duties.
Further to the above, where any Members of the Board of Directors do not fulfill the
requirements set out, the competent authorities, in the framework of the Single
Supervisory Mechanism, shall have the power to remove such Members from the Board of
Directors. The CGSNC, within the aforementioned context, shall consider the suitability of
the Members of the Board of Directors on a periodic basis, utilizing Board Review
assessments and any other pertinent information available.
In order to be considered as a suitable candidate by the Board of Directors and its CGSNC,
the prospective nominee must: meet the fit and proper requirements, meet individual and
collective suitability requirements, have no systematic conflict of interests with the Bank,
have no impediments according to the relevant legislation and be able to devote sufficient
time to the Board of Directors. All nominees must submit a declaration that they meet the
relevant requirements.
F8.
The Bank considers the high quality of its Non-Executive and Independent Non-Executive
Members of the Board of Directors as a fundamental element of its culture and long-term
performance, since good succession planning:
• ensures a continuous process to identify suitable candidates who are ready to take
over when Members leave the Board on various occasions;
• achieves continuity to deliver strategic plans by aligning the Bank’s human resources
with business planning;
• demonstrates a commitment to recruiting and promoting high-performing Members.
The Policy and Process for the Succession Planning of Non-Executive and Independent Non-
Executive Members of the Board of Directors sets out the framework for the succession
planning of the aforementioned Members. It is in line with the Greek and the European
regulatory requirements and best practice standards, including, among others, the Basel
Committee Corporate Governance Principles for Banks, the Bank of Greece Executive
Committee Act No. 224/21.12.2023, which incorporates the Joint ESMA /EBA Guidelines on
the assessment of the suitability of members of the management body and key function
holders, as in force, as well as the Hellenic Corporate Governance Code.
The succession planning for the Non-Executive and Independent Non-Executive Members
of the Board is also governed by the “Suitability and Nomination Policy for the Members of
the Board of Directors and Key Function Holders”.
The Policy and Process for the Succession Planning of Non-Executive and Independent Non-
Executive Members of the Board of Directors is validated during a succession planning
meeting that concludes with the identification of successors, after a thorough discussion
and analysis which, apart from the “Suitability and Nomination Policy for the Members of
the Board of Directors and Key Function Holders” and the findings of the annual evaluation,
also takes into account the candidates’ level of readiness and pote ntial.
The Policy aims at ensuring each time the smooth and efficient operation of the Board of
Directors of the Bank.
In particular, the objectives of the Policy are to:
• Ensure the implementation of the Bank’s strategy regarding leadership;
• Ensure organizational sustainability through leadership continuity;
POLICY AND PROCESS FOR THE
SUCCESSION PLANNING OF
NON-EXECUTIVE AND
INDEPENDENT NON-
EXECUTIVE MEMBERS OF THE
BOARD OF DIRECTORS
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
193 | ANNUAL FINANCIAL REPORT
• Strengthen the confidence of Investors, Regulators, Employees and other Stakeholders
in the Bank’s ability to safeguard and promote organizational continuity;
• Establish principles, processes and role clarity to support smooth leadership
transitions;
• Mitigate the risks that may arise from disorderly changes in the smooth operation of
the Board;
• Ensure diversity and appropriate gender representation within the Board;
• Ensure that the principle of equal opportunities is respected when implementing the
succession planning process;
• Provide guidance to the Board and to the CGSNC on the succession planning process of
the Bank’s Non-Executive and Independent Non-Executive Members in order to ensure
their smooth and proper succession based on the Bank’s Succession Policy and the
Suitability and Nomination Policy for the Members of the Board of Directors and Key
Function Holders as well as the respective legal and regulatory framework;
• Identify the competency requirements of key positions and assess potential
candidates;
• Identify and nominate suitable candidates to fill vacancies which occur.
Succession planning does not constitute a process of automatic nomination of identified
successors when actual vacancies occur. It is, however, a key input to the selection process.
Succession plans may be activated under (a) medium-term planning for the orderly
replacement of current Non-Executive Members and/or Independent Non-Executive
Members and (b) contingency planning for sudden and unforeseen events.
The Chair of the Board of Directors is actively involved in the succession planning, in
collaboration with the CGSNC and the Human Resources of the Bank. The CGSNC may
request the assistance of an external specialist consultant, if deemed necessary.
F9.
With the support of the CGSNC, the Board of Directors annually assesses its effectiveness
and that of its Committees.
From time to time and at least once every three years, the Board of Directors may appoint
external consultants to facilitate a more in-depth review of its effectiveness.
EVALUATION OF THE BOARD
OF DIRECTORS
F10.
Following the recent evaluation of the Board of Directors, an in-depth assessment of our
collective suitability has been conducted. This assessment focuses on our collective
knowledge, skills and experience, in accordance with the ESMA/EBA Guidelines, with the
support of the CGSNC.
Each Board Member engaged in this process by completing an Individual Self-Assessment
questionnaire, designed around the criteria specified in the Bank of Greece Executive
Committee Act Νο. 224/21.12.2023, which incorporates the joint ESMA/ EBA Guidelines on
the assessment of the suitability of members of the management body and key function
holders, as in force. The Chair of the Board of Directors has meticulously reviewed these
self-assessments and has compiled the Collective Suitability Matrix, taking into account
various critical aspects such as governance, risk management, compliance, audit,
management, strategy, decision-making, basic theoretical knowledge and past experience.
Based on the approved Collective Suitability Matrix, it has been resolved that our Board will
be enriched with the addition of individuals with C-suite banking experience, knowledge of
the markets the Bank operates in and global markets as well as further expertise in IT and
digital transformation. The Bank plans to fill the vacant Board positions, taking into account
the abovementioned areas.
ASSESSMENT OF THE BOARD
MEMBERS’ COLLECTIVE
SUITABILITY BASED ON THE
ESMA/EBA GUIDELINES
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
194 | ANNUAL FINANCIAL REPORT
F11.
The Independent Non-Executive Members of the Board of Directors should fulfill all the
criteria for being Independent Non-Executive Members, in accordance with the Bank of
Greece Executive Committee Act No. 224/21.12.2023, the relevant ESMA/EBA Guidelines,
the CGSNC Charter, with Law 4706/2020 on Corporate Governance as well as with the
Hellenic Corporate Governance Code of the Hellenic Corporate Governance Council.
The fulfillment of the legal requirements as to the classification of a Member of the Board
of Directors as an Independent Μember is reviewed by the Board of Directors at least on an
annual basis per fiscal year and in any case prior to the publication of the Annual Financial
Report which includes the relevant assertion. In particular, this review took place during
the Board of Directors’ meeting of 26.2.2026.
As part of our compliance requirements, the Independent Non-Executive Members are
requested annually to complete and sign a Declaration affirming that they meet all criteria
for being Independent Non-Executive Members. In addition, the Corporate Secretariat and
Governance Policies Business Area has established a process to ensure these criteria are
met. This includes also obtaining copies of the Members’ criminal records on a quarterly
basis.
In December 2025, in accordance with the internal process and procedures that involve,
inter alia, a review by the competent Business Areas of the independence criteria,
collection of all relevant Declarations by the Independent Non-Executive Members as well
as assessment of all relevant information and data, the independence of the Members of
the Board of Directors has been confirmed , under the coordination of the Corporate
Secretariat and Governance Policies Business Area.
Our Board of Directors, with the support of the CGSNC and taking into consideration the
above, has reviewed the independence criteria and confirmed that the Independent Non-
Executive Members, namely Dimitris C. Tsitsiragos, Elli M. Andriopoulou, Aspasia F.
Palimeri, Panagiotis I.-K. Papazoglou, Jean L. Cheval, Elanor R. Hardwick, Diony C. Lebot and
Johannes Herman Frederik G. Umbgrove, fulfill all the criteria for being Independent Non-
Executive Members of the Board of Directors. This confirmation is in accordance with Law
4706/2020 on corporate governance, the Bank of Greece Executive Committee Act No.
224/21.12.2023, the Articles of Incorporation and the Hellenic Corporate Governance Code,
as in force.
ANNUAL CONFIRMATION OF
THE MEMBERS’
INDEPENDENCE
F12.
12.1 Induction and Training Policy and Procedure for the Members of the Board of
Directors
The Induction and Training Policy and Procedure for the Members of the Board of Directors
sets out the principles and the approach for the induction and training programs addressed
to the Members of the Board of Directors, in accordance with the legislative and regulatory
framework in force, including the relevant Joint ESMA/EBA Guidelines, the Bank of Greece
Executive Committee Act No. 224/21.12.2023 and European best practices in corporate
governance.
The Policy applies to the Members of the Board of Directors individually and/or collectively.
The objectives of the induction and training programs provided to the Board of Directors
are:
• to facilitate the Board of Directors’ clear understanding of the relevant laws and
regulations, the Bank’s structure, business model, risk profile and governance
arrangements as well as the role of the Member(s) within them;
INDUCTION AND TRAINING
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195 | ANNUAL FINANCIAL REPORT
• to facilitate the Board of Directors’ clear understanding of the international, European
and national economic and regulatory developments in the financial sector and their
impact on the Bank;
• to promote the Board of Directors’ awareness regarding the benefits of diversity in the
Board of Directors and the Bank;
• to improve the skills, knowledge or competence of the Members of the Board of
Directors to fulfill their responsibilities on an ongoing or on an ad hoc basis;
• to provide relevant general and, as appropriate, individually-tailored training
programs.
The Policy is approved by the Board of Directors and is reviewed every two years by the
CGSNC, which may propose relevant amendments to the Board of Directors.
12.2 Induction and Training Programs for the Members of the Board of Directors
All the newly-appointed Members of the Board of Directors receive key information one
month after taking up their position at the latest and the induction should be completed
within six months. For this purpose, the Bank offers to all the new Members of the Board of
Directors an induction program on:
• The Bank’s structure, business model, risk profile and governance arrangements;
• Legal and regulatory requirements in relation to the Bank and the services it provides;
• The role of the Board Members;
• Corporate Governance principles;
• Risk Management, Compliance and Internal Audit;
• Wholesale and Retail Banking;
• Wealth Management and Treasury;
• External Statutory Audit;
• Capital Adequacy, Financial and Accounting Services;
• Credit Risk and Non-Performing Exposures (NPEs);
• ESG, Sustainability and Non-Financial Information;
• Information Technology and Security;
• Human Resources;
• International Network;
• Digitalization;
• Transformation;
• Strategic Planning.
Additionally, the Bank, in the framework of the continuous training of the Members of the
Board of Directors, provides informative and/or training sessions to all of them as well as
the possibility to attend relevant informative and/or training seminars and meetings on the
abovementioned or on other topics concerning the financial sector and the Bank. The
training should place emphasis on conceptual and strategic issues, focusing on new
developments and on their potential impact on the Bank.
The CGSNC sets an annual training – informative schedule. The annual training plan is kept
up to date, taking into account the Board suitability assessment, governance, strategy and
other relevant changes as well as changes in the applicable legislation and in market
developments. Furthermore, the annual training plan and/or the informative schedule for
the Board of Directors shall include separate sessions for the Executive and the Non-
Executive Members, taking into account their roles and tasks, and, where appropriate,
sessions for particular positions according to their specific responsibilities and involvement
in the Board Committees.
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196 | ANNUAL FINANCIAL REPORT
The Board of Directors, following a relevant recommendation by the CGSNC, approved the
2026 annual training plan – informative schedule for the Members of the Board of Directors
at its meeting held in September 2025.
Throughout 2025, the following training programs (informative sessions) took place:
The Bank also provides its Board Members with the
opportunity to participate in training and education al
sessions offered by external institutions. Upon request by
any Member, the Bank may offer tailor-made programs
to further enhance the Members’ knowledge and
competences.
During 2025, certain Board Members attended individual training programs, such as:
Training Program
Company
Banking Governance High-Level
Seminar “Board of the Future”
European Central Bank (ECB), jointly with
the Florence School of Banking and
Finance of the European University
Institute (EUI)
Corporate Governance: Maximize
Your Effectiveness in the Boardroom
University of Pennsylvania (UPenn), The
Wharton School, Aresty Institute of
Executive Education
BoD Training
1. Strategic Oversight in a Dynamic Banking
Landscape
2. UNEP FI Climate Mitigation Journey
3. DORA - Third Party Risk Management
4. BCBS 239
5. Cybersecurity
6. AI in Banking
F13.
The Board has the authority to establish both permanent and ad hoc Committees to
support it in discharging its responsibilities effectively. While these Committees primarily
have an advisory role, they may also assume certain delegated authorities as determined
by the Board.
Each Committee operates under a dedicated Charter that outlines its composition, tenure,
functioning and responsibilities. Currently, there are four Committees at the Board level:
the Audit Committee, the Risk Management Committee, the Remuneration Committee and
the Corporate Governance, Sustainability and Nominations Committee.
Each Committee comprises no fewer than three Members, with the composition proposed
to the Board by the Corporate Governance, Sustainability and Nominations Committee
(CGSNC). This proposal takes into account the "Suitability and Nomination Policy for the
Members of the Board of Directors and Key Function Holders" as well as relevant legal and
regulatory frameworks. It is also important to note that all Committee Members of each
are Independent Non-Executive Members.
The primary focus of these Committees is to oversee policies, practices and procedures
within their respective areas of mandate, as detailed in the Charter of each Committee.
They also play a crucial role in preparing draft resolutions for approval by the Board of
Directors and submitting relevant briefings, reports, key information and recommendations
to the Board. Furthermore, the Committees report regularly to the Board about their work.
COMMITTEES OF THE BOARD
OF DIRECTORS
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197 | ANNUAL FINANCIAL REPORT
AUDIT COMMITTEE
The Committee has been established and operates in accordance with all applicable laws
and regulations. The Extraordinary General Meeting of Shareholders dated 12.6.2025
resolved on the amendment of the number and qualifications of the Members of the
Committee as per article 44 par. 1 case b) of Law 4449/2017, having taken into
consideration the resolution of the Bank’s Ordinary General Meeting of 27.7.2023,
pertaining to the type of the Committee, its term of office and the number and the
qualifications of its Members. The Committee currently constitutes a Committee of the
Board of Directors. The Board of Directors, at its meeting dated 13.6.2025, appointed the
Members of the Audit Committee, constituted into a body, and resolved that Mr.
Panagiotis I.-K. Papazoglou remain its Chair, in accordance with the provisions of article 44
par.1 case e) of Law 4449/2017, as in force, as per its previous resolution dated 24.7.2024.
The Members of the Committee at its resolution dated 13.6.2025, taking into account:
i. article 44 par. 1 case (g) of Law 4449/2017, as in force, which provides that at least
one Member of the Committee, who is independent of the Bank and possesses
adequate auditing and accounting knowledge and experience shall attend the
meetings of the Audit Committee relating to the approval of the Financial
Statements,
ii. the fact that Mr. Panagiotis I.-K. Papazoglou and Mr. Jean L. Cheval, who are
Independent Non-Executive Members, possess adequate auditing and accounting
knowledge and experience,
appointed both of them as Members of the Committee possessing adequate auditing and
accounting knowledge and experience and resolved that at least one of them shall attend
the Committee’s meetings relating to the approval of the Financial Statements. It is noted
that the Members of the Committee collectively possess adequate knowledge of the
banking sector and, in general, the required knowledge, skills and experience to adequately
discharge the Committee’s responsibilities.
Audit Committee Composition as of the date of publication of the 2025 Annual Report
Panagiotis I.-K. Papazoglou
Chair, Independent Non-Executive
Member since 24.7.2024
Member of the Committee from 27.7.2023
until 24.7.2024
Elli M. Andriopoulou
Independent Non-Executive Member
Member of the Committee since 22.7.2022
Jean L. Cheval
Independent Non-Executive Member
Member of the Committee from 29.6.2018
until 31.7.2020 and since 22.7.2022
Johannes Herman Frederik G. Umbgrove
Independent Non-Executive Member
Member of the Committee since 26.4.2018
2025
Number of Meetings
16
Average ratio of Members’ attendance
95%
Please also refer to section “F6. 2025 Board Members’ Individual Attendance Rates at
Meetings”.
The Committee convenes at least on a quarterly basis, adding meetings on an as-needed
basis. It may invite any Member of the Management or Executive as well as external
auditors to attend its meetings. The Chief of Internal Audit and the Chief of Compliance are
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
198 | ANNUAL FINANCIAL REPORT
regular attendees of the Committee meetings and have unhindered access to the Chair and
to the Members.
The main responsibilities of the Audit Committee include but are not limited to those
presented below.
The Committee:
• Performs the oversight of the financial reporting processes and procedures for drawing
up the Annual and the Interim Financial Statements of the Bank and its Subsidiaries as
well as the Sustainability Report, in accordance with the applicable accounting
standards.
• Reviews the annual Financial Statements of the Bank and its Subsidiaries, together
with the Statutory Auditors’ Report where applicable and the Board of Directors’
Annual Management Report, prior to their submission to the Board of Directors for
approval.
• Is informed of the evolution of significant accounting standards and oversees the
impact on accounting policies.
• Reviews the annual or multi-year audit plans and recommends their approval by the
Board of Directors.
• Reviews the periodic reports on the activity of the Internal Audit in the Bank and its
Subsidiaries and the recommendations identified in these reports.
• Reviews and endorses policies regarding the Internal Audit methodology of the Bank as
well as any amendments thereto and submits them for approval by the Board of
Directors.
• Reviews and endorses policies regarding the Compliance methodology of the Bank as
well as any amendments thereto and submits them for approval by the Board of
Directors.
• Informs the Board of Directors of the outcome of the statutory audit and explains how
the statutory audit contributed to the integrity of the financial reporting and what the
role of the Audit Committee was in that process.
• Assists the Board of Directors in ensuring the independent, objective and effective
conduct of internal and external audits.
• Assists the Board of Directors in overseeing the effectiveness and performance of the
Internal Audit Unit and of the Compliance Unit of the Bank and of the relevant Units
across the Group.
• Is responsible for the procedure followed for the selection of the Statutory Certified
Auditors of the Bank and its Subsidiaries and makes recommendations to the Board of
Directors on the appointment or dismissal, rotation, tenure and remuneration of the
Statutory Certified Auditors, according to the relevant regulatory and legal provisions.
• Monitors the independence and performance of the Statutory Certified Auditors in
accordance with the applicable laws, a responsibility which includes reviewing, inter
alia, the provision by them of Non-Audit Services to the Bank and its Subsidiaries. In
relation to this, the Committee examines and approves all proposals regarding the
provision by the Statutory Certified Auditor of Non-Audit Services to the Bank and its
Subsidiaries, based on the relevant Bank policy that the Audit Committee oversees and
recommends to the Board of Directors for approval.
• Monitors and assesses the adequacy, effectiveness and efficiency of the Internal
Control System of the Bank and its Subsidiaries, based on reports by the Internal Audit
Unit and by the Compliance Unit, on findings of the external auditors, the supervisors
and the tax authorities as well as management information, as appropriate.
• Evaluates the adequacy and effectiveness of the processes and procedures of the
Compliance Unit, based on the Annual Compliance Report, as per the regulatory
framework in force.
• Assesses the adequacy and effectiveness of the "Anti-Money Laundering and
Combating the Financing of Terrorism Policy" and of the respective procedures.
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The specific duties and responsibilities of the Audit Committee are set out in its Charter,
which is posted on the Bank’s website (https://www.alpha.gr/en/group/corporate-
governance/commitees).
The activities of the Audit Committee for the year 2025 are presented below.
During 2025, the Committee has been actively engaged in several key initiatives relating to
the Internal Control System, Internal Audit, Anti-Money Laundering (AML) and Regulatory
Compliance.
The Committee monitored the effectiveness of the Internal Control System of the Bank and
the Group, especially regarding financial and non-financial reporting. Furthermore, the
Committee endorsed the 2024 Report of the Internal Audit Function regarding the
evaluation of the Internal Control System and proposed its approval by the Board of
Directors, in order for it to be submitted to the Bank of Greece. The Committee also
approved and submitted an assessment report on the adequacy and effectiveness of the
Internal Control System of the Alpha Bank Group to the Bank of Greece.
The Committee also approved the scope of the assessment of the adequacy of the Internal
Control System for the years 2023-2025 by an External Auditor, as per the Bank of Greece
Executive Committee’s Act 243/7.7.2025, while it reviewed and endorsed for appr oval by
the Board of Directors the selection of the Audit Firm for the said assessment.
At a meeting held without the presence of the Management, the Committee confirmed the
independence of the Chief of Internal Audit. Additionally, it was informed of the quarterly
activity reports of the Internal Audit and Compliance Functions of the Bank.
The Committee endorsed the updated Internal Audit Charter, the Internal Audit
Methodology, the revised Annual Audit Plan (AAP) for the year 2025 as well as the Annual
Audit Plan for 2026 and submitted them for approval by the Board of Directors.
Additionally, the Audit Committee reviewed the Annual Report of the Compliance Function
for the year 2024, the Annual Report of the Compliance Function on Anti-Money
Laundering (AML) and Combating the Financing of Terrorism (CFT) for the year 2024, as
well as the Independent Assessment Report regarding the custody of Alpha Bank customer
assets and submitted them to the Board of Directors for information. The Committee took
cognizance of the Compliance Risk Assessment of the Bank and the consolidated Group
Compliance Risk Assessment for the year 2025. Furthermore, the Committee endorsed the
Annual Plan and objectives of the Compliance Unit for 2026, including the Group Data
Protection Officer (DPO)’s Objectives, the Compliance Framework and the Organizational
Structure of the Compliance Unit and submitted them for approval by the Board of
Directors.
Moreover, the Committee recommended to the Board of Directors the appointment of Mr.
E.A. Valetopoulos as the Money Laundering Responsible Officer (MLRO).
Finally, the 2025 goal setting and the 2024 annual assessment of the Chief of Internal Audit
and Chief of Compliance were performed by the Chair of the Audit Committee and agreed
with all Members of the Committee.
Financial Reporting Processes and Statutory Audit
The Committee monitored and reviewed the process and the conduct of the statutory audit
of the Financial Statements of the Bank and the Group. It informed the Board of Directors
of the relevant outcome and of the assurance of sustainability reporting, taking into
consideration, inter alia, the relevant reports submitted to the Committee by the Statutory
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200 | ANNUAL FINANCIAL REPORT
Certified Auditor. The Committee discussed how the statutory audit contributed to the
integrity of financial reporting as well as on the Committee’s role in the process, describing
any relevant actions it took.
During 2025, the Committee held several meetings with the Statutory Certified Auditor of
the Group (Deloitte). It reviewed the audit approach and monitored the Statutory Certified
Auditor’s overall activity and performance, and the Statutory Certified Auditors’ Audit Plan
for 2025 with reference, among others, to the planned audit approach, key audit matters
and risks, materiality, risk assessment and scope of the audit and received regular updates
on the progress thereof.
At a meeting without the presence of the Bank’s Management, the Committee confirmed
the independence and the objectivity of the Statutory Certified Auditor. The Committee
reviewed the annual evaluation of the Statutory Certified Auditor for the year 2024.
Additionally, the Committee, following its review and assessment, recommended to the
Board of Directors for approval the reappointment of Deloitte as the Statutory Certified
Auditor of the Group in order for the Board of Directors to propose them to the Ordinary
General Meeting as well as the relevant Statutory and Tax Audit fees for the year 2025 and
a follow-up on the 2024 Statutory and Tax Audit fees of the Alpha Bank Subsidiaries. It is
noted that the Ordinary General Meeting of the Bank held on 21.5.2025 approved the
reappointment of Deloitte for the audit of the Bank’s Standalone and Consolidated
Financial Statements for the period from 1.1.2025 to 31.12.2025.
Finally, in 2025 the Committee took cognizance of the process for the selection of the
Statutory Certified Auditor for the year 2027 and for a maximum period of ten years, as per
the Policy and Procedures for the Selection and Reappointment of the Statutory Auditor
and the applicable legal and regulatory framework. In this context, the Committee
examined the submitted presentations and concluded that two audit firms are eligible,
taking into consideration, among others, their competency and independence, an d
submitted its proposal to the Board of Directors, in order for the relevant assignment to be
submitted for approval to the Ordinary General Meeting of the Shareholders.
Financial Statements
During 2025, the Committee reviewed the annual Financial Statements of the Bank and the
Group for the year 2024 as well as the Financial Statements for the periods ended
31.3.2025, 30.6.2025 and 30.9.2025, the relevant Press Releases, the Statutory Certified
Auditors’ Audit Report according to article 10 of Regulation (EU) No 537/2014 and the
Additional Report according to article 11 of Regulation (EU) No 537/2014, prior to their
submission to the Board of Directors for approval.
According to the Independent Statutory Certified Auditors’ Report, the published
Standalone and Consolidated Financial Statements give a true and fair view, in all material
respects, of the financial position of Alpha Bank S.A. and the Group as at December 31,
2025, their financial performance and their cash flows for the year then ended in
accordance with the International Financial Reporting Standards, as endorsed by the
European Union.
The Additional Report provided by the Independent Statutory Certified Auditors to the
Committee, in accordance with article 11 of Regulation (EU) 537/2014 of the European
Parliament and of the Council of 16 April 2014 on specific requirements regarding statutory
audit of public interest entities and repealing Commission Decision 2005/909/EC,
highlighted, among others, the audit approach and the valuation methods, the materiality
level.
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Non-Audit Services
During 2025, the Committee examined and approved all the proposals regarding the
provision by the Statutory Certified Auditor of Non-Audit Services to the Bank and the
Group, based on the relevant Bank’s Policy and Procedures for the Assignment of Non-
Audit Services to the Statutory Auditor. Deloitte did not provide any non-permissible non-
statutory audit services.
Group Sustainability Policy/Environmental, Social and Governance (ESG)
The Committee took cognizance of the Limited Assurance Report on the Sustainability
Statement prepared by Deloitte for the year ended 2024. Moreover, the Committee
reviewed the Recommendations Report with regard to the Sustainability Report for the
year 2024 and took cognizance of a presentation on the Sustainability Statement 2025
under the Corporate Sustainability Reporting Directive (CSRD).
Governance and other Committee Activities
During 2025, in the context of the periodic review of the Group’s Policies, the Audit
Committee reviewed and revised the following policies and, if needed, it endorsed them
and proposed their approval by the Board of Directors: Market Abuse Prevention Policy and
Procedures, Compliance Policy, Anti-bribery and Corruption Policy, Customer Complaints
Management Policy, Whistleblowing Policy and Procedures, Policy on “Related Parties”
Transactions, Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT)
Policy, Policy on the Prevention of Conflict of Interests, Policy for the External Periodical
Assessment of the Internal Control Framework of Alpha Bank, Group Outsourcing Policy
and Policy and Procedures for the Selection and Reappointment of the Statutory Auditor.
Furthermore, the Committee endorsed the annual review of its Charter and recommended
its approval by the Board of Directors.
The Committee held several meetings with Executives from various Business Areas of the
Bank in order to review operational risk, cyber, IT and other issues.
The Committee was also updated on the Supervisory Review and Evaluation Process (SREP)
and the corresponding Action Plan according to the SREP 2025 Decision, as well as on the
preliminary outcome of the 2025 Supervisory Review and Evaluation Process (SREP)
Supervisory Dialogue. Moreover, the Committee was informed of the Operational Act
regarding the Compliance Function’s Organizational Structure sent by the European Central
Bank and of the Joint Supervisory Team (JST) Feedback on Alpha Bank’s Response to the
abovementioned Act.
In 2025, the Audit Committee conducted joint meetings with the Risk Management
Committee, the Remuneration Committee and the Corporate Governance, Sustainability
and Nominations Committee to discuss areas of common interest (cybersecurity and
remuneration issues).
Related Parties Transactions
In accordance with the Policy on “Related Parties” Transactions, the Committee reviewed
the outcome of the monitoring of all the Related Parties’ transactions of the Bank.
Monitoring activities of Group Audit Committees
To further enhance corporate governance and foster collaboration among our Subsidiaries,
the Committee holds meetings with the Audit Committees of the Subsidiaries. Specifically,
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
202 | ANNUAL FINANCIAL REPORT
the Audit Committee held meetings with the Audit Committees of Alpha Bank Cyprus Ltd
and Alpha Real Estate Services S.A.
The Committee also reviewed the Annual Activity Reports for 2024 and the Semi-Annual
Activity Report for 2025 prepared by the Audit Committees of the Subsidiaries.
The Committee has been established and operates in accordance with all applicable laws
and regulations. The Members of the current Risk Management Committee were appointed
by a resolution of the Board of Directors of 12.12.2024.
Risk Management Committee Composition as of the date of publication of the 2025
Annual Report
Jean L. Cheval
Chair, Independent Non-Executive Member
Chair of the Committee since 22.7.2022
Member of the Committee from 31.7.2020 until 22.7.2022
Aspasia F. Palimeri
Independent Non-Executive Member
Member of the Committee since 22.7.2022
Elanor R. Hardwick
Independent Non-Executive Member
Member of the Committee since 22.7.2022
Diony C. Lebot
Independent Non-Executive Member
Member of the Committee since 27.7.2023
2025
Number of Meetings
18
Average ratio of Members’ attendance
92%
Please also refer to section “F6. 2025 Board Members’ Individual Attendance Rates at
Meetings”.
The Committee convenes at least on a quarterly basis and may invite any Member of the
Management or Executive to attend its meetings. The Chief Risk Officer (CRO) is a regular
attendee of the Committee meetings and has unhindered access to the Chair and the
Members. The CRO, while administratively reporting to the Chief Executive Officer (CEO),
shall report functionally to the Board of Directors through the Committee.
The main responsibilities of the Risk Management Committee include but are not limited to
those presented below.
The Committee:
• Assists the Board of Directors in promoting a sound risk culture at all levels throughout
the Bank and its Subsidiaries, fostering risk awareness and encouraging open
communication and challenge across the Organization.
• Reviews regularly and recommends to the Board of Directors for approval the risk and
capital management strategy, ensuring alignment with the business objectives of the
Bank and the Group.
• Reviews and recommends annually to the Board of Directors for approval the Banking
Group’s Risk Appetite Framework (RAF) and risk appetite statement, considering also
Environmental, Social and Governance (ESG) risks, i.e. the risks of any negative
financial impact on the Bank, stemming from the current or prospective impacts of ESG
factors on its counterparties, such as climate-related risks, and ensuring alignment with
the Group’s strategic objectives and capital allocation.
RISK MANAGEMENT
COMMITTEE
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203 | ANNUAL FINANCIAL REPORT
• Determines the principles which govern risk management across the Bank and the
Group in terms of the identification, measurement, monitoring, control and mitigation
of risks.
• Εnsures that the Group’s strategy, budget process, capital and liquidity planning and
remuneration framework are aligned with the RAF and that the Bank adequately
embeds ESG risks in the overall risk appetite statement and framework, business
strategy and risk management framework.
• Recommends to the Board of Directors for approval Bank-wide and Group-wide high-
level policies on the management of credit, market, liquidity, operational, reputational
and other risks, including but not limited to the provisioning and the write-off policies.
It also reviews policies potentially affected by ESG risks, including the (credit) policies
for each sector and product.
• Monitors that the Bank adequately embeds ESG risks in the overall risk appetite
statement and framework, business strategy and risk management framework.
• Evaluates, on an annual basis or more frequently, if necessary, the appropriateness of
risk identification and measurement systems, methodologies and models, including the
capacity of the Bank’s IT infrastructure to record, report, aggregate and process risk-
related information.
• Reviews the Group’s Annual Internal Capital Adequacy Assessment Process
(ICAAP)/Internal Liquidity Adequacy Assessment Process (ILAAP) and the related target
ratios and recommends their approval to the Board of Directors.
• Assesses the overall effectiveness of capital planning, allocation processes and systems
and the allocation of capital requirements to risk types.
• Keeps itself informed of recent regulatory developments, emerging supervisory
expectations, the results of supervisory requests and the Supervisory Review and
Evaluation Process (SREP) conclusions.
• Collaborates with the Corporate, Governance, Sustainability and Nominations
Committee and the Audit Committee, as necessary, on the effective oversight of the
mitigation of certain key areas of risk, including climate-related or other ESG risks and
capital management as well as their repercussions on the Internal Control System. The
Committee also convenes jointly with the Audit Committee to discuss and review
issues relevant to the remediation plans associated with regulatory/supervisory
assessments and certain operational risk or other issues of importance and common
interest.
All Members of the Committee have prior experience in the financial services sector and,
individually and collectively, appropriate knowledge, skills and expertise regarding risk
management and control practices.
The specific duties and responsibilities of the Risk Management Committee are set out in its
Charter, which is posted on the Bank’s website (https://www.alpha.gr/en/group/corporate-
governance/commitees).
The activities of the Risk Management Committee for the year 2025 are presented below.
During 2025, the Risk Management Committee discussed, challenged and endorsed, among
others, several key initiatives, as follows:
The Committee reviewed on a monthly basis the progress made with regard to credit risk,
non-financial risks, market and liquidity risk as well as supervisory issues. Furthermore, the
Committee reviewed the Risk Management Committee Procedure and agreed on providing
semi-annual feedback through a dedicated discussion item included in the Committee’s
Agenda, also providing feedback οn the Monthly Risk Management Report.
Notably, it reviewed the updated Non-Performing Exposures (NPEs) Reduction Plan for
2025 and resolved to submit it to the Board of Directors for approval. Moreover, it was
updated, on a quarterly basis, on the performance of the Plan, while it was informed on a
regular basis about the progress of the Step-Up Campaign and its results.
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204 | ANNUAL FINANCIAL REPORT
The Committee also examined the annual Risk Management Report and the Assessment
Report of the Risk Management Function for the year 2024 and proposed to the Board of
Directors their approval for submission to the Bank of Greece.
Moreover, the Committee endorsed the Bank’s proposals to increase/amend the
concentration limits of specific Wholesale Banking names and recommended the respective
amendments to the Concentration Risk and Credit Threshold Policy, which was submitted
for approval by the Board of Directors. The Committee also reviewed and endorsed
amendments to the International Syndication Policy and the Name Concentration Risk
Policy, the updated Wholesale Banking Credit Policy, the Group Loan Default Classification
Policy and the Group Loan Impairment Policy as well as amendments to the Credit and the
Arrears Committees Acts, the updated Credit Policy Manuals, i.e. the International Network
Wholesale Banking Credit Manual, the Retail Banking Credit Policy – Small Businesses, the
Housing and Consumer Credit Policy, the updated Shareholder Remuneration Policy and
the Group Outsourcing Policy and recommended their approval by the Board of Directors.
Furthermore, the Risk Management Committee was updated on the Non-Financial Risks
Annual Profile, while it discussed and recommended for approval by the Board of Directors
the General Cybersecurity and Information Security Policy, the ICT and Security Risk
Management Policy, the Strategy on ICT Third-Party Risk, the Policy on Arrangements
regarding the Use of ICT Services Provided by ICT Third-Party Service Providers, the ICT
Third-Party Risk and Outsourcing Committee Act as well as the ICT Third-Party Risk and
Outsourcing Support Committee Act, the Operational Resilience Policy and the Business
Continuity Management Policy, as well as on several outsourcing issues, i.e. the periodic
review of Key Performance Indicators (KPIs) for monitoring the performance of critical and
non-critical outsourcing arrangements and the outsourcing risk assessment result.
The Committee also endorsed various Management Committees’ Acts, including the Assets
– Liabilities Management Committee (ALCo), the Credit Risk Committee, the Non-Financial
Risks and Internal Control Committee, the Real Estate (RE) Committee I, the Reputational
Risk Committee, the Supervisory and Resolution Projects Committee and the Data
Governance and Quality Committee, and resolved to propose their approval by the Board
of Directors.
Additionally, the Risk Management Committee further reviewed and recommended
updates to the Data Governance and Quality Strategy and the related Policies and
Frameworks, i.e. the Data Governance Framework (DGF), the Finance and Risk Reporting
Framework (FRRF) and the Risk Data and Aggregation Risk Reporting (RDARR) Validation
Framework, as well as to the Data Definition Policy, the Data Criticality Policy, the Data
Quality Policy, the Data Architecture Policy, the DGF Monitoring and Amendment Policy
and the End User Computing (EUC) Policy, and resolved to propose their approval by the
Board of Directors.
The Risk Management Committee also reviewed the monthly Credit Committee I approvals
for Wholesale Loans, the Commercial Real Estate Portfolio and the Assets-Liabilities
Management Committee (ALCo) quarterly activities.
The Risk Management Committee discussed the Chief Risk Officer’s (CRO) performance for
2024 and reviewed and approved the CEO’s evaluation of the CRO as well as the CRO
Scorecard for 2025. Further, following a relevant discussion with the CGSNC, it endorsed
the recommendation regarding the CRO succession, proposing the appointment of Mr. K.
Sarafopoulos as CRO by the Board of Directors.
The Risk Management Committee was also informed of and discussed several significant
topics, such as the update of the Interest Rate Risk arising from Non-Trading Book Activities
and the Credit Spread Risk arising from Non-Trading Book Activities.
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It was updated on the preliminary outcome of the Supervisory Dialogue in the context of
the 2025 Supervisory Review and Evaluation Process (SREP), the draft and the final SREP
Decision and the Action Plan addressing the items highlighted in the SREP 2025 Decision.
The Committee was also updated on the progress made regarding the On-Site Inspections
(OSI) on Retail and IT.
The Committee endorsed the 2025 Group Internal Capital Adequacy Assessment Process
(ICAAP) and the Group Internal Liquidity Adequacy Assessment Process (ILAAP) Reports as
well as the submission of the Capital Adequacy Statement (CAS), the Liquidity Adequacy
Statement (LAS), the updated 2025 Recovery Plan, the Risk and Capital Strategy (RCS) for
2025 and the updated Risk Appetite Framework (RAF) for 2025 and resolved to submit
them to the Board of Directors for approval. Moreover, the Committee reviewed the Risk
and Capital Strategy (RCS) and Recovery Plan (RP) Dashboard on a quarterly basis and the
final EU-wide 2025 Stress Test results and resolved to submit them to the Board of
Directors.
Moreover, the Committee reviewed the Non-Financial Risks, focusing on the areas of
Information and Communication Technology (ICT), Compliance, Conduct and Data, and
covered the evolution of various other risk types, including credit, market, liquidity, climate
and ESG and data risks, also reviewing capital adequacy and supervisory issues on a regular
basis. It also endorsed the Pillar III Supervisory and ESG Disclosures Report for the First Half
of 2025 and resolved to submit it to the Board of Directors for approval.
Additionally, the Basel Committee on Banking Supervision’s (BCBS) standard 239 Action
Plan and the RDARR Validation Reports were discussed on a regular basis. Furthermore, in
the context of the BCBS 239, the Members of the Committee were informed about the
Timeliness Review and the Improvement Framework for Statutory and FinRep Reporting
and endorsed the updated Financial Reporting Policy (FinRep), which they resolved to
submit for approval by the Board of Directors.
Moreover, the Committee reviewed and endorsed the action plan regarding the OSI on
Commercial Real Estate and the OSI on New Lending and recommended their approval by
the Board of Directors, while it was updated on the draft report regarding the OSI on
RDARR as well as on the relevant draft Recommendation Letter.
The Risk Management Committee discussed and was updated on the Digital Operational
Resilience Act (DORA) Compliance Program and the DORA action plan as well as on
Cybersecurity and IT issues on a regular basis. It also endorsed the Information and
Communications Technology (ICT) Response and Recovery Plans, the ICT Business
Continuity Plans, the updated 2025 Recovery Plan of Alpha Bank Group, as well as the Real
Estate Plan for the year 2026 and resolved to submit them for approval by the Board of
Directors.
During 2025, a joint meeting of the Risk Management Committee and the Audit Committee
was held in order to review areas of common interest related to cybersecurity.
Lastly, the Risk Management Committee reviewed the Annual Activity Reports for 2024 and
the Semi-Annual Activity Reports for 2025 which were prepared by the Risk Management
Committees of the major Subsidiaries.
REMUNERATION COMMITTEE
The Committee has been established and operates in accordance with all applicable laws
and regulations. The Members of the current Remuneration Committee were appointed
by a resolution of the Board of Directors of 27.2.2025.
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Remuneration Committee Composition as of the date of publication of the 2025
Annual Report
Dimitris C. Tsitsiragos
Independent Non-Executive Member
Chair of the Committee from 27.7.2023 until 27.2.2025
Member of the Committee from 31.7.2020 until
27.7.2023 and since 27.2.2025
Aspasia F. Palimeri
Independent Non-Executive Member
Chair of the Committee since 27.2.2025
Member of the Committee from 22.7.2022 until
27.2.2025
Panagiotis I.-K. Papazoglou
Independent Non-Executive Member
Member of the Committee since 27.7.2023
Johannes Herman Frederik G.
Umbgrove
Independent Non-Executive Member
Member of the Committee since 26.4.2018
Mr. Efthimios O. Vidalis was a Member of the Committee until 27.2.2025
The Committee convenes at least on a quarterly basis and may invite any Member of the
Management or Executive to attend its meetings. The Chief Human Resources Officer is a
regular attendee of the Committee meetings.
2025
Number of Meetings
17
Average ratio of Members’ attendance
99%
Please also refer to section “F6. 2025 Board Members’ Individual Attendance Rates at
Meetings”.
The main responsibilities of the Remuneration Committee include but are not limited to
those presented below.
The Committee:
• Assists the Board of Directors in ensuring that the Group Remuneration Policy is
consistent with the values, culture, business strategy, risk appetite and strategic
objectives of the Bank and its Subsidiaries, taking into account Environmental, Social
and Governance (ESG) risks that affect the business environment in the short,
medium or long-term.
• Is responsible for the preparation of decisions on remuneration to be taken by the
Non-Executive Members, in particular regarding the remuneration of the Executive
Members of the Board of Directors as well as of other identified Staff (i.e. Staff whose
professional activities have a material impact on the Institution’s risk profile).
• Provides its support and advice to the Non-Executive Members of the Board of
Directors on the design of the Remuneration Policy for the Bank and the Group,
including that such remuneration policy is gender-neutral according to the relevant
legislative and regulatory provisions, supports the equal treatment of Staff, promotes
inclusiveness and respects diversity in general.
• Recommends to the Non-Executive Members the remuneration of the Non-Executive
Members of the Board of Directors.
• Reviews and advises on fixed salaries, benefits and total fixed remuneration within
the Bank.
• Reviews the variable remuneration framework. Recommends to the Board of
Directors for approval variable remuneration schemes for Employees across the Bank
and the Group and proposes the total envelope for variable remuneration across the
Bank and the Group.
• Reviews the performance of the Executive Members of the Board of Directors (the
“Executive Members”), the Chiefs – Members of the Executive Committee and the
Key Function Holders (the “KFHs”) of the Bank, based on the input that it receives
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from the evaluators, in accordance with the provisions of the Bank’s “Policy for the
Evaluation of Senior Executives and Key Function Holders”.
• Validates the Evaluation Scorecards and the goals of the Executive Members of the
Board of Directors, the Chiefs – Members of the Executive Committee and the KFHs.
• Ensures that adequate policies and processes for the regular performance evaluation
of Senior Executives and Key Function Holders of the Bank and of the Group Staff are
in place, adequately implemented and in alignment with the Group’s Remuneration
Policy and the Human Resources policies and processes (including staff succession
planning and talent management systems).
The Members of the Committee collectively have appropriate knowledge, skills and
professional experience concerning remuneration policies and practices, risk
management and control activities as well as concerning the incentives and risks that can
arise therefrom. At least one Member has sufficient professional experience in risk
management.
The specific duties and responsibilities of the Remuneration Committee are set out in its
Charter, which is posted on the Bank’s website
(https://www.alpha.gr/en/group/corporate-governance/commitees).
The activities of the Remuneration Committee for the year 2025 are presented below.
During 2025, the main activities of the Committee, among others, were the following:
Remuneration Policies and Frameworks
The Committee reviewed and recommended for approval to the Board of Directors the
Remuneration Policy for Alpha Bank and the other Companies of the Banking Group along
with its Annexes and the Remuneration Report as per Law 4548/2018 as well as the
Remuneration Policy of the Members of the Board of Directors as per Law 4548/2018. It
was also updated on the definition of the Particularly High Amount of Variable
Remuneration. It endorsed amendments to the Stock Award Plan Regulation, supported
the continuation of the Company’s Stock Award Plan in accordance with Law 4548/2018
and recommended their approval to the Board of Directors. Additionally, the Committee
recommended to the Board of Directors the approval of the increase of the maximum
ratio between the fixed and variable components of remuneration as well as the approval
of the distribution of part of the Bank’s profits to the Bank’s Staff as a reward for their
contribution to the Bank’s profitability and objectives.
Moreover, the Committee reviewed and endorsed the Expenses Policy for the Non-
Executive Members of the Board of Directors as well as the remuneration of the
Non‑Executive Board Members.
Governance, Oversight and Regulatory Alignment
The Remuneration Committee reviewed the list of Material Risk Takers (MRTs) for 2024
and the updated list of 28.2.2025 and recommended their approval by the Non-Executive
Members of the Board of Directors.
Moreover, the Committee reviewed the Policy for the Evaluation of Senior Executives and
Key Function Holders and provided input to the CGSNC, its Charter and recommended its
approval by the Board of Directors. Moreover, it endorsed the Action Plan for the SSM
Thematic Review on Risk Culture and Incentives.
The Committee was also updated on the Audit Report on the Remuneration Policy and
the Pillar III Remuneration Disclosures.
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It also reviewed and endorsed a Healthcare Plan for the Non-Executive Members of the
Board of Directors.
Moreover, the Committee held a joint meeting with the CGSNC regarding engagement
with investors in preparation for the Ordinary General Meeting of 2026.
Lastly, it reviewed its Annual Activity Report and submitted it to the Board of Directors for
information.
Human Resources Strategy, Talent Development and Remuneration Issues
The Committee was updated on key Human Resources initiatives, including Career
Pathing, the Talent Identification Program, the new Onboarding Plan, the Internal
Mobility Framework, the Learning Strategy, the Alpha Performance Dialogue (APD) 2024
Results, the 2024 Annual Increases and the 2024 Remuneration Review (Actual versus
Budget). Moreover, it was presented with a Time Plan Review for the Combined
Remuneration Cycle.
The Committee reviewed and endorsed the 2024 Combined Bonus Plan (CBP) Allocation,
the Profit Distribution final allocation and the CBP award to the Senior Leadership Team
(SLT). Moreover, it approved the Sales Incentive Program (SIP) Branch Network Targets, it
reviewed and endorsed the SIP 2025 Framework, the 2024 SIP Final Bonus Allocation for
Branch employees and recommended the approval of conditional bonus allocations for
the Fourth Quarter of 2024, and the three Quarters of 2025 to the Board of Directors. It
was informed for the 2024 CBP Final Distribution.
The Committee reviewed and endorsed the Total Cash Strategy for Band D and below
(salary and variable remuneration) as well as the Senior Leadership Team (SLT) variable
remuneration ranges and recommended their approval by the Board of Directors.
Moreover, the Committee validated the 2025 Scorecards for Senior Executives and Key
Function Holders as well as their 2024 evaluation.
Subsidiary Coordination and Joint Governance
In its continuous effort to enhance corporate governance and to foster stronger
collaboration among Subsidiaries, the Remuneration Committee has initiated a series of
videoconference meetings with the Remuneration Committees of Subsidiaries. As part of
this initiative, it has already held joint meetings with the Remuneration Committee of
Alpha Bank Cyprus (ABC) Ltd as well as with the Remuneration and Nomination
Committee of Alpha Real Estate Services S.A.
Moreover, the Committee reviewed the 2024 Annual Activity Reports and the 2025
Semi‑Annual Activity Reports of the Remuneration Committees of Alpha Bank London
(ABL) Ltd, Alpha Bank Cyprus (ABC) Ltd and Alpha Real Estate Services S.A.
Additionally, the Committee has been updated on various remuneration issues
concerning the Bank’s Subsidiaries.
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The Committee has been established and operates in accordance with all applicable laws
and regulations. The Members of the current Corporate Governance, Sustainability and
Nominations Committee were appointed by a resolution of the Board of Directors of
27.2.2025.
Corporate Governance, Sustainability and Nominations Committee Composition as of
the date of publication of the 2025 Annual Report
Elanor R. Hardwick
Chair, Independent Non-Executive Member
Chair of the Committee since 30.9.2021
Member of the Committee from 31.7.2020 until 30.9.2021
Elli M. Andriopoulou
Independent Non-Executive Member
Member of the Committee since 22.7.2022
Diony C. Lebot
Independent Non-Executive Member
Member of the Committee since 27.7.2023
Johannes Herman Frederik
G. Umbgrove
Independent Non-Executive Member
Member of the Committee since 26.4.2018
Mr. Efthimios O. Vidalis was a Member of the Committee until 27.2.2025
Please also refer to section “F6. 2025 Board Members’ Individual Attendance Rates at
Meetings”.
The Committee convenes at least on a quarterly basis and may invite any Member of the
Management or Executive to attend its meetings.
The main responsibilities of the Corporate Governance, Sustainability and Nominations
Committee include but are not limited to those presented below.
The Committee:
• Is regularly informed of current trends and developments in the areas of banking and
corporate governance, including best practice and relevant regulations.
• Monitors the compliance of the Bank and the Group with the pertinent Hellenic
Corporate Governance Code to which the Bank adheres, ensuring appropriate
application of the “comply or explain” principle required; provides oversight that the
implementation of this principle aligns with the legislation in force, the regulatory
expectations and the international corporate governance best practice.
• Reviews the Bank's Internal Governance Regulation and recommends its approval by
the Board of Directors.
• Facilitates the regular review of the Charters of the Board Committees, in consultation
with the relevant Committees, by providing input to each Committee in order to ensure
that the Charters remain fit-for-purpose and align with the Hellenic Corporate
Governance Code as well as with corporate governance best practices.
• Reviews, at least semi-annually, current and emerging trends and regulatory
developments in ESG issues that may significantly affect the Bank’s activities, pointing
out to the Board of Directors areas that may require actions.
• Oversees the implementation of the Bank’s policies on ESG issues.
• Acts as the ultimate liaison/responsible Board Committee with respect to all
sustainability/ESG issues and promotes respective communications and feedback from
all the Board of Directors Committees.
• Assists the Board of Directors in establishing the conditions required for effective
succession and continuity in the Board of Directors.
• Develops and regularly reviews the selection criteria and the appointment process for
the Members of the Board of Directors.
2025
Number of Meetings
16
Average ratio of Members’ attendance
97%
CORPORATE GOVERNANCE,
SUSTAINABILITY AND
NOMINATIONS COMMITTEE
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• Identifies and recommends for approval by the Board of Directors candidates to fill
vacancies, according to the Suitability and Nomination Policy for the Members of the
Board of Directors and Key Function Holders, evaluates the balance of knowledge, skills,
diversity and experience of the Board of Directors, prepares a description of the roles
and capabilities for a particular appointment and assesses the time commitment
expected.
• Assesses periodically, and at least annually, the structure, size, composition and
performance of the Board of Directors and makes recommendations to the Board of
Directors with regard to any changes.
• Assesses periodically, and at least annually, the knowledge, skills and experience of
each Member of the Board of Directors and of the Board of Directors collectively and
reports to the Board of Directors accordingly.
• Oversees the design and implementation of the induction program for the new
Members of the Board of Directors as well as the ongoing knowledge and skills
development for the Members, which support the effective discharge of their
responsibilities.
The Committee ensures and regularly evaluates that its Members collectively possess the
required knowledge, skills and experience relating to sustainability and ESG issues as well as
to the business of the Bank to assess the appropriate composition of the Board of Directors
and, among others, the selection process and the suitability requirements, in order to
adequately discharge the Committee’s responsibilities.
The specific duties and responsibilities of the CGSNC are set out in its Charter, which is
posted on the Bank’s website (https://www.alpha.gr/en/group/corporate-
governance/commitees).
The activities of the CGSNC for the year 2025 are presented below.
Throughout 2025, the Committee remained actively engaged in a wide range of governance,
nomination and sustainability responsibilities. It focused on Board succession planning,
executive appointments, policy and framework reviews, preparation for shareholder
meetings and oversight of key regulatory and ESG initiatives.
Board Succession and Composition
The Committee paid significant attention to Board Succession Planning. Following extensive
evaluation, it recommended to the Board of Directors:
• the appointment of Mr. L.A. Papagaryfallou as Executive Member of the Board of
Directors, in replacement of Mr. S.N. Filaretos;
• the appointment of Ms. A.G. Areni as Non-Executive Member of the Board of Directors,
in replacement of Mr. E.O. Vidalis.
The Committee also reviewed updates on ongoing board succession planning, examined and
endorsed the candidates’ skills profiles and recommended them for approval by the Board
of Directors.
In line with the Bank of Greece Executive Committee Act No. 224/21.12.2023, the
EBA/ESMA Guidelines, the Committee assessed the collective suitability of the Board of
Directors on the basis of the EBA/ESMA Guidelines Matrix and confirmed that the Members
fulfill the Suitability and Nomination Criteria as well as the Independence Criteria, and, in
this context, proposed the appointment of Mr. J.-H.-F.G. Umbgrove as Independent
Non-Executive Member of the Board of Directors to the General Meeting of Shareholders.
The Committee was additionally informed of potential new board roles for Mr. J.L. Cheval
and Ms. D.C. Lebot.
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Furthermore, the Committee proposed the new composition of the Remuneration
Committee and of the Corporate Governance, Sustainability and Nominations Committee
and endorsed the determination of the number and qualifications of the Audit Committee
Members.
Executive Appointments and Organizational Structure
The Committee reviewed and endorsed amendments to the Bank’s Organizational Chart and
Executive Committee structure. In this context, it recommended to the Board of Directors
the appointments of:
• Mr. M.V. Tsarbopoulos as Chief Digital and Technology Officer;
• Mr. P.K. Georgiopoulos as Chief Retail Client Strategies Officer;
• Mr. G.D. Linatsas as Chief of Investment Banking; and
• Mr. K.G. Sarafopoulos as Chief Risk Officer.
The Committee also recommended to the Board of Directors the composition of the
Disciplinary Committees and the Management Committees.
Shareholder Meetings and Governance Activities
The Committee reviewed and recommended to the Board of Directors the Draft Invitation
and Draft Resolutions for the Ordinary General Meeting of Shareholders (21.5.2025) and the
Extraordinary General Meeting of Alpha Services and Holdings S.A. (23.6.2025). Moreover, it
received updates on the Corporate Governance Roadshows and took cognizance of the
Okapi/Velos 2025 AGM wrap-up report.
Additionally, the Committee reviewed a presentation regarding the 2026 Ordinary General
Meeting of Shareholders and the Board re-election cycle. In a joint session with the
Remuneration Committee, it was also updated on investor engagement and on the
preparation and the voting procedures of the Ordinary General Meeting.
Policies, Frameworks and Governance Documentation
The Committee reviewed a wide range of governance documents and recommended their
approval by the Board of Directors, including:
• the Corporate Governance Statement for 2024;
• the Charters of the Board Committees;
• the Internal Governance Regulation;
• the Suitability and Nomination Policy for the Members of the Board of Directors
and Key Function Holders and the Suitability and Nomination Process for the
Members of the Board of Directors;
• the Policy for the Succession Planning of Senior Executives and Key Function
Holders;
• the Policy for the Evaluation of Senior Executives and Key Function Holders;
• the Policy for the Submission of Documents to the Board of Directors and its
Committees; and
• the Board of Directors Training Plan for 2026.
Moreover, the Committee also reviewed the Board Effectiveness Action Plan, received an
update on Career Pathing and monitored the implementation of the Policy for the
Submission of Documents to the Board of Directors and its Committees.
Compliance and External Assessments
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The Committee reviewed the Request for Proposal concerning the evaluation of the
effectiveness of the Board of Directors and its Committees.
Moreover, the Committee was presented with the results of the assessment of Alpha Bank’s
approach to Corporate Governance conducted by PriceWaterhouseCoopers (PWC). The
assessment did not reveal any material weaknesses.
Group-Level and Subsidiary Oversight
The Committee reviewed and endorsed the documentation related to the merger of Alpha
Services and Holdings S.A. with Alpha Bank S.A., recommending its approval by the Board of
Directors.
Moreover, it assessed and endorsed the Material Risk Takers list at Group level.
The Committee also reviewed the attendance of the Members at the Board and Committee
meetings for 2024 and the first half of 2025 and submitted its Annual Activity Report to the
Board Members for information.
Additionally, it reviewed the Annual Activity Reports for 2024 and the Semi-Annual Activity
Reports for 2025 prepared by the Subsidiaries’ Nomination Committees and Boards of
Directors. The Committee also held joint meetings with the Nominations, Corporate
Governance and Sustainability Committee of Alpha Bank Cyprus Ltd and with the
Remuneration and Nomination Committee of Alpha Real Estate Services S.A.
Lastly, the Committee was updated on and did not object to new appointments, changes in
composition, and mandate renewals within the Boards of Directors of Alpha Bank Cyprus
Ltd, Alpha Bank London Ltd, Alpha Leasing S.A. and Alpha Finance Investment Services S.A.
ESG and Sustainability Oversight
The Committee received regular updates on Environmental, Social and Governance (ESG)
matters and on the implementation of the Corporate Sustainability Reporting Directive
(CSRD). In this context, it reviewed and endorsed the Sustainability Statement and
recommended its approval by the Board of Directors. It also reviewed the Task Force on
Climate-related Financial Disclosures (TCFD) Report.
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G. EXECUTIVE COMMITTEE
G1.
In accordance with Law 4548/2018 and the Bank’s Articles of Incorporation, the Board of
Directors has established an Executive Committee.
The Executive Committee acts as a collective corporate body of the Bank. The Committee’s
powers and authorities are determined by way of a CEO act, delegating powers and
authorities to the Committee. The Committee is vested, at least, with the following powers
and authorities to manage the affairs of the Bank and take decisions. The Committee has
the right to delegate further all or parts of its vested authority.
The indicative main responsibilities of the Committee include but are not limited to the
following:
The Committee:
• Prepares the strategy, the business plan and the annual budget of the Bank and the
Group, including the strategy on Environmental, Social and Governance (ESG) issues,
for submission to and approval by the Board of Directors as well as the annual and
interim Financial Statements.
• Decides on and manages the capital allocation to the Business Units.
• Prepares the Internal Capital Adequacy Assessment Process (ICAAP) Report and the
Internal Liquidity Adequacy Assessment Process (ILAAP) Report for submission to and
approval by the Board of Directors, manages their implementation and reports
accordingly to the Board of Directors.
• Monitors the performance of each Business Unit and Subsidiary of the Bank versus the
Budget and ensures that corrective measures are taken.
• Reviews and approves, in the framework of its authorities, the Policies of the Bank and
informs the Board of Directors accordingly or submits them, as the case may be, to the
latter for approval.
• Discusses issues related to the Group’s Purpose and Values, culture and human
resources as well as approves and manages any collective program proposed by the
Human Resources Unit for the Staff (including any bonus schemes, voluntary
separation schemes etc.).
• Is responsible for the implementation of (i) the overall risk strategy, including the
Bank’s risk appetite and its risk management framework, (ii) an adequate and effective
internal governance and internal control framework that includes a clear
organizational structure and well-functioning independent internal risk management,
compliance and audit functions of high stature and significant know-how as well as
sufficient resources to perform their operations, (iii) an adequate and effective
framework for the implementation of the Bank’s strategy on ESG issues, (iv) the
amounts, types and distribution of both internal capital and regulatory capital to
adequately cover the risks of the Bank, (v) the means for achieving targets for the
liquidity management of the Bank, (vi) the selection and suitability assessment process
for Key Function Holders and (vii) any arrangements aimed at ensuring the integrity of
the accounting and financial reporting systems, including financial and operational
controls, risk management and compliance with the law and the relevant standards.
EXECUTIVE COMMITTEE
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The composition of the Executive Committee of the Bank as of 31.12.2025 is as follows:
Following the successful completion of the acquisition of AXIA and the retirement of its
Chief Risk Officer (CRO), Alpha Bank proceeded with further enhancements to its Executive
Committee as of 1.1.2026. These changes are reinforcing its capacity to drive sustainable
growth, strengthen risk governance, and unlock new value creation opportunities.
The composition of the Executive Committee of the Bank as of 1.1.2026 and until the
publication is as follows:
The CVs of the Members of the Executive Committee are presented below and are also
available on the Bank’s website https://www.alpha.gr/en/Group/advocating-sound-
governance-practices/management/executive-committee.
Chair
Vassilios E. Psaltis
CEO
Members
Lazaros A. Papagaryfallou
Deputy CEO
Spiros A. Andronikakis (until 31.12.2025)
Chief Risk officer
Ioannis M. Emiris
Chief of Wholesale Banking
Nikos V. Salakas
Chief of Corporate Center and General Counsel
Panayotis K. Georgiopoulos
Chief Retail Client Strategies Officer
Stefanos N. Mytilinaios
Chief Integration and Group Initiatives Officer
Fragiski G. Melissa
Chief Human Resources Officer (CHRO)
Georgios V. Michalopoulos
Chief Wealth Management Officer
Vasilis G. Kosmas
Chief Financial Officer (CFO)
Michalis V. Tsarbopoulos
Chief Digital and Technology Officer
Isidoros S. Passas was a Member of the Executive Committee until 15.7.2025
Chair
Vassilios E. Psaltis
CEO
Members
Lazaros A. Papagaryfallou
Deputy CEO
Ioannis M. Emiris
Chief of Wholesale Banking
Nikos V. Salakas
Chief of Corporate Center and General Counsel
Panayotis K. Georgiopoulos
Chief Retail Client Strategies Officer
George D. Linatsas
Chief of Investment Banking
Konstantinos G. Sarafopoulos
Chief Risk Officer (CRO)
Fragiski G. Melissa
Chief Human Resources Officer (CHRO)
Stefanos N. Mytilinaios
Chief Integration and Group Initiatives Officer
Georgios V. Michalopoulos
Chief Wealth Management Officer
Vasilis G. Kosmas
Chief Financial Officer (CFO)
Michalis V. Tsarbopoulos
Chief Digital and Technology Officer
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G2.
Chair
Vassilios E. Psaltis
CEO
Experience and contribution
Vassilios E. Psaltis is the CEO and an Executive Member of the Board of Directors of Alpha
Bank. In his capacity as a Board Member since November 2018, and CEO since January
2019, he actively contributes to implementing Alpha Bank’s strategic plan. In 2023 he
promoted a multilevel milestone deal with UniCredit. This strategic partnership has
unlocked the profitability potential of Alpha Bank’s international business, while creating
upside potential for the rest of the Group.
With over 25 years of experience in the banking industry, he has been appointed to key
positions at Alpha Bank since 2007. Through these posts he has significantly reinforced the
position of Alpha Bank. He spearheaded capital raisings from foreign institutional
shareholders, diversifying the Bank’s shareholder base, as well as significant mergers and
acquisitions that contributed to the consolidation of the Greek banking system.
On top of his duties at Alpha Bank, he has also been serving as a Member of the Board of
Directors and the Executive Committee of the Hellenic Federation of Enterprises (SEV) since
July 2021 and as a Member of the Board of Directors of the Hellenic Bank Association (HBA)
since October 2021. In 2019 he was appointed member of the Institut International d'
Études Bancaires (IIEB).
He holds a PhD and MA in Business and Banking from the University of St. Gallen,
Switzerland.
Current and past appointments
• CEO, Alpha Bank (2019 - today)
• General Manager, Alpha Bank (2012-2018)
• Group Chief Financial Officer (CFO), Alpha Bank (2010-2018)
• Senior Manager, Corporate Planning and Controlling, Alpha Bank (2007-2010)
• Deputy (acting) Chief Financial Officer, Emporiki Bank (2002-2006)
• Senior management positions, ABN AMRO Bank’s Financial Institutions Group, London
(1999-2001)
CVs OF THE MEMBERS OR THE
EXECUTIVE COMMITTEE
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216 | ANNUAL FINANCIAL REPORT
Member
Lazaros A. Papagaryfallou
Deputy CEO
Current appointments
Lazaros Papagaryfallou is an Executive Member of the Board of Directors of Alpha Bank. He
has been a Board Member since February 2025, and Deputy CEO since July 2024. He joined
Alpha Bank in 1998.
He is a member of the Executive Committee of Alpha Bank.
Past appointments
• Alpha Bank Group, Chief Financial Officer (CFO) (2019)
• Alpha Bank, Appointed Executive General Manager of the Bank (2013-2019), Manager
of the Corporate Development, International Network and Strategic Planning Divisions
(1998-2013)
• Alpha Bank Group, Chairman and Member of the Boards of Directors of various Group
Companies, both in Greece and abroad, in the banking, insurance, financial services,
industrial and real estate sectors
Through these posts he contributed to implementing the Group’s Restructuring Plan,
as well as designing and closing mergers, acquisitions and portfolio transactions, and
strengthening the Bank’s capital.
• Work experience: Citibank, ABN AMRO
Studies
• MBA in Business Administration, Finance, University of Wales, Cardiff Business School
• Degree in Business Administration, Athens University of Economics and Business
Other information
Nationality: Greek
Member
Ioannis M. Emiris
Chief of Wholesale Banking
Career highlights and studies
He studied Economics and Business Administration at the Athens University of Economics
and Business (former Athens School of Economics and Business) and holds an MBA from
Columbia Business School as well as a US Certified Public Accounting (CPA) degree. He
started his career as a certified public accountant in PricewaterhouseCoopers in New York.
From 1991 to 2012, he worked for the Alpha Bank Group, initially as an Investment Banker
in Alpha Finance Investment Services S.A. and from 2004 as Manager of the Project Finance
and the Investment Banking Divisions of Alpha Bank. From 2012 to 2014, he was the Chief
Executive Officer of the Hellenic Republic Asset Development Fund (HRADF). On 5.11.2014,
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he was appointed Executive General Manager and on 19.11.2019 he was appointed Chief of
Wholesale Banking.
Member
Nikos V. Salakas
Chief of Corporate Center and General Counsel
Career highlights and studies
He studied Law at the National and Kapodistrian University of Athens and holds a
postgraduate degree (LL.M. in International Business Law) from the University College
London. In March 2019, he joined Alpha Bank as Chief Legal and Governance Officer, after
more than twenty years of cooperation with Koutalidis Law Firm, at which he had been
Head of the Banking and Finance Department since 2010. In 2022 he returned to Koutalidis
Law Firm, while taking up the role of Special Legal Counsel to the Board of Directors and
the Executive Committee of the Bank, making, thus, a key contribution to the
implementation of critical and strategic transactions. He has more than 25 years of
experience in Greek and International Banking and Regulation, Finance, Restructuring an d
Securities Transactions and he is ranked amongst the top Greek lawyers by the
International Financial Law Review (IFLR), the Legal 500 guide and Chambers and Partners.
He has supported Alpha Bank in regulatory issues, M&As as well as in strategic transactions
since 1999. On 1.4.2024 he was appointed Chief of Corporate Center and General Counsel
and Member of the Executive Committee.
Member
Panayotis K. Georgiopoulos
Chief Retail Client Strategies Officer
Career highlights and studies
He holds a PhD in Analytical Decision Making and a Master’s degree in Manufacturing
Engineering from the University of Michigan, USA, and is a Mechanical Engineering
graduate of the National Technical University of Athens (NTUA). He has an extensive track
record in the telecommunications industry and has been recognized for successfully
executing transformational initiatives that strengthened the strategic positioning and
competitiveness of the organizations he served. He has served, among others, as CEO of
Nova, Executive Committee Member and Head of Commercial and Digital Operations at
Vodafone Greece and has also held research and senior executive positions at multinational
groups in the US and Greece. Throughout his career, he has led significant M&A
transactions and played a key role in elevating customer experience. On 15.7.2025 he was
appointed Chief Retail Client Strategies Officer.
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Member
George D. Linatsas
Chief of Investment Banking
Career highlights and studies
He holds a B.S. in Finance and Marketing from the University of Maryland at College Park
and an MBA in International Finance from American University. He brings more than 25
years of experience in investment banking and capital markets, with a strong track record
in advisory, M&A, and capital markets transactions in Greece and the wider region. As a
Founding Partner and Group Managing Director of AXIA, he played a central role in building
one of the most active independent investment banking platforms in the market. Prior to
AXIA, he served as General Manager, Head of Equities and Board Member of Piraeus
Securities. Throughout his career, he has led some of the largest M&A and capital market
transactions in the local market and is a frequent speaker at finance conferences. On
1.1.2026 he was appointed Chief of Investment Banking.
Member
Konstantinos G. Sarafopoulos
Chief Risk Officer (CRO)
Career highlights and studies
He holds an MSc in Applied and Computational Mathematics (with Distinction) and an MA
(Hons) in Mathematics from the University of Oxford. He brings strong expertise in risk
management, asset-liability management, and financial markets, combining deep technical
knowledge with balanced judgment and a constructive approach to business decision-
making. He joined Alpha Bank in 2021 and served as Group Chief Investment Officer from
January 2023 until December 2025, having previously held the role of Manager ALM. Prior
to joining Alpha Bank, he spent 15 years at JP Morgan Chase, progressing to Executive
Director and serving as a Senior Portfolio Manager in International Rates and FX in London.
On 1.1.2026 he was appointed Chief Risk Officer (CRO).
Member
Fragiski G. Melissa
Chief Human Resources Officer (CHRO)
Career highlights and studies
She studied Psychology at the National and Kapodistrian University of Athens and holds
postgraduate degrees in Industrial/Organizational Studies from Columbia University and in
Social Studies from the New School for Social Research. She brings 28 years of experience in
human resources. She served as a Regional Human Resource Director for Southeastern
Europe at Colgate Palmolive, while in her career she also held positions of responsibility at
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Makro Cash & Carry and at KPMG. For the last 8 years before joining Alpha Bank, she was
Head of Human Resources at Vodafone in Greece and Romania. On 3.3.2020 she was
appointed Executive General Manager – Chief Human Resources Officer and on 20.5.2022
she was appointed Chief Human Resources Officer (CHRO).
Member
Stefanos N. Mytilinaios
Chief Integration and Group Initiatives Officer
Career highlights and studies
He holds a First-Class degree in Aerospace Engineering from the University of Bristol, Great
Britain, and an MBA with Distinction from INSEAD in Fontainebleau, France. He brings
onboard extensive experience in technology, operations and business, having assumed
managerial positions in Greece and abroad. He served as the Deputy Group CIO at
Eurobank and as a business consultant at McKinsey & Company, based in Athens and
London. Moreover, he has been the Chief Technology Officer at Commercial Bank of Qatar
and later on he was appointed General Manager, Digital Business at Piraeus Bank. On
1.12.2020 he was appointed Chief Operating Officer (COO). On 15.7.2025 he was appointed
Chief Integration and Group Initiatives Officer.
Member
Georgios V. Michalopoulos
Chief Wealth Management Officer
Career highlights and studies
He studied Mathematics at the National and Kapodistrian University of Athens and holds an
MBA in Finance from City, University of London (Bayes Business School). He started his
career at Alpha Bank in 1994 and worked in the Treasury functions in Athens and London.
He has served as Group Treasurer and Manager of the Planning and Trading and the
Financial Markets Divisions. He has been a Member of the Board of Directors of various
Group Companies in the banking, finance and insurance sectors in Greece and abroad for a
number of years. On 4.5.2016 he was appointed Executive General Manager of Treasury
Management and on 20.5.2022 he was appointed Chief Wealth Management Officer.
Member
Vasilis G. Kosmas
Chief Financial Officer (CFO)
Career highlights and studies
He holds a BA in Economics from the Athens University of Economics and Business
(graduated in the top 3rd percentile) and an MBA, concentration in Finance, from New York
University, Leonard N. Stern School of Business. During his career, he held many positions
of responsibility, such as Finance Manager at Procter & Gamble and Senior Engagement
Manager at McKinsey & Company. He served as Director in Structured Finance and
Wholesale Funding as well as Corporate Development and Group Strategy at the National
Bank of Greece and as Chief Operating Officer at Ethniki Insurance. Moreover, he worked as
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Managing Director, Deal Advisory at KPMG LLP. He was a partner at Alantra in London, UK
until 15.5.2024. On 23.7.2024 he was appointed Chief Financial Officer (CFO).
Member
Michalis V. Tsarbopoulos
Chief Digital and Technology Officer
Career highlights and studies
He holds an MBA from the Simon School of Business of the University of Rochester, New
York, USA, as well as a Diploma in Electrical and Computer Engineering from the National
Technical University of Athens. His professional experience spans over 20 years, including
14 years in senior leadership roles within the banking sector in Greece. During his tenure at
Eurobank, he held several key positions, most recently serving as Group Chief Digital
Officer, responsible for planning, supervising and supporting the implementation of the
bank’s digital strategy, and as Deputy General Manager - Head of Global Transaction
Banking. Earlier in his career, he worked at the Boston Consulting Group, focusing on
Financial Services, and served as Manager of Strategic Initiatives at HSBC Greece. On
1.12.2021, he was appointed Executive General Manager of Alpha Bank and on 1.1.2024,
Chief Digital Officer. On 15.7.2025 he was appointed Chief Digital and Technology Officer.
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G3.
Members of the Executive Committee
Number of
shares
% of the share
capital
Chair
Vassilios E. Psaltis
CEO
430,872
0.019
Members
Lazaros A. Papagaryfallou
Deputy CEO
385,321
0.017
Spyros A. Andronikakis
Chief Risk Officer (until 31.12.2025)
449,641
0.019
Ioannis M. Emiris
Chief of Wholesale Banking
493,409
0.021
Nikos V. Salakas
Chief of Corporate Center and General
Counsel
93,347
0.004
Panayotis K. Georgiopoulos
Chief Retail Client Strategies Officer
−
−
George D. Linatsas
Chief of Investment Banking (since 1.1.2026)
−
−
Konstantinos G. Sarafopoulos
Chief Risk Officer (since 1.1.2026)
29,969
0.001
Fragiski G. Melissa
Chief Human Resources Officer
147,147
0.006
Stefanos N. Mytilinaios
Chief Integration and Group Initiatives Officer
58,001
0.003
Georgios V. Michalopoulos
Chief Wealth Management Officer
269,549
0.012
Vasilis G. Kosmas
Chief Financial Officer
24,703
0.001
Michalis V. Tsarbopoulos
Chief Digital and Technology Officer
44,934
0.002
NUMBER OF SHARES OWNED
ON 31.12.2025
G4.
4.1 Non-Financial Risks and Internal Control Committee
The Committee, among others:
• Ensures that an appropriate organizational structure and framework for non-financial
risk management (methodology, procedure and infrastructure) is in place.
• Ensures the alignment of the non-financial risk policies and framework for non-
financial risk, with the Bank’s Risk Appetite Framework.
• Approves the operational risk provisions on third-party lawsuits against the Bank.
• Approves the authorization limits of the Committees responsible for the management
of non-financial risk events of the Bank and the Group Companies.
• Reviews the non-financial risk events whose financial impact exceeds the limits of the
other Committees.
• Is updated on the non-financial risks regulatory requirements as well as on the
regulatory findings which are identified via internal and external audits .
• Is informed of issues raised by the Internal Audit Business Area, concerning high risk
areas and required corrective actions in order to reduce them.
• Reviews the results and decides on the required actions on issues stemming from
external evaluation processes of various bodies.
• Takes cognizance of the non-financial risk profile of the Group .
Management Committees
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4.2 Credit Risk Committee
The Committee, among others:
• Assesses the adequacy and efficiency of the credit risk management policy and
procedures of the Bank and the Group and plans the required corrective actions.
• Is informed, on a regular basis, about the Credit Risk Policies of the countries in which
the Group operates, ensuring that they are aligned with the Bank’s Credit Risk
Appetite.
• Reviews periodically the development of credit risk by sector and geographic area and
of concentration risk where the Group operates.
• Reviews the reports of the Risk Management Units submitted to the Board of Directors
and the Risk Management Committee.
• Reviews the Troubled Assets Committee’s reports.
• Oversees progress versus the annual targets submitted to the Single Supervisory
Mechanism (SSM) through the Business Plan, in the framework of the management of
Non-Performing Exposures (NPEs) and Non-Performing Loans (NPLs).
• Reviews and approves the Group Credit Risk Policies as well as the Group Credit
Control Framework.
• Approves the Group’s write-offs.
• Approves the development and update of the Credit Risk Models as well as the
relevant Governance Framework.
• Approves the methodology for the calculation of the Expected Credit Loss (ECL)
methodology.
• Approves the quarterly impairment provisions.
• Is informed of the most important findings resulting from the conduct of credit reviews
by the Credit Control Business Area.
• Is informed of the strategy for the management of arrears, of arrears manuals and of
the Group’s Arrears Committees, approved by the Troubled Assets Committee.
• Reviews the results of the Stress Tests.
• Reviews the results and decides on required actions on issues stemming from external
evaluation processes, including the Supervisory Review and Evaluation Process (SREP),
the SSM Audits and the European Banking Authority (EBA) Stress Tests.
• Is informed of and reviews Pillar III disclosures and other issues related to Credit Risk.
• Is informed of and reviews the progress of projects related to supervisory guidelines
(e.g. new definition of default, provisioning calendar) as well as important projects for
the Bank related to Credit Risk.
4.3 Troubled Assets Committee (TAC)
The Committee, among others:
• Formulates and approves the delegated authorities that shall be granted to the
Servicers as regards decisions related to the credit risk associated with the portfolio
assigned.
• Evaluates and approves the modification of financial terms included in the relevant
Service Level Agreement, following the Cost Control Committee’s approval, and
submits them to the Risk Management Committee for information purposes, if
deemed necessary.
• Formulates, evaluates and approves the Wholesale and Retail Banking Non-Performing
Loans (NPLs) Strategy and submits it to the Credit Risk Committee for approval and to
the Risk Management Committee for information purposes, if deemed necessary.
• Approves, in principle, proposals regarding the sale of exposure portfolios in terms of
their operational feasibility and their relevance to the Business Plan as well as the
Budget of the NPEs Strategy, Recovery and Monitoring Business Area. This information
is forwarded to the Executive Committee for final approval or to the Board of
Directors, as appropriate.
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• Ensures the planning, approval, periodic monitoring and evaluation of pilot products
and campaigns associated with targeted Retail Banking portfolios that the NPEs
Strategy, Recovery and Monitoring Business Area implements via the Servicers.
• Monitors, controls and evaluates the actions taken to achieve the approved budgetary
targets business plans and objectives set for the NPEs Strategy, Recovery and
Monitoring Business Area and for the Servicers in Greece and abroad, in line with the
Bank’s Business Plan; the NPEs Strategy, Recovery and Monitoring Business Area
submits to the Committee proposals on the modification of business plans and the
Budget, and the Committee is responsible for evaluating and selecting the proposals
that shall be submitted to the Credit Risk Committee (and the Risk Management
Committee, if deemed necessary).
• Approves, in principle, the business rationale (subject to the Executive Committee and
the Board of Directors approval, where required) for the assignment of the
management of exposures to companies which specialize in managing receivables and
are licensed by the Bank of Greece. Additionally, the NPEs Strategy, Recovery and
Monitoring Business Area is responsible for: (a) monitoring the implementation of the
said transactions and (b) evaluating the performance of the said companies in relation
to the targets set and updating the Committee, at regular intervals.
• Approves, in principle, the business rationale of the NPEs Strategy, Recovery and
Monitoring Business Area’s proposal regarding the assignment of work to external
advisors, subject to the Cost Control Committee’s approval.
• Approves, within its competences, ad hoc reports, which are submitted to the
European Central Bank (ECB).
• Coordinates the proceedings of the Troubled Assets Committees which operate within
the Group Companies abroad.
4.4 Assets-Liabilities Management Committee (ALCo)
The Committee, among others:
• Is informed of and decides on matters regarding the strategic management of assets
and liabilities to ensure the optimal structure of the Balance Sheet with the aim of
achieving the short-term and medium- to long-term business objectives of the Bank
and the Group Companies.
• Assesses financial risks and decides on the risk hedging strategy and actions, taking into
account (current and, according to forecasts, future) market conditions, the Regulatory
Framework and the Supervisory Indicators.
4.5 Group Sustainability Committee
The Committee:
• Steers the Group’s strategy and direction on sustainability and ESG related topics, to
support the sustainability and resilience of the Group’s business model and enable
long-term value creation.
• Agrees and proposes for endorsement by the Executive Committee and approval by
the Board of Directors the Group’s ESG strategy and its targets, including financial and
non-financial Key Performance Indicators (KPIs), according to the established
governance procedures.
• Ensures that the aforementioned ESG targets and KPIs are aligned with and
incorporated into the Group’s Risk Appetite Framework, the Business Plan and any
relevant policies, through the implementation of an appropriate decision-making
process and the approval of the responsible bodies, for said policies.
• Monitors the Group’s sustainability performance against policy targets and
benchmarks.
• Monitors current and emerging ESG trends affecting the Group.
• Remains informed of the investment community’s expectations regarding ESG-related
topics and proposes actions to ensure the Group differentiates itself successfully.
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• Proposes criteria for sustainable credit approvals, debt issuances and investments to
be incorporated in the relevant policies.
• Oversees the content of ESG-related non-financial disclosures, including the Non-
Financial Report and the Sustainability Report.
• Monitors the Group’s alignment with ESG requirements, including regulatory
expectations and public or other stakeholder commitments.
• Monitors the implementation of sustainability and corporate responsibility initiatives.
• Oversees internal and external communication related to ESG issues.
• Remains informed of matters raised by the Internal Audit Business Area, concerning
ESG risks and the required mitigating actions to address them.
• Takes cognizance of relevant findings which are identified in external audits and
assesses the action plans proposed to mitigate them.
• Is informed about the results of supervisory evaluations and decides on appropriate
actions in response to topics stemming from new supervisory requirements, guidelines
and recommendations of relevant bodies, such as: (i) the Supervisory Review and
Evaluation Process (SREP), (ii) the Single Supervisory Mechanism (SSM), (iii) the
European Banking Authority (EBA) and (iv) Other Legal, Regulatory or Government
authorities which may issue ESG-related legislation or regulation. For supervisory
issues, the Committee leverages on the existing governance structure of the Bank.
• Is advised by the Compliance or the other Control functions of the Bank on the
appropriate action to be taken with regard to new or amended regulatory
requirements.
• Discusses proposals for relevant operational or capital expenses, driven by the Group’s
ESG initiatives, subject to the Bank’s governance process on budgeting and expense
control.
4.6 ICT Third-Party Risk and Outsourcing Committee
Within the framework of its responsibilities, the Committee, among others:
• Reviews, on a regular basis (at least annually) or whenever deemed necessary, the
Group Outsourcing Policy, the Strategy on ICT Third-Party Risk, the Policy on
Arrangements Regarding the Use of ICT Services Provided by ICT Third-Party Providers
as well as procedures related with the said policies and strategy and assesses the need
to update them (e.g. due to a change in the legislative/regulatory framework), taking
into account any relevant recommendation by the ICT Third-Party Risk and Outsourcing
Support Committee, and submits to the Board of Directors for approval any changes to
the said policies and strategy and for information any changes to the relevant
procedures approved by the Committee.
• Evaluates and validates the characterization of criticality or not of planned outsourcing
arrangements, following a relevant recommendation by the ICT Third-Party Risk and
Outsourcing Support Committee.
• Supervises the documentation of outsourcing agreements as well as contractual
arrangements on the use of ICT services provided by ICT third-party service providers,
in cooperation with the Outsourcing and Third-Party Governance Business Object of
the Central Procurement Management and Outsourcing Business Area.
• Evaluates the overall outsourcing risk, ICT third-party risk and the individual risks for
the candidate service provider(s), as they have emerged from the selection and
evaluation process, including the Exit Strategy for critical or important outsourcing
arrangements and contractual arrangements on the use of ICT services supporting
Critical or Important Functions, according to the Policy on Arrangements Regarding the
Use of ICT Services Provided by ICT Third-Party Providers.
• Evaluates the results of the due diligence and risk assessment process for the
candidate outsourcing service provider(s)/ICT third-party service providers as they
have emerged from the selection and evaluation process and taking into account the
relevant opinion of the ICT Third-Party Risk and Outsourcing Support Committee.
• Approves non-critical/important planned outsourcing arrangements that do not
exceed the Bank’s risk appetite, taking into account the relevant assessment and
comparison with the Bank’s risk appetite by the ICT Third-Party Risk and Outsourcing
Support Committee.
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• Recommends to the Board of Directors the approval of critical/important planned
outsourcing arrangements or contractual arrangements on the use of ICT services
supporting Critical or Important Functions.
• Recommends to the Board of Directors the approval or not of non-critical/important
planned outsourcing arrangements or contractual arrangements on the use of ICT
services not supporting Critical or Important Functions that exceed the Bank’s risk
appetite, taking into account the relevant assessment and comparison with the Bank’s
risk appetite by the ICT Third-Party Risk and Outsourcing Support Committee, to the
Board of Directors.
• Is informed by the competent Business Areas of the results of periodic outsourcing risk
assessments and ICT third-party risk assessments, of possible deviations in the level of
compliance and performance of service providers regarding their contractual
obligations, as well as of incidents that may affect the responsiveness and compliance
of service providers, and gives its opinion on corrective actions submitted by the
competent Business Areas.
• Is informed by the ICT Third-Party Risk and Outsourcing Support Committee about ICT
incidents or disruptions to ICT services provided by ICT third-party service providers,
reviews lessons learned and gives its opinion on corrective actions submitted by the
competent Business Areas.
• Evaluates and approves the methodology for the determination of the reporting
perimeter of the Register of Information (“Scoping Methodology”) with reference to
contractual arrangements on the use of ICT services provided by ICT third-party service
providers.
4.7 Underwriting Committee
The Committee, among others, decides on the following:
− the approval in order for the Bank to assume the role of Issuance Advisor and/or
Coordinator of the Main Contractor and/or Contractor in a specific company,
− the Issuance, Coordination, Sales and Underwriting consultant fees as well as their
proposed distribution among contractors,
− the Bank’s participation in securities’ underwriting undertaken and coordinated by
other banks,
− the approval of the underwriting policy on securities at the Athex, while being
informed about the strategy of the Company to be listed, its valuation in principle
and the estimate of the funds raised from the Athex, the potential investors and
other participants, the indicative time-schedule as well as the underwriting group,
if it has been decided by the company.
4.8 Reputational Risk Committee
The Committee, among others:
• Is informed of upcoming activities and partnerships of the Bank and the Group
Companies which may lead to significant reputational risk and decides on the
continuation (under certain requirements) or not of the said activities/partnerships. In
particular, it evaluates the hereunder cases, if the counterparty reputational risk (or
the Bank’s reputational risk exposure regarding New Customer Product or Services/
Commission Charges) has been assessed as medium-high or high risk, based on the
tools that are developed and maintained by the Risk Management Sector:
➢ New Financing to borrowers of the Wholesale Banking Sector.
➢ New Bond Issuing.
➢ New Investment Banking activities.
➢ New Public Offerings.
➢ New Non-Critical Outsourcing Arrangements.
➢ New Suppliers.
➢ New Investors.
• Is informed about the existing incidents/transactions/activities/practices that have or
may have a significant negative impact on the reputation of the Bank and the Group
Companies as well as the actions that have already been taken or are planned to be
taken to address them and proposes further actions when deemed necessary.
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• Is informed of the management and evolution of the said events until their final
settlement/resolution.
4.9 RE Committee I
The Committee, among others:
• Determines and monitors the strategy of acquisition, utilization, management,
exploitation and sale of all types of real estate which are either already owned (co-
owned) by the Bank and/or the Group Companies or considered for recovery by the
Bank or the Group Companies or considered for investment by the Bank or the Group
Companies or leased by third parties and used by the Bank or the Group Companies.
4.10 Cost Control Committee
The Committee, among others:
• Approves the policies and procedures in the context of the Group’s Cost Control
Framework.
• Validates the Capital Expenditures (CapEx) and Operating Expenses (OpEx) budget as
well as its allocation to expense categories, as per the proposal submitted by the
Financial Planning and Control Business Area, prior to its submission to the Executive
Committee for approval.
• Validates the annual Project Portfolio proposal, formulated by the competent areas.
• Evaluates and approves expense requests within its limits.
• Receives updates on a quarterly basis from the Financial Planning and Control Business
Area with respect to the evolution of expenses versus the Budget, at Bank and at
Group level.
• Assigns to the Expense Line Owners the identification of cost rationalization areas
within their area of responsibility and evaluates/validates proposals concerning the
execution of relevant actions, in collaboration with the competent Units.
• Indicates the appropriate way of handling confidential expenses, based on their
confidentiality rating.
• Validates the proposal submitted by the Financial Planning and Control Business Area
regarding the methodology and rules of cost allocation for the purpose of measuring
the Units’ performance (Value Based Management).
4.11 Management Credit Committees
The Committees, among others, decide, within their delegation limits, on the following:
− Credit requests to companies or groups of connected companies, under the
competence of the Business Areas supervised by the Chief of Wholesale Banking.
− Risk issues of Credit Institutions, Central Governments, Transnational
Organizations and Intermediates under the competence of the Business Areas
supervised by the Chief of Wholesale Banking.
− Retail Banking credit requests for new credits and periodic reviews of credit limits
and debt modifications of performing exposures.
− Credit requests of Individuals for personal/consumer and housing loans, for which
an application is submitted through the Private Banking Business Area.
− Credit requests of companies or groups of connected companies with performing
exposures under the management of the Private Banking Business Area.
− Lending to companies or groups of connected companies of the International
Network with Performing Exposures.
4.12 Management Arrears Committees
The Committees, among others, decide on Customers’ requests under the management of
the NPEs Strategy, Recovery and Monitoring Business Area in Greece and in the countries
where the Group operates, regarding the following portfolios:
− Wholesale Banking – Greece
− Retail Banking – Greece, and
− Wholesale Banking – International Network.
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4.13 Communications Committee
The Committee takes cognizance of and decides, among others, upon:
• Communications, marketing and public relations matters, including the overall
strategy, internal and external communications, events and sponsorships as well as
budget allocation matters, to ensure targeted reach-out to internal and external
stakeholders a nd active management of the Bank’s brand and reputation.
H. DESCRIPTION OF THE DIVERSITY POLICY APPLIED TO THE MEMBERS OF THE BOARD OF DIRECTORS AND EMPLOYEES
DESCRIPTION OF THE DIVERSITY
POLICY APPLIED TO THE MEMBERS
OF THE BOARD OF DIRECTORS AND
EMPLOYEES
The Diversity Policy outlines our principles and approach towards achieving diversity
within both our Board of Directors and our Employees. We are committed to adhering to
the legislative and regulatory frameworks currently in force, including the Joint ESMA/EBA
"Guidelines on the assessment of the suitability of members of the management body and
key function holders," as well as embracing European best practices in corporate
governance.
In essence, diversity at Alpha Bank is defined as the presence of sufficiently varied
characteristics among the Members of the Board of Directors and our Employees. This
includes factors such as age, gender, geographical provenance as well as educational and
professional background. Our goal is to ensure that these differences are significant
enough to foster a variety of perspectives and views within the Board of Directors and
among our Employees.
By promoting diversity, we aim to create a more inclusive and dynamic environment that
values and leverages the unique contributions of each individual. This, in turn, enhances
our decision-making processes and ultimately drives our success as an organization.
While the diversity of the Board of Directors is not a criterion for assessing the Members’
individual suitability, it is a vital factor when selecting and evaluating Members of the
Board. A diverse Board of Directors brings a broader range of experiences, knowledge,
skills and values, which enhance its overall functioning and effectively address the
phenomenon of “groupthink”. By fostering a more diverse Board, we can encourage
independent opinions and constructive challenges during the decision-making process.
The Policy applies not only to the selection procedures for the Board Members but also to
the appointment of our Senior Management and Employees. The key objectives of this
Policy are to support and promote diversity across all levels of our Organization. This
approach facilitates independent opinions and sound decision-making within the Board of
Directors.
Additionally, we are committed to ensuring appropriate gender representation within the
Board of Directors and respecting the principle of equal opportunities during the selection
process. This commitment extends to our Employees, guaranteeing equal treatment and
opportunities for individuals of all genders.
The objectives of our Policy are, first and foremost, to support and promote diversity
within Board of Directors and our Employees. This means engaging a broad set of qualities
and competencies when recruiting. By doing so, we aim to achieve a variety of views and
experiences, which we believe are crucial for facilitating independent opinions and sound
decision-making within the Board.
Moreover, we strive to ensure appropriate representation of all genders within the Board
of Directors. This principle of equal opportunities is paramount when selecting Board
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
228 | ANNUAL FINANCIAL REPORT
Members. Similarly, we are dedicated to ensuring equal treatment and opportunities for
Employees of different genders.
Additionally, when setting diversity objectives, the Bank considers diversity benchmarking
results published by competent authorities, such as the European Banking Authority (EBA),
or other relevant international bodies or organizations. This helps us align our goals with
best practices and standards in the industry.
Our Policy is approved by the Board of Directors and undergoes a review every two years
by the Corporate Governance, Sustainability and Nominations Committee (CGSNC). The
CGSNC may propose relevant amendments to the Board of Directors, as necessary.
H1.
The Bank embraces the benefits of having a diverse Board of Directors. It recognizes that diversity can help
achieve maximum team performance and effectiveness, enhance innovation and creativity and promote critical
thinking and team cooperation within the Board. In this context, a diversified Board of Directors fosters
constructive challenge and discussion on the basis of different points of view, while also contributing to the
improvement of decision-making regarding strategies and risk-taking by encompassing a broader range of views,
opinions, experience, perception, values and backgrounds, thus reducing the phenomena of “groupthink” and
“herd behavior”.
A truly diversified Board of Directors allows and makes good use of differences in skills, regional and industry
experience, background, abilities, qualifications, professional training, gender and other distinctions between
the Members. Pursuant to the Suitability and Nomination Policy for the Members of the Board of Directors and
Key Function Holders of the Bank, all Board appointments, including the succession planning, are made in
accordance with legal and regulatory requirements ensuring an optimal balance, among others, of skills,
experience, knowledge independence and high ethical standards, without any discriminations based on sex,
race, color, ethnic or social origin, religion or belief, property, birth, disability, sexual orientation, gender, age,
geographical provenance and/or educational and professional background.
The above suitability and differentiation parameters should be taken into consideration in determining the best
possible composition of the Board of Directors and, when possible, should be balanced appropriately.
At least the following diversity aspects shall be taken into consideration for all Board appointments, without
prejudice to the legislative and regulatory framework and to the Suitability and Nomination Policy for the
Members of the Board of Directors and Key Function Holders of the Bank:
• Educational and professional background, skills and knowledge as well as experience in order to facilitate
productive challenge and independent thinking, in accordance with the Suitability and Nomination Policy
for the Members of the Board of Directors and Key Function Holders.
• Gender: taking into consideration that different typical attitudes and behaviors can be observed in persons
of different genders.
• Age: considering that the time period in which a person has grown up influences his/her values, behavior
and risk culture.
• Geographical provenance: the region where a person has gained a cultural, educational or prior
professional background. Diversity regarding geographical provenance ensures that the Board has a direct
understanding of the culture values, market specificities and legal framework present in the main business
hubs that the Bank is active in and facilitates well-informed decision-making regarding the business
strategy in those business and geographical areas.
In reviewing the composition of the Board of Directors and in identifying suitable candidates for appointment,
reappointment or during the succession planning, the CGSNC will:
a. Consider the benefits of all aspects of diversity, including, but not limited to, those described above, in
order to enable the Board of Directors to discharge its duties and responsibilities effectively.
b. Consider candidates on the basis of merit and objective criteria, pursuant to the strategic objectives of the
Bank, the legislative and regulatory requirements and in due consideration of diversity in the Board of
Directors.
Board of
Directors
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
229 | ANNUAL FINANCIAL REPORT
According to the legal and regulatory framework, as described in the “Suitability and Nomination Policy for the
Members of the Board of Directors and Key Function Holders”, the CGSNC assesses or re-assesses, on an ongoing
basis and at least annually, on the basis of the “Suitability and Nomination Process for the Members of the Board
of Directors”, the collective and individual suitability of the Members of the Board of Directors. As part of this
annual evaluation of the effectiveness of the Board of Directors and its Committees, the CGSNC will consider the
adequate balance of all aspects of suitability and diversity, including, but not limited to, those described above.
The CGSNC will discuss and agree annually upon all measurable objectives for achieving diversity in the Board of
Directors. In the event that any diversity objectives or targets have not been met, the CGSNC shall explain the
relevant reasons and the measures to be taken, in order to ensure that the diversity objectives and targets will
be met.
The CGSNC reviews and monitors regularly the effectiveness of the Policy and makes relevant recommendations
to the Board of Directors. Furthermore, it reviews regularly the proportion of women who are employed by the
Bank as a whole, in senior management positions and in the Board of Directors.
According to the Diversity Policy, the Board of Directors’ actual target is that the percentage of the less
represented gender in the Board would reach at least 30% in the next three years, while always considering
industry trends and best practices. In li ght of the above, the Board of Directors’ target has been achieved, since
the percentage of the less represented gender stands at 45% (31.12.2025).
All the candidates for the Board of Directors shall be assessed based on the same criteria, irrespective of gender,
since the eligible Members for the Board of Directors must fulfill all the conditions set in relation to their
qualifications. In this context, all genders shall have equal opportunities to be nominated under the condition
that they fulfill all the other prerequisites in accordance with the Suitability and Nomination Policy for the
Members of the Board of Directors and Key Function Holders of the Bank. The Bank shall not nominate Members
of the Board of Directors with the sole purpose of increasing diversity to the detriment of the functioning and
suitability of the Board of Directors collectively or at the expense of the suitability of individual Members of the
Board of Directors.
Acc o rd in g t o t h e
55%
9% 9%
18%
9%
Greek British Dutch French Italian
Nationality of the Members of the Board of Directors 2025
(based on the BoD composition of 31.12.2025)
82%
9% 9%
Educational Profiles of the Members of the Board of Directors 2025
(based on the BoD composition of 31.12.2025)
Business Administration/Economics Law Engineering Sciences
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
230 | ANNUAL FINANCIAL REPORT
H2.
Providing equal opportunities for employment and career advancement to all Employees goes beyond a legal
obligation for the Bank, it is a fundamental pillar of its Human Resources Strategy. This principle is embedded in
the Bank’s Human Resources management procedures and practices, ensuring consistent implementation across
all countries in which the Bank operates.
When setting diversity objectives, the Bank considers diversity benchmarking results, published by the
competent authorities, the European Banking Authority (EBA) or other leading international bodies and
organizations.
In its commitment to turning gender equality into practice and addressing the underrepresentation of women in
leadership roles, a common challenge in the Greek labor market, the Bank has introduced a range of measures
to help Employees balance professional and personal responsibilities. These initiatives also promote fair
treatment and merit-based career advancement, ensuring equal opportunities for female Employees.
Additionally, the Bank offers diverse training, coaching and mentoring programs to foster gender equality. It
remains dedicated to achieving gender diversity within its Senior Management, reflecting the diversity of its
broader workforce.
The Bank applies uniform Remuneration, Benefits and Corporate Expenses Policies that are neutral with respect
to personal characteristics such as gender, race, age, religion or other legally protected attributes, while
respecting and promoting diversity and fostering an inclusive culture that ensures fairness and equal treatment
across all Employee categories. In that context, the Bank offers fair remuneration, based on contracts aligned
with national labor market standards, ensuring compliance with applicable regulations on minimum wage,
working hours and leave entitlements. The Bank’s and the Group’s remuneration practices fully comply with the
applicable legal and regulatory framework, as in force, including Law 4261/2014 [transposing EU Directive
2013/36/EU – Capital Requirements Directive (CRD) IV], Law 4548/2018 and the EBA Guidelines on sound
remuneration policies and the Bank of Greece Executive Committee Act 231/15.7.2024.
The Bank promotes a work environment free of discrimination and harassment, recognizing and valuing each
Employee’s contribution and worth. It guarantees high-quality working conditions and merit-based advancement
opportunities, ensuring fairness and equality across all levels of the Organization. To monitor and reduce
diversity gaps, the Bank conducts annual reviews of relevant data and implements corrective measures to
narrow gaps where necessary.
Employee
s
55% 45%
Gender Diversity
(based on the BoD composition of 31.12.2025)
Male Female
55% 36% 9%
Age Range
(based on the BoD composition of 31.12.2025)
< 61 61-70 > 70
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
231 | ANNUAL FINANCIAL REPORT
The Bank upholds human rights and firmly opposes all forms of child, forced or compulsory labor. It respects
Employee rights and is committed to safeguarding them, in full compliance with national law, the EU legislation
and the International Labour Organization Conventions.
Employees in management positions* as of 31.12.2025.
Age Breakdown as of 31.12.2025
Gender
26-40
41-50
51+
Total
Percentage
Male
22
164
216
402
57%
Female
21
115
171
307
43%
Total
43
279
387
709
100%
Percentage
6%
39%
55%
100%
Educational Level
Breakdown as of
31.12.2025
Percentag
e
Postgraduate Studies (Master's, PhD)
399
56%
Tertiary Education (graduates of Universities or Technological Education
Institutes)
193
27%
High School (Lyceum) graduates
117
17%
Total
709
100%
*Management positions are defined as the positions from the level of Branch Manager and above.
The percentage and the number of Employees in managerial positions per educational level indicate that
Employees in managerial positions holding postgraduate degrees represent in 2025 the highest percentage, i.e.
56%.
To enhance the skills of Employees with managerial duties and promote continuous development, the Bank has
invested in various training channels and initiatives. Continuous learning is ensured through specialized
leadership journeys and learning paths provided on the Bank’s online platform as well as proper training via ACE
Academies’ webinars and eLearnings. In 2025, a structured Career Development Conversation framework was
introduced for Employees at mid-level seniority and Managers, aiming to foster professional growth and
progression. The Learning Strategy was revamped to include an enhanced onboarding and induction program,
while role-specific learning paths were introduced. As part of the cultural transformation initiative, more than 50
interactive workshops were conducted across the Organization and approximately 600 Employees across the
Bank were certified in Change Management principles. Sales and customer experience capabilities were elevated
as key priorities for Relationship Manager roles. To invest in future-ready skills, a new Academy was established
for IT and Cybersecurity, offering dedicated learning pathways for all roles in these areas.
In line with the Bank’s standard practice, the Executive Members of the Board of Directors do not receive
remuneration in their capacity as Board Members.
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
232 | ANNUAL FINANCIAL REPORT
Special Annual Report
on Gender Balance on the
Board of Directors
The Special Annual Report (the “Report”) relating to the gender balance among the
Members of the Board of Directors of the Bank, in accordance with article 3C par. 1 of Law
4706/2020 as well as with the Letter No. 12678/8.9.2025 from the General Secretariat for
Equality and Human Rights of the Ministry of Social Cohesion and Family Affairs, was
submitted to the Hellenic Capital Market Commission (HCMC), to the Documentation,
Research and Digital Support Department (Gender Equality Observatory) of the Genera l
Secretariat for Equality and Human Rights of the Ministry of Social Cohesion and Family and
to the Ombudsman. The Report is available on the Bank’s website, at
https://www.alpha.gr/-/media/AlphaGr/Files/Group/etairiki-diakybernisi/Alpha-
Bank_Special-Annual-Report-on-Gender-Balance-on-the-BoD_2025-ENG.pdf.
Information on the implementation of the percentage set out in article 3A par. 3 and on the
number of the Executive, the Non-Executive and the Independent Non-Executive Board
Members belonging to the underrepresented gender is provided in the table below:
Considering the above, the Bank is already fully compliant with the provisions of article 3A
par. 3 of Law 4706/2020 regarding the gender-balanced representation on its Board of
Directors. In particular, five (5) out of eleven (11) Members of the current Board belong to
the underrepresented gender, resulting in a percentage of 45% in relation to the total
number of Board Members. As a result, not only the 25% requirement but also the 33%
requirement with respect to the total number of the Bank’s Board Membe rs are fulfilled.
Furthermore, it is noted that there are only two (2) Executive Members on the Board of
Directors of Alpha Bank, and thus, article 3A par. 4 of Law 4706/2020 is not applicable.
The Bank’s Suitability and Nomination Policy for the Members of the Board of Directors and
Key Function Holders, as approved by its Ordinary General Meeting of Shareholders dated
21.5.2025, following the relevant recommendation of the Board of Directors and the
Corporate Governance, Sustainability and Nominations Committee, has already been
harmonized with the amendments made to Law 4706/2020 following the adoption of Law
5178/2025. In particular, notwithstanding the entry into force of the provisions of article 3A
(3), (4) and (5) and article 3B of Law 4706/2020 on 30.6.2026, the above harmonization was
already considered best practice at this point in time.
Furthermore, it is noted that the Bank, through the upcoming election of its Board of
Directors in 2026, shall continue to encourage the candidacy of the underrepresented
gender in order to maintain the abovementioned high percentages (as in the current
composition).
Total
Members
Male
Members
Female
Members
Percentage of Members
of the underrepresented
gender (%)
Members
11
6
5
45%
Executive Members
2
2
0
0%
Non-Executive Members
1
0
1
100%
Independent Non-Executive
Members
8
4
4
50%
Recent Minutes of the Board
of Directors pertaining to its
constitution into a body
Following its resolution dated 13.6.2025, the Board of Directors
was constituted into a body and granted authorization
regarding the representation of the Bank.
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
233 | ANNUAL FINANCIAL REPORT
I1.
REMUNERATION
Our Bank’s and Group’s remuneration practices are consistent with the applicable legal
and regulatory framework, as in force, including Law 4261/2014 [which transposed
European Directive 2013/36/EU (CRD IV)], Law 4548/2018 as well as the Bank of Greece
Executive Committee Act No 231/15.7.2024 which transposed EBA Guidelines on sound
remuneration policies under Directive 2013/36/EU.
Τhe Ordinary General Meeting of the Bank dated 21.5.2025, following a relevant
recommendation by the Board of Directors and the Remuneration Committee and in view
of the completion of the merger by absorption of Alpha Services and Holdings S.A. by the
Bank and the listing of the Bank’s shares on the Main Market of the Athens Exchange,
approved and adopted the Remuneration Policy of the Members of the Board of
Directors, in accordance with articles 110 and 111 of Law 4548/2018, as approved by the
Ordinary General Meeting of the Shareholders of Alpha Services and Holdings S.A. on
21.5.2025.
The Remuneration Policy of the Members of the Board of Directors, in accordance with
articles 110 and 111 of Law 4548/2018, is available on the Bank’s website, as stipulated by
Law, through the link https://www.alpha.gr/-/media/AlphaGr/Files/Group/etairiki-
diakybernisi/Remuneration-Policy-of-the-Members-of-the-BoD_ENG.pdf.
The Board of Directors’ remuneration is determined by the Ordinary General Meeting of
the Shareholders of the Bank, upon recommendation of the Board of Directors, following
a proposal by the Remuneration Committee.
It is noted that, in accordance with the Bank’s standard practice, the Executive Members
of the Board of Directors do not receive any remuneration in their capacity as Members of
the Board of Directors. The Executive Members of the Board of Directors participate in the
Stock Option Plan and the Stock Award Program approved by the Bank as detailed below.
The Ordinary General Meeting of the Bank dated 21.5.2025, following a relevant
recommendation by the Board of Directors and in view of the completion of the merger
by absorption of its parent company “Alpha Services and Holdings S.A.” by the Bank,
approved the Stock Option Plan, as approved by the Ordinary General Meeting of the
Shareholders of Alpha Services and Holdings S.A. on 31.7.2020 (then Alpha Bank S.A.), and
decided to continue its implementation for the period following the completion of the
merger.
The Extraordinary General Meeting of the Bank dated 12.6.2025, taking into consideration
the relevant recommendation of the Board of Directors as well as the applicable legal and
regulatory framework and the international best practice, following the approval of the
merger by absorption of Alpha Services and Holdings S.A. by the Bank by virtue of the
same Extraordinary General Meeting, resolved on the establishment and implementation
of a Stock Award Plan, as approved and amended by the Ordinary General Meetings of the
Shareholders of Alpha Services and Holdings dated 27.7.2023 and 21.5.2025, accordingly.
The Ordinary General Meeting of the Bank dated 21.5.2025, following the relevant
recommendation by the Board of Directors as per the respective recommendation of the
Remuneration Committee, approved the remuneration of the Non-Executive Members of
the Board of Directors, including the Independent Non-Executive Members, in their
capacity as Members, for the financial year 2025.
For more information, please refer to the Remuneration Report, which is and will remain
available on Alpha Bank’s website, at https://www.alpha.gr/-
/media/AlphaGr/Images/Group/archive-holdings/reverse-merge-files/Remuneration-
Report-2024_en_site.pdf
In particular, as regards the remuneration amounts, the following general rules apply:
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
234 | ANNUAL FINANCIAL REPORT
A. The remuneration of the Independent Non-Executive Chair of the Board of
Directors amounted to Euro 360,000 annually.
B. The remuneration, per beneficiary, for the Non-Executive Members of the Board
of Directors, in their capacity as Members of the Board of Directors, amounted to
Euro 75,000 annually.
C. The remuneration, per beneficiary, for the Non-Executive Members of the Audit
Committee of the Board of Directors amounted to Euro 30,000 annually. The
remuneration for the Chair of the Audit Committee of the Board of Directors
amounted to Euro 65,000 annually.
D. The remuneration, per beneficiary, for the Non-Executive Members of the Risk
Management Committee of the Board of Directors amounted to Euro 30,000
annually. The remuneration for the Chair of the Risk Management Committee of
the Board of Directors amounted to Euro 65,000 annually.
E. The remuneration, per beneficiary, for the Non-Executive Members of the
Remuneration Committee of the Board of Directors amounted to Euro 17,500.00
annually. The remuneration for the Chair of the Remuneration Committee of the
Board of Directors amounted to Euro 40,000 annually.
F. The remuneration, per beneficiary, for the Non-Executive Members of the
Corporate Governance, Sustainability and Nominations Committee of the Board
of Directors amounted to Euro 17,500 annually. The remuneration for the Chair
of the Corporate Governance, Sustainability and Nominations Committee of the
Board of Directors amounted to Euro 40,000 annually.
G. The remuneration for the Member in charge of coordinating the Data
Governance Framework activities shall amount to Euro 12,000 annually.
H. The role of the NPL Expert and the role of the Member in charge of overseeing
ESG issues have ceased to exist, following the resolution of the Board of Directors
dated 27.2.2025, and, as a result, the relevant fees were abolished, effective as
of March 1, 2025.
I. No Member is paid for participation in more than three Committees of the Board
of Directors.
J. A Member of the Board of Directors who is at the same time a Member of the
Audit Committee and of the Risk Management Committee is paid for
participation in only one of these Committees. Only if the Member of the Board
of Directors is the Chair in one of the abovementioned Committees, is he/she
paid for participation in both.
K. The Non-Executive Member, Ms. A.G. Areni (as of 27.2.2025) did not receive any
remuneration following the decision to waive in full any and all compensation,
fees or other forms of remuneration to which she may be entitled in her capacity
as Non-Executive Member of the Board of Directors of the Bank as of her
appointment.
BOARD OF DIRECTORS’ MANAGEMENT REPORT AS AT 31.12.2025
235 | ANNUAL FINANCIAL REPORT
J.
The Bank, during the collection and processing of data of its Customers, Employees, and
external partners, using artificial intelligence systems or other technological means, acts
responsibly by ensuring transparency, legality, and respect for privacy. Specifically, it is
committed to applying strict ethical data management rules, complying with legislation,
and protecting individual rights by adhering to the following key principles for data usage:
• Legality and Transparency: Data is processed in accordance with the relevant
legislation, including banking secrecy laws and personal data protection laws, for
clearly defined and transparent purposes. The Bank informs clearly the data subjects
about what data is collected, how it is used and why it is being processed.
• Purpose Limitation: Data is used exclusively for defined and legitimate purposes.
• Data Minimization: Only the necessary data for each use is collected.
• Security and Protection: Technical and organizational measures are applied to
protect data from unauthorized access or leakage, as well as to ensure the its
integrity and availability.
• Accountability: The Bank ensures that all Employees and partners comply with the
principles of ethical data use and continuously trains its staff on this matter.
• Outsourcing Data Processing to Third Parties: In cases where data processing is
outsourced, the Group uses only third parties that provide sufficient assurances for
the application of current legislation and appropriate technical and organizational
measures to protect the data.
• Respect for the Rights of Data Subjects: Data is used in a manner that ensures
respect for the rights of data subjects, without discrimination or unfairness.
Furthermore, the ability to exercise the rights provided by the relevant legislation is
made available.
• Automated Decision Making: In cases where data processing is done through
automated means for decision-making purposes, the data subject is informed
accordingly, their consent is obtained (if required) and the possibility for human
intervention (review of the request) is provided.
• Record Keeping: A Data Processing Activities Log and a Registry of Systems using
Artificial Intelligence are continuously maintained and updated.
• Integration of Key Principles: The protection of data and the rights of data subjects is
also ensured through the relevant Policy Framework and procedures for all stages of
each project, whether it involves systems or processes.
INFORMATION REGARDING
ARTICLE 10 OF
LAW 4961/2022
“EMERGING
INFORMATION
AND
COMMUNICATION
TECHNOLOGIES,
STRENGTHENING
DIGITAL
GOVERNANCE,
AND OTHER
PROVISIONS”
Athens, February 26, 2026
THE CHAIRMAN
OF THE BOARD OF DIRECTORS
THE CHIEF
EXECUTIVE OFFICER
DIMITRIOS C. TSITSIRAGOS
ID No A 00808440
VASSILIOS E. PSALTIS
ID No A 02206685
TRUE TRANSLATION FROM THE ORIGINAL IN THE GREEK LANGUAGE
Independent Auditor’s Limited Assurance Report on Alpha Bank S.A.’s Sustainability Statement
INDEPENDENT AUDITOR’S LIMITED ASSURANCE REPORT
To the Shareholders of Alpha Bank S.A.
We have conducted a limited assurance engagement on the consolidated Sustainability Statement of Alpha Bank S.A.
(henceforth the “Bank) and its subsidiaries (collectively the “Group”), included in section “Sustainability Statement FY
2025” of the consolidated Board of Directors’ Annual Report (the “Sustainability Statement”), for the period from
01/01/2025 to 31/12/2025.
Limited Assurance Conclusion
Based on the procedures we have performed, as described below in the “Scope of Work Performed” paragraph, and the
evidence we have obtained, nothing has come to our attention that causes us to believe that:
• the Sustainability Statement has not been prepared in all material respects, in accordance with Article 154 of Law
4548/2018, as amended by Law 5164/2024 and currently in force, based on which, Article 29(a) of EU Directive
2013/34 was transposed into Greek legislation;
• the Sustainability Statement does not comply with the European Sustainability Reporting Standards (hereinafter
“ESRS”), in accordance with EU Regulation 2023/2772 of the Commission of 31 July 2023, and EU Directive
2022/2464 of the European Parliament and the Council of 14 December 2022;
• the process carried out by the Group to identify and assess material impacts, risks and opportunities (the
“Process”), as set out in Note “[IRO-1] Description of the process to identify and assess material impacts, risks and
opportunities” of the Sustainability Statement, does not comply with the “Disclosure Requirement IRO-1-
Description of the process to identify and assess material impacts, risks and opportunities” of ESRS 2 “General
Disclosures”;
• the disclosures included in section “Disclosures pursuant to Article 8 of Regulation 2020/852 (“EU Taxonomy
Regulation”)” of the Sustainability Statement, do not comply with Article 8 of EU Regulation 2020/852.
Basis for Conclusion
We conducted a limited assurance engagement in accordance with International Standard on Assurance Engagements
3000 (Revised), “Assurance Engagements Other than Audits or Reviews of Historical Financial Information” (“ISAE
3000”).
The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a
reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is
substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been
performed.
Our responsibilities are further described in the “Auditor’s Responsibilities” section of our report.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion.
Deloitte Certified Public
Accountants S.A.
3a Fragkokklisias & Granikou str.
Marousi Athens GR 151-25
Greece
Tel: +30 210 6781 100
www.deloitte.gr
T R UE
Professional Ethics and Quality Management
We are independent of the Bank and the Group, during the whole period of this engagement and we have complied with
the requirements of the International Code of Ethics for Professional Accountants issued by the International Ethics
Standards Board for Accountants (IESBA Code), the ethical and independence requirements of Law 4449/2017 and EU
Regulation 537/2014.
Our audit firm applies the International Standard on Quality Management 1 (ISQM 1), “Quality Management for firms
that perform audits or reviews of financial statements, or other assurance or related services engagements” and
accordingly, maintains a comprehensive system of quality management, including documented policies and procedures
regarding compliance and ethical requirements, professional standards and applicable legal and regulatory
requirements.
Management’s Responsibilities Regarding the Sustainability Statement
Management of the Bank is responsible for designing and implementing a process to identify the information reported in
the Sustainability Statement, in accordance with ESRS, and for disclosing this Process in Note “[IRO-1] Description of the
process to identify and assess material impacts, risks and opportunities” of the Sustainability Statement.
This responsibility includes:
• Understanding the context in which the Bank’s and the Group’s activities and business relationships take place
and developing an understanding of its affected stakeholders.
• • The identification of the actual and potential impacts (both negative and positive) related to sustainability
matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the Bank’s and
the Group’s financial position, financial performance, cash flows, access to finance or cost of capital over the
short, medium, or long-term.
• The assessment of the materiality of the identified impacts, risks and opportunities related to sustainability
matters by selecting and applying appropriate thresholds, and
• Making assumptions that are reasonable in the circumstances.
Management of the Bank is further responsible for the preparation of the Sustainability Statement, in accordance with
Article 154 of Law 4548/2018, as amended by Law 5164/2024 and currently in force, based on which, Article 29(a) of EU
Directive 2013/34 was transposed into Greek legislation.
In this context, Management’s responsibility includes:
• Compliance of the Sustainability Statement with ESRS.
• Preparing the disclosures in section “Disclosures pursuant to Article 8 of Regulation 2020/852 (“EU Taxonomy
Regulation”)” of the Sustainability Statement, in compliance with Article 8 of EU Regulation 2020/852.
• Designing implementing and maintaining such internal controls that management determines are necessary to
enable the preparation of the Sustainability Statement is free from material misstatement, whether due to fraud
or error.
• The selection and application of appropriate sustainability reporting methods and making assumptions and
estimates about individual sustainability disclosures that are reasonable in the circumstances.
The Audit Committee of the Bank is responsible for overseeing the sustainability reporting process of the Group.
Inherent Limitations in Preparing the Sustainability Statement
As discussed in Notes “Entity-Specific Information” and “CONTRIBUTION TO HEALTHY ECONOMIES” in the Sustainability
Statement, sustainability information for which the applicable criteria are self-defined, the nature of this sustainability
information, and absence of consistent external standards, allow for different, but acceptable, measurement
methodologies to be adopted which may result in variances between entities. The adopted measurement methodologies
may also impact the comparability of sustainability matters reported by different entities and from year to year within an
entity as methodologies develop.
In reporting forward-looking information in accordance with ESRS, Management of the Bank is required to prepare the
forward-looking information on the basis of disclosed assumptions about events that may occur in the future and
possible future actions by the Bank and the Group. The actual outcome is likely to be different since anticipated events
frequently do not occur as expected.
As discussed in Note “ESRS E1 CLIMATE CHANGE”, the sustainability information includes, among others, information
based on climate-related scenarios, that is subject to inherent uncertainty regarding the likelihood, timing or effect of
possible future physical and transitional climate-related impacts.
Our work covered the subject matters listed in the section “Scope of Work Performed” for obtaining limited assurance
and is based on the procedures included in the Program, as defined in this section of our report. Our work does not
constitute an audit or review of historical financial information in accordance with the applicable International Standards
on Auditing or International Standards on Review Engagements, and for this reason, we do not provide any other
assurance beyond what is stated in the section “Scope of Work Performed”.
Auditor’s Responsibilities
This limited assurance report has been prepared based on the provisions of Article 154C of Law 4548/2018 and Article
32A of Law 4449/2017.
Our responsibility is to plan and perform the limited assurance engagement to obtain limited assurance about whether
the Sustainability Statement is free from material misstatement, whether due to fraud or error and to issue a limited
assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material
when, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users
taken on the basis of the Sustainability Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE 3000, we exercise professional judgment and
maintain our professional skepticism throughout the engagement.
Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:
• Performing risk assessment procedures, including obtaining an understanding of internal controls relevant to the
engagement, to identify risks in the Process applied by the Group to identify the information reported in the
Sustainability Statement does not address the applicable requirements of the ESRS, but not for the purpose of
providing a conclusion on the effectiveness of the Process, including the outcome of the Process; and
• Designing and performing procedures to evaluate whether the Process to identify the information reported in the
Sustainability Statement is consistent with the Bank’s description of its Process as disclosed in Note “[IRO-1]
Description of the process to identify and assess material impacts, risks and opportunities”.
In addition, we are responsible for:
• Performing risk assessment procedures, including obtaining an understanding of internal control relevant to the
engagement, to identify disclosures where material misstatements are likely to arise, whether due to fraud or
error, but not for the purpose of providing a conclusion on the effectiveness of the Group’s internal controls.
• Designing and performing procedures responsive to disclosures in the consolidated Sustainability Statement,
where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting
from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional
omissions, misrepresentations, or the override of internal controls.
This document has been prepared by Deloitte Certified Public Accountants Societe Anonyme.
Deloitte Certified Public Accountants Societe Anonyme, a Greek company, registered in Greece with registered number 0001223601000 and its registered
office at Marousi, Attica, 3a Fragkokklisias & Granikou str., 151 25, is one of the companies of the Deloit te Central Mediterranean S.r.l. (“DCM”) geography.
DCM, a company limited by guarantee registered in Italy with registered number 09599600963 and its registered office at Via Santa Sofia no.28, 20122,
Milan, Italy is one of the Deloitte NSE LLP geographies. Deloitte NSE LLP is a UK limited liability partnership and member firm of of Deloitte Touche
Tohmatsu Limited, a UK private company limited by guarantee.
DTTL and each DTTL member firm and related entity is liable only for its own acts and omissions, and not those of any of each other. DTTL does not provide
services to clients. Please see http://www.deloitte.com/to learn more.
© 2026 For more information contact Deloitte Central Mediterranean.
Scope of Work Performed
Our work involves performing procedures and obtaining audit evidence to form a limited assurance conclusion and are
limited to the procedures listed in the limited assurance program issued by the Board of Directors of the Hellenic
Accounting and Auditing Supervisory Oversight Board according to its 262/22.01.2025 decision (hereinafter the
“Program”), developed for the purpose of issuing of a limited assurance report on the Group’s Sustainability Statement.
Our procedures were designed for the purpose of obtaining a limited level of assurance to support our conclusion but
not for obtaining evidence that would be required to provide a reasonable level of assurance.
Athens, 26 February 2026
The Certified Public Accountant
Dimitris Katsibokis
Reg. No SOEL: 34671
Deloitte Certified Public Accountants S.A.
3a Fragoklissias & Granikou Str.
15125 Marousi
Reg. No SOEL: E120
TRUE TRANSLATION FROM THE ORIGINAL IN GREEK
INDEPENDENT AUDITOR’S REPORT
To the Shareholders of Alpha Bank S.A.
Report on the Audit of the Separate and Consolidated Financial Statements
Opinion
We have audited the separate and consolidated financial statements of Alpha Bank S.A. (the Bank), which comprise the
separate and consolidated balance sheet as at 31 December 2025, and the separate and consolidated income statement,
statements of comprehensive income, changes in equity and cash flows for the year then ended and the notes to the
financial statements, including material accounting policy information.
In our opinion, the accompanying separate and consolidated financial statements present fairly, in all material respects,
the financial position of Alpha Bank S.A. and its subsidiaries (the Group) as at 31 December 2025, their financial
performance and their cash flows for the year then ended in accordance with International Financial Reporting
Standards (IFRSs), as endorsed by the European Union.
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing (ISAs) as they have been incorporated
into the Greek legislation. Our responsibilities under those standards are further described in the “Auditor’s
Responsibilities for the Audi t of the Separate and Consolidated Financial Statements” section of our report. We have
been independent of the Bank and the Group during the whole period of our appointment, in accordance with the
International Ethics Standards Board for Accountants’ Cod e of Ethics for Professional Accountants (IESBA Code) as
applied in financial statements audits of public interest entities and the ethical requirements in Greece, relevant to the
audit of the separate and consolidated financial statements. We have fulfilled our ethical requirements in accordance
with the applicable legislation and the abovementioned Code of Ethics. We believe that the audit evidence we have
obtained is sufficient and appropriate to provide a basis for our opinion.
Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the
separate and consolidated financial statements of the current year. These matters and the assessed risks of material
misstatements were addressed in the context of our audit of the separate and consolidated financial statements as a
whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.
Deloitte Certified Public
Accountants S.A.
3a Fragkokklisias & Granikou str.
Marousi Athens GR 151-25
Greece
Tel: +30 210 6781 100
www.deloitte.gr
Key audit matters
How our audit addressed the Key audit matters
Allowance for expected credit losses (ECL) for loans at amortized cost
Loans at amortized cost of the Bank and the Group as at 31
December 2025 excluding Collateralized Loan Obligations
(CLOs) amounted to € 39,489 million and € 42,075 million,
respectively (31.12.2024: € 36,954 million and € 38,440
million, respectively) and allowance for expected credit
losses amounted to € 570 million for the Bank and € 637
million for the Group as at 31 December 2025 (31.12.2024: €
570 million and € 601 million, respectively).
Measurement of Expected Credit Loss (ECL) on loans at
amortized cost is considered a key audit matter as the
determination of assumptions used, involves critical
management judgments and accounting estimates with high
level of subjectivity and complexity.
The most significant management judgements and
accounting estimates, relate to:
• The criteria used for the staging assessment of loans at
amortized cost (Significant Increase in Credit Risk –SICR
and Unlikeness to Pay –UTP).
• The determination of credit risk parameters, such as
Loss Given Default (LGD), Probability of Default (PD) and
the Exposure at Default (EAD) as well as the modelling
assumptions and data used to build and run the credit
risk models (the models).
• Assumptions for the determination of expected future
cash flows of individually assessed credit impaired
exposures, including assessment approach, valuation of
collaterals and the time to liquidate the collaterals.
• The forecast of each significant forward-looking
information (growth rates, unemployment, inflation and
real estate indices) used by management in the models,
and the probability weightings used to estimate the
impact of multiple economic scenarios.
• The Identification and valuation of post model
adjustments made by management to include any
impact not captured by the models.
Management has provided further information about
accounting policies for determining the ECL on loans at
amortized cost and management of credit risk in notes
1.2.13, 1.3, 12, 24 and 49.1 to the separate and consolidated
financial statements.
Based on our risk assessment and following a risk-based
approach, we have evaluated the impairment methodologies
applied and assumptions made by management in relation to
this key audit matter, and we performed, inter alia, the
following audit procedures:
• With the support of our financial risk modelling specialists
where appropriate, we assessed the design and
implementation of relevant internal controls over the ECL
estimate including the controls around:
- the incorporation of the model’s outcome within the
relevant systems and the calculation of the ECL
estimate
- the significant assumptions used in the models
- model monitoring and model validation
- governance and review of post model adjustments
- the determination of staging criteria and staging
allocation
- the selection of the significant forward-looking
information used in the models
- the selection of macro-economic scenarios and
probability weightings and
- accuracy and completeness of data used in models.
When considered appropriate we further tested the
operating effectiveness of selective controls.
• We assessed the design and implementation of relevant
controls over the ECL measurement of credit impaired
exposures assessed on an individual basis, including
controls around the determination of the appropriate
approach, the valuation and time to liquidation of
collaterals as well as the estimation of the expected future
cash flows and for selected controls we further tested
whether they operated effectively.
• With the support of our financial risk modelling specialists
we:
- assessed the appropriateness of the Group’s IFRS9
impairment policies and methodologies;
- assessed the appropriateness of the criteria used to
allocate loans to stages in accordance with IFRS9. This
included an evaluation of the criteria set by
management for determining the Significant Increase
in Credit Risk (SICR) or the Unlikeness to Pay (UTP)
trigger and other criteria used for staging allocation.
On a sample basis, assessed the timely identification of
SICR, UTP and other criteria used for staging
allocation;
- inspected the model codes (development) and
assessed the appropriateness of the significant credit
risk parameters (i.e. Loss Given Default-LGD,
Probability of Default –PD, Exposure at Default –EAD),
used in the models;
Key audit matters
How our audit addressed the Key audit matters
Allowance for expected credit losses (ECL) for loans at amortized cost (continued)
- assessed the validation reports prepared by
management through reperformance of certain
validation metrics;
- on a sample basis tested the mathematical accuracy of
the ECL estimate through recalculation;
- assessed the reasonableness and appropriateness of
the significant forward-looking information, used in
the models by comparing them to external market
sources and the probability weighted scenarios utilised
in the ECL calculation.
• We further performed substantive procedures to test
the accuracy and completeness of critical data used in
the models by agreeing a sample of ECL calculation data
points to source systems or documentation.
• On a sample basis we assessed whether, the approach
used in the measurement of impairment for the
individually assessed credit impaired exposures is
appropriate, and we tested the reasonableness of
significant assumptions used, including valuation of
collaterals (where we also made use of our real estate
specialists), time to liquidate collaterals, and the
estimation of the discounted future cash flows.
• We assessed the accuracy and completeness of post
model adjustments, made by management in order to
incorporate the impact of assumptions not captured by
the models. In addition, when considered necessary, we
assessed any contradictory evidence and performed
retrospective review.
• Given the complexity and granularity of the related
disclosures, we assessed their completeness and
accuracy in accordance with the provisions of the
relevant accounting standards.
Key audit matters
How our audit addressed the Key audit matters
Fair Value measurement of net assets acquired in the context of Group significant business acquisitions
During the current year, the Group executed significant
acquisitions aligned with its strategic growth objectives.
Specifically, the Group acquired:
a) 100% ownership at FlexFin Ltd,
b) certain assets, liabilities and key personnel from
Astrobank Public Company Ltd in Cyprus,
c) 100% of AXIA Ventures Group Ltd incorporated in Cyprus
and
d) a portfolio of real estate companies holding commercial
real estate assets in Greece and Cyprus.
Total purchase price consideration for these acquisitions
amounted to €405 million, total net assets acquired and the
goodwill recognized at Group financial statements
amounted to €329 million and €83 million, respectively
while transaction expenses amounted to € 7 million.
The aforementioned acquisition transactions are considered
a key audit matter since they are significant for the Group,
complex and involve a high degree of management
judgement and significant accounting estimates in the fair
value measurement of the assets acquired, including
goodwill, and liabilities assumed, including deferred
considerations, at the acquisition date.
Management has disclosed further details regarding these
acquisition transactions and the accounting principles and
policies applied in determining the fair values of acquired
assets and liabilities, as well as the goodwill recognised, in
notes 1.2.7,1.2.10,1.3, 49.4 and 56 to the separate and
consolidated financial statements.
Based on our risk assessment, we evaluated the judgments
and assumptions made by management in relation to this
key audit matter.
Our evaluation included, inter alia, the following audit
procedures:
• We assessed the design and implementation of the
relevant internal controls over the significant
transactions, including controls over the review and
approval process of the transactions as well as the
review of the fair value measurement including the
review of the methods and assumptions used.
• We examined the governance processes over these
transactions, including the oversight exercised and the
approvals granted by the Board of Directors and the
relevant committees.
• We examined the sale-purchase agreements, and other
supporting documentation to assess whether the
accounting treatment applied to these transactions at
Group financial statements complies with the relevant
provisions of IFRSs.
• With the support of our internal valuation specialist:
- we reviewed management’s valuation reports
prepared for each transaction and assessed whether
valuation methods used for the purpose of
determing the fair values of assets acquired,
including goodwill and liabilities assumed, including
deferred considerations, are appropriate
- we assessed the reasonableness of the significant
assumptions used in these valuations, including cash
flows assumptions, growth rate, discount rate,
probability weighting scenarios and market
multiples (to the extend relevant to the method
applied)
• We examined and assessed the accuracy and
completeness of the accounting entries performed at
Group level.
• We evaluated the accuracy and completeness of the
related disclosures in accordance with the requirements
of the relevant IFRSs.
Key audit matters
How our audit addressed the Key audit matters
Recoverability of Deferred Tax Asset (DTA)
The Bank and the Group has recognized deferred tax assets
of € 4,812 million and €4,816 million respectively, as at 31
December 2025 (€ 4,770 million and € 4,807 million
respectively as at 31 December 2024).
The recognition and measurement of the deferred tax asset
is considered a key audit matter as it involves a high degree
of management judgment and significant accounting
estimates.
The most significant judgements and estimates made by
management for assessing the recoverability of deferred tax
assets include:
• Revenue and Cost forecasts for the preparation of the
annual budget and the 3 year business plan taking into
account the impact of the Group’s strategic plan.
• Forward looking information and management
projections used to extend the period covered under
the business plan to the time when the deferred tax
asset can be utilized for tax purposes.
• Ability of the Bank to utilize tax losses, derived from the
reverse merger with Alpha Services and Holdings S.A.,
against future profits within the eligible period as
provided by tax legislation.
• Adjustments required for the conversion of accounting
profits to taxable profits.
Management has provided further information about the
deferred tax asset in notes 1.2.15, 1.3, 18 and 30 to the
separate and consolidated financial statements.
Based on our risk assessment, we evaluated the method
used to determine the amount of deferred tax asset
recognized and examined the related DTA exercise prepared
by management.
Our examination included, inter alia, the following audit
procedures and when considered necessary we were also
supported by our tax specialists:
• We assessed the design and implementation of the
relevant internal controls over the preparation and
approval of the annual budget and the 3year business
plan as well as over the forward looking information,
including the internal controls over the significant
assumptions, inputs, calculation and methodologies
used for this purpose.
• We compared prior years’ budgets to actual results, to
evaluate the forecasting ability of management.
• We compared the significant assumptions used by
management in the DTA exercise with the approved
budget and the 3 year business plan for consistency.
• We assessed whether significant assumptions used
beyond the business plan period were reasonable in the
context of the long - term economic outlook.
• We assessed whether, based on the DTA exercise, the
deferred tax calculated on the tax losses derived from
the reverse merger with Alpha Services and Holdings
S.A., considers the expiration period as provided by the
tax legislation.
• We examined the appropriateness of the adjustments
made by management to convert the forecasted
accounting profits into tax profits, considering the tax
legislation currently in force.
• We evaluated the accuracy and completeness of the
related disclosures in accordance with the provisions of
the relevant accounting standards.
Key audit matters
How our audit addressed the Key audit matters
Information Technology General Controls and controls over financial reporting
The Bank’s and the Group’s financial reporting processes are
highly dependent on Information Technology (“IT”) systems
supporting automated accounting and reconciliation
procedures, thus leading to a complex IT environment,
pervasive in nature and in which a significant number of
transactions are processed daily, across numerous locations.
This is a key audit matter since it is important that controls
over access security, cyber risks, system change control and
datacenter and network operations, are designed and
operate effectively to ensure complete and accurate
financial records and information.
Management has provided further information about
General Information Technology Controls under the header
“Internal Control System ICS” in Section C of the Corporate
Governance Statement.
Based on our risk assessment, we have tested the design and
operating effectiveness of General Information Technology
Controls (GITCs) relevant for financial reporting. Our
assessment included the evaluation of user access and the
change management process over applications, operating
systems and databases, as well as the evaluation of
datacenter and network IT operations. In summary, our key
audit activities included, among others, testing of:
• User access provisioning and de provisioning process.
• Privileged access to applications, operating systems and
databases.
• Periodic review of user access rights in Information
Systems.
• Change management process over applications,
operating systems and databases (i.e. user request, user
acceptance testing and final approval for promotion to
production).
• Datacenter and network operations.
Other Information
Management is responsible for the other information. The other information, included in the Annual Report prepared in
accordance with Law 3556/2007, comprises the Board of Directors’ Report, referred to in the section “Report on Other
Legal and Regulatory Requirements” and the Statements by the Members of the Board of Directors, but does not include
the separate and consolidated financial statements and our auditor’s report thereon.
Our opinion on the separate and consolidated financial statements does not cover the other information and we will not
express any form of assurance conclusion thereon.
In connection with our audit of the separate and consolidated financial statements, our responsibility is to read the other
information and, in doing so, consider whether the other information is materially inconsistent with the separate and
consolidated financial statements, or our knowledge obtained in the audit, or otherwise appears to be materially
misstated. If, based on the work we have performed, we conclude that there is a material misstatement in this other
information, we are required to report that fact. We have nothing to report in this regard.
Responsibilities of Management and Those Charged with Governance for the Separate and Consolidated Financial
Statements
Management is responsible for the preparation and fair presentation of the separate and consolidated financial
statements in accordance with IFRSs, as endorsed by the European Union, and for such internal control as management
determines is necessary to enable the preparation of separate and consolidated financial statements that are free from
material misstatement, whether due to fraud or error.
In preparing the separate and consolidated financial statements, management is responsible for assessing the Bank’s and
the Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using
the going concern basis of accounting unless management either intends to liquidate the Bank and the Group or to cease
operations, or has no realistic alternative but to do so.
The Audit Committee (article 44 of Law 4449/2017) of the Bank is responsible for overseeing the Bank’s and Group’s
financial reporting process.
Auditor’s Responsibilities for the Audit of the Separate and Consolidated Financial Statements
Our objectives are to obtain reasonable assurance about whether the separate and consolidated financial statements as
a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that
includes our opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in
accordance with ISAs, as these have been incorporated into Greek legislation, will always detect a material misstatement
when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the
aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these
separate and consolidated financial statements.
As part of an audit in accordance with ISAs, as these have been incorporated into Greek legislation, we exercise
professional judgment and maintain professional scepticism throughout the audit. We also:
• Identify and assess the risks of material misstatement of the separate and consolidated financial statements,
whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit
evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material
misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion,
forgery, intentional omissions, misrepresentations, or the override of internal control.
• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the
Bank’s and Group’s internal control.
• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and
related disclosures made by management
• Conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on
the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast
significant doubt on the Bank’s and Group’s ability to continue as a going concern. If we conclude that a material
uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the
separate and consolidated financial statements or, if such disclosures are inadequate, to modify our opinion. Our
conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future
events or conditions may cause the Bank and the Group to cease to continue as a going concern.
• Evaluate the overall presentation, structure and content of the separate and consolidated financial statements,
including the disclosures, and whether the separate and consolidated financial statements represent the
underlying transactions and events in a manner that achieves fair presentation.
• Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial
information of the entities or business units within the Group as a basis for forming an opinion on consolidated
financial statements. We are responsible for the direction, supervision and review of the audit work performed
for the purposes of the group audit. We remain solely responsible for our audit opinion.
We communicate with those charged with governance regarding, among other matters, the planned scope and timing of
the audit and significant audit findings, including any significant deficiencies in internal control that we identify during
our audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical
requirements regarding independence and communicate with them all relationships and other matters that may
reasonably be thought to impair our independence, and where applicable, related safeguards applied.
From the matters communicated with those charged with governance, we determine those matters that were of most
significance in the audit of the separate and consolidated financial statements of the current year and are therefore the
key audit matters.
Report on other Legal and Regulatory Requirements
1. Board of Directors’ t Report
Taking into consideration that management is responsible for the preparation of the Board of Directors’ Report
which also includes the Corporate Governance Statement, according to the provisions of paragraph 1, sub
paragraphs aa), ab) and b) of article 154C of Law 4548/2018, which however do not include the Sustainability
Statement, for which we have issued a related limited assurance report according to International Standard on
Assurance Report 3000 (Revised) dated 26 February 2026, we note the following:
a) The Board of Directors’ Management Report includes the Corporate Governance Statement which
provides the information required by article 152 of Law 4548/2018.
b) In our opinion, the Board of Directors’ Management Report has been prepared in accordance with the
applicable legal requirements of articles 150 and 153 of Law 4548/2018, except for the provisions relating
to the submission of the Sustainability Statement of paragraph 5A of article 150 of this Law, and its
content is consistent with the accompanying separate and consolidated financial statements for the year
ended 31 December 2025.
c) Based on the knowledge we obtained during our audit of the Bank and the Group and its environment, we
have not identified any material inconsistencies in the Board of Directors’ Management Report.
2. Additional Report to the Audit Committee
Our audit opinion on the accompanying separate and consolidated financial statements is consistent with the
additional report to the Audit Committee of the Bank referred to in Article 11 of the European Union (EU)
Regulation 537/2014.
3. Non-audit Services
We have not provided to the Bank and the Group any prohibited non-audit services referred to in Article 5 of EU
Regulation 537/2014.
The allowable non-audit services we have provided to the Bank and the Group during the year ended 31
December 2025 are disclosed in note 52 to the accompanying separate and consolidated financial statements.
4. Appointment
We were first appointed as statutory auditors by the general assembly of the shareholders of the Bank on 30 June
2017. Our appointment has been, since then, uninterruptedly renewed by the annual general assembly of the
shareholders for nine consecutive years.
5. Internal Regulation
The Bank retains an Internal Regulation according to the provisions of article 14 of Law 4706/2020.
6. Assurance Report on European Single Electronic Format Reporting
Subject Matter
We have undertaken the reasonable assurance work to examine the digital archives of Alpha Bank S.A. (the Bank
or/and the Group), which have been prepared in accordance with the European Single Electronic
Format (ESEF),including the separate and consolidated financial statements of the Bank for the year ended 31
December 2025, in XHTML format, as well as the envisaged iXBRL file (213800DBQIB6VBNU5C64-2025-12-31-1-
el.xbri) with the appropriate tagging on the above consolidated financial statements, including the notes to the
these financial statements (the Subject Matter), in order to conclude whether they been prepared in accordance
with the requirements set out in the section Applicable Criteria.
6. Assurance Report on European Single Electronic Format Reporting (Continued)
Applicable Criteria
The Applicable Criteria for the European Single Electronic Format (ESEF) are laid down in European Commission
Delegated Regulation (EU) 2019/815, as amended by Regulation (EU) 2020/1989 (the ESEF Regulation) and
2020/C 379/01 European Commission interpretative communication of 10 November 2020, as provide by Law
3556/2007 and the related announcements of the Securities and Exchange Commission and the Athens Stock
Exchange. In summary, these criteria provide, inter alia, that:
- Annual financial reports should be prepared in XHTML format.
- With respect to the consolidated financial statements prepared in accordance with International Financial
Reporting Standards, financial information included in the consolidated Balance Sheet, Income statement,
total comprehensive income, statement of changes in equity and statement of cash flows as well as
financial information included in the notes to these financial statements shall be tagged with iXBRL mark-
up (“XBRL tags” and “block tags”) in accordance with ESEF Taxonomy, as currently in force. The t echnical
specifications of ESEF, including the related taxonomy, are included in ESEF Regulatory Technical
Standards.
Responsibilities of Management and Those Charged with Governance
Management is responsible for the preparation and submission of these separate and consolidated financial
statements of the Bank for the year ended 31 December 2025, in accordance with the Applicable Criteria, as well
as for such internal control as management determines is necessary to enable the preparation of digital files free
from material misstatement, whether due to fraud or error.
Αuditor’s Responsibilities
Our responsibility is to issue this report in relation to the assessment of the Subject Matter, based on the work
performed, as described below in the section “Scope of work performed”.
Our work has been conducted in accordance with International Standard on Assurance Engagements 3000
(Revised) “Assurance engagements other than audits or review of historical financial information (ISAE 3000).
ISAE 3000 requires that we plan and perform our work so as to obtain reasonable assurance to assess the Subject
Matter in accordance with the Applicable Criteria. In the course of the assurance engagement we assess the risk
of material misstatement in the information relating to the Subject Matter.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our reasonable
assurance opinion, as set out in this report.
Professional Ethics and Quality Management
We have been independent of the Bank and the Group during the whole period of our assignment and have
comply with the requirements of of the Code of Conduct for professional Auditors of the Board of International
standards of Conduct for Auditors (Code of Ethics), the ethical and independence requirements of Law 4449/2017
and Regulation (EU) 537/2014.
Our auditing firm implements the International Quality Management Standard (ISQM) 1 ‘Quality Management for
companies that perform audits or reviews of financial statements or other assurance or related service
assignments’ and therefore maintains an integrated quality management system that includes documented
policies and procedures related to compliance with ethical requirements, professional standards and applicable
legal and regulatory requirements.
This document has been prepared by Deloitte Certified Public Accountants Societe Anonyme.
Deloitte Certified Public Accountants Societe Anonyme, a Greek company, registered in Greece with registered number
0001223601000 and its registered office at Marousi, Attica, 3a Fragkokklisias & Granikou str., 151 25, is one of the companie s
of the Deloit te Central Mediterranean S.r.l. (“DCM”) geography. DCM, a company limited by guarantee registered in Italy with
registered number 09599600963 and its registered office at Via Santa Sofia no.28, 20122, Milan, Italy is one of the Deloitte
NSE LLP geographies. Deloitte NSE LLP is a UK limited liability partnership and member firm of of Deloitte Touche Tohmatsu
Limited, a UK private company limited by guarantee.
DTTL and each DTTL member firm and related entity is liable only for its own acts and omissions, and not those of any of each
other. DTTL does not provide services to clients. Please see http://www.deloitte.com/to learn more.
© 2026 For more information contact Deloitte Central Mediterranean.
6. Assurance Report on European Single Electronic Format Reporting (Continued)
Scope of work performed
The assurance work performed, is limited to the items included in the Decision No 214/4/11-02-2022 of the
Board of Hellenic Accounting and Auditing Oversight Board (HAASOB) and the “Guidelines in connection with the
procedures and the assurance report of the certified auditors on the ESEF reported of Issuers with trading
securities on a regulated market in Greece” dated 14/02/2022, as issued by the Institute of Certified Public
Accountants, in order to obtain reasonable assurance about whether the separate and consolidated financial
statements of the Bank, prepared by management, comply in all material respects with the Applicable Criteria.
Inherent Limitations
Our work covered the items mentioned in the section "Scope of work performed" so as to obtain reasonable
assurance based on the procedures described therein. In this context, the work performed could not provide an
absolute assurance that all matters that could be considered as material weaknesses are revealed.
Conclusion
On the basis of the work performed and the evidence obtained, we conclude that the separate and consolidated
financial statements of the Bank, for the year ended 31 December 2025, in XHTML format as well as the
envisaged iXBRL file (213800DBQIB6VBNU5C64-2025-12-31-1-el.xbri) with the appropriate tagging on these
consolidated financial statements, including the notes, are prepared in all material respects in accordance with
the Applicable Criteria.
Athens, 26 February 2026
The Certified Public Accountant
Foteini D. Giannopoulou
Reg. No. SOEL: 24031
Deloitte Certified Public Accountants S.A.
3a Fragoklissias & Granikou Str.
151 25 Maroussi
Reg. No. SOEL: Ε 120
250 | ANNUAL FINANCIAL REPORT
Financial Statements for the Group and the Bank as at
31.12.2025
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
251 | ANNUAL FINANCIAL REPORT
The attached notes (pages 258-455) form an integral part of these consolidated financial statements
Income Statement
(Amounts in millions of Euro)
Group
Bank
From 1 January to
Note
31.12.2025
31.12.2024 as
restated
31.12.2025
31.12.2024 as
restated
Interest and similar income
4,037
4,408
3,898
4,284
Interest expense and similar charges
(2,439)
(2,763)
(2,438)
(2,779)
Net interest income
3
1,598
1,645
1,460
1,505
- of which: net interest income based on the effective interest rate
1,595
1,730
1,449
1,591
Fee and commission income
543
480
468
421
Commission expense
(67)
(60)
(62)
(57)
Net fee and commission income
4
476
420
406
364
Dividend income
5
23
6
50
11
Gains less losses on derecognition of financial assets measured at amortised cost
6
27
31
29
31
Gains less losses on financial transactions
7
18
80
3
120
Other income
8
25
32
17
27
Total income from banking operations
2,167
2,214
1,965
2,058
Income from leasing of investment properties
12
7
1
2
Income from services relating to investment properties
3
2
-
-
Expenses related to investment properties management
(6)
(8)
(2)
(2)
Gain/(Losses) from valuation of investment properties
8
(4)
1
2
Net income from investment property management
9
17
(3)
-
2
Total income from Banking and investment property management
2,184
2,211
1,965
2,060
Staff costs
10
(374)
(370)
(301)
(304)
General administrative expenses
11
(345)
(308)
(286)
(252)
Depreciation and amortization
28,29
(131)
(174)
(122)
(160)
Total expenses
(850)
(852)
(709)
(716)
Impairment losses and provisions to cover credit risk
12
(316)
(360)
(297)
(332)
Expenses relating to credit risk management
13
(83)
(93)
(81)
(92)
Impairment losses on fixed assets and equity investments
14
(51)
(13)
118
33
Gains/(Losses) on disposal of fixed assets and equity investments
15
7
27
6
3
Provisions
16
(12)
(85)
(21)
(82)
Transformation costs
17
(18)
(14)
(17)
(12)
Share of profit/(loss) of associates and joint ventures
43
(3)
-
-
Profit/(loss) before income tax
904
818
964
862
Income tax
18
15
(221)
38
(212)
Net profit/(loss) from continuing operations after income tax
919
597
1,002
650
Net profit/(loss) after income tax from discontinued operations
57
24
57
-
-
Net profit/(loss) for the year
943
654
1,002
650
Net profit/(loss) attributable to:
Equity Holders of the Bank
943
654
1,002
650
- from continuing operations
919
597
1,002
650
- from discontinued operations
24
57
-
-
Non-controlling interests
Earnings/(losses) per share:
Basic (€per share)
19
0.3783
0.2591
0.0353
0.0116
Basic (€per share) from continuing operations
19
0.3679
0.2348
0.0353
0.0116
Basic (€per share) from discontinued operations
19
0.0104
0.0243
-
-
Diluted (€ per share)
19
0.3776
0.2588
0.0353
0.0116
Diluted (€ per share) from continuing operations
19
0.3673
0.2345
0.0353
0.0116
Diluted (€ per share) from discontinued operations
19
0.0104
0.0242
-
-
*
Certain figures of the previous year have been restated as described in note 2.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
252 | ANNUAL FINANCIAL REPORT
The attached notes (pages 258-455) form an integral part of these consolidated financial statements
Statement of Comprehensive Income
(Amounts in millions of Euro)
Group
Bank
From 1 January to
Note
31.12.2025
31.12.2024 as
restated
31.12.2025
31.12.2024 as
restated
Net profit/(loss), after income tax, recognized in the Income Statement
943
654[object Object]
1,002
650
Other comprehensive income
Items that may be reclassified subsequently to the Income Statement
Net change in investment securities' reserve measured at fair value through other
comprehensive income
(2)
-
(2)
-
Net change in cash flow hedge reserve
26
31
26
31
Foreign currency translation net of investment hedges of foreign operations
2
2
-
-
Share of other comprehensive income from Associates and Joint Ventures
2
-
-
-
Income tax
18
4
(7)
(7)
(9)
Items that may be reclassified subsequently to the Income Statement from continuing
operations
32
26
17
22
Items that may be reclassified subsequently to the Income Statement from discontinued
operations
(1)
53
-
-
Items that will not be reclassified to the Income Statement
Gains/(losses) from investments in equity securities measured at fair value through other
comprehensive income
4
(13)
6
(14)
Income tax
18
(1)
4
(1)
4
Items that will not be reclassified to the Income Statement from continuing operations
3
(9)
5
(10)
Other comprehensive income, after income tax, for the year
34
70
22
12
Total comprehensive income for the year
977
724[object Object]
1,024
662
Total comprehensive income for the period attributable to:
Equity holders of the Bank
977
724
1,024
662
-from continuing operations
954
614
1,024
662
-from discontinued operations
23
110
-
-
Non-controlling interests
-
-
-
-
*
Certain figures of the previous year have been restated as described in note 2.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
253 | ANNUAL FINANCIAL REPORT
The attached notes (pages 258-455) form an integral part of these consolidated financial statements
Balance Sheet
(Amounts in millions of Euro)
Note
Group
Bank
31.12.2025
31.12.2024 as
restated
31.12.2025
31.12.2024 as
restated
ASSETS
Cash and balances with central banks
20
3,469
2,998
2,223
1,756
Due from financial institutions
21
2,793
2,296
2,871
2,241
Trading securities
22
104
54
38
30
Derivative financial assets
23
445
628
446
740
Loans and advances to customers
24
43,483
39,825
40,500
37,881
Investment securities
- Measured at fair value through other comprehensive income
25a
1,157
1,009
1,083
935
- Measured at amortized cost
25b
16,176
15,645
14,469
14,709
- Measured at fair value through profit or loss
25c
237
167
226
158
Investments in subsidiaries
26
-
-
3,086
2,632
Investments in associates and joint ventures
26
576
571
99
129
Investment property
27
574
323
72
74
Property, plant and equipment
28
595
534
529
500
Goodwill and other intangible assets
29
516
438
409
419
Deferred tax assets
30
4,816
4,807
4,812
4,768
Other assets
31
975
808
659
648
75,916
70,103
71,522
67,620
Assets classified as held for sale
54
1,542
1,999
194
641
Total Assets
77,458
72,102
71,716
68,261
LIABILITIES
Due to banks
32
6,536
6,533
7,858
6,744
Derivative financial liabilities
23
718
793
718
800
Due to customers
33
55,084
51,032
49,560
48,321
Debt securities in issue and other borrowed funds
34
3,804
3,208
3,833
3,255
Liabilities for current income tax
35
11
69
-
65
Deferred tax liabilities
30
35
18
-
-
Employee defined benefit obligations
36
25
23
23
22
Other liabilities
37
1,000
894
782
760
Provisions
38
140
162
106
119
67,353
62,732
62,880
60,086
Liabilities related to assets classified as held for sale
54
1,281
1,153
-
-
Total Liabilities
68,634
63,885
62,880
60,086
EQUITY
Equity attributable to holders of the Bank
Share capital
39
671
682
671
4,678
Share premium
40
5,909
4,784
5,909
1,125
Merger Reserve
41
(1,125)
-
(1,577)
-
Special Reserve from Share Capital Decrease
43
-
-
246
246
Other Εquity Ιnstruments
42
700
700
700
700
Reserves
43
(7)
(93)
743
(89)
Amounts directly recognized in equity and are associated with assets
classified as held for sale
43
(14)
(14)
-
-
Retained earnings
44
2,777
2,203
2,245
1,515
Less: Treasury shares
39
(106)
(61)
(101)
-
8,805
8,201
8,836
8,175
Non-controlling interests
19
16
-
-
Total Equity
8,824
8,217
8,836
8,175
Total Liabilities and Equity
77,458
72,102
71,716
68,261
*
Certain figures of the previous year have been restated as described in note 2.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
254 | ANNUAL FINANCIAL REPORT
The attached notes (pages 258-455) form an integral part of these consolidated financial statements
Statement of Changes in Equity
Group
(Amounts in millions of Euro)
Note
Share
Capital
Treasury
shares
Share
premium
Other Equity
Instruments
Reserves
Amounts directly recognized in
equity and associated with
assets classified as held for sale
Retained
earnings as
restated
Total
Non-
controlling
interests
Total
Equity
Reported Balance 1.1.2024
682
(11)
4,783
400
(111)
(64)
1,626
7,305
18
7,323
Impact from change in accounting policy
2
-
-
-
-
-
-
28
28
-
28
Restated Balance 1.1.2024
682
(11)
4,783
400
(111)
(64)
1,654
7,333
18
7,351
Profit/(Loss) for the year, after income tax as restated
-
-
-
-
-
-
654
654
-
654
Other comprehensive income for the year, after income tax
-
-
-
-
26
53
(9)
70
-
70
Total comprehensive income for the year, after income tax
-
-
-
-
26
53
645
724
-
724
Share Capital Increase through options exercise
-
-
1
-
(1)
-
-
-
-
-
Shares awarded to employees
-
6
-
-
(6)
-
-
-
-
-
Transfer of cumulative income and expenses recognised directly in equity that relate to assets
classified as held for sale
-
-
-
-
-
(3)
3
-
-
-
Valuation reserve of employee stock award program
-
-
-
-
5
-
-
5
-
5
Sale of subsidiary
-
-
-
-
(42)
-
42
-
-
-
Payment of AT1 dividend
-
-
-
-
-
-
(48)
(48)
-
(48)
Sales and purchases of treasury shares
-
(56)
-
-
-
-
1
(55)
-
(55)
AT1 Capital instrument Issuance
-
-
-
300
-
-
(4)
296
-
296
Appropriation reserves
-
-
-
-
37
-
(37)
-
-
-
Dividend distribution
-
-
-
-
-
-
(61)
(61)
-
(61)
(Acquisitions)/Disposals/Other changes of ownership interest in subsidiaries
-
-
-
-
-
-
-
-
(2)
(2)
Other
-
-
-
-
(1)
-
8
7
-
7
Restated Balance 31.12.2024
682
(61)
4,784
700
(93)
(14)
2,203
8,201
16
8,217
*
Certain figures of the previous year have been restated as described in note 2.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
255 | ANNUAL FINANCIAL REPORT
The attached notes (pages 258-455) form an integral part of these consolidated financial statements
Group
(Amounts in millions of Euro)
Note
Share
Capital
Treasury
shares
Share
premium
Other Equity
Instruments
Reserves
Amounts directly recognized in
equity and associated with
assets classified as held for sale
Merger
Reserve
Retained
earnings
Total
Non-
controlling
interests
Total
Equity
Balance 1.1.2025 as restated
682
(61)
4,784
700
(93)
(14)
-
2,203
8,201
16
8,217
Profit/(Loss) for the year, after income tax
-
-
-
-
-
-
-
943
943
-
943
Other comprehensive income for the year, after income tax
-
-
-
-
32
(1)
-
3
34
-
34
Total comprehensive income for the year, after income tax
-
-
-
-
32
(1)
-
946
977
-
977
Valuation reserve of employee stock award program
-
-
-
-
11
-
-
-
11
-
11
Shares awarded to employees
-
9
-
-
(7)
-
-
(2)
-
-
-
Cancelation of Treasury Shares
(11)
61
-
-
-
-
-
(50)
-
-
-
Sales and purchases of treasury shares
-
(115)
-
-
-
-
-
7
(108)
-
(108)
(Acquisitions)/Disposals/Other changes of ownership interests in subsidiaries
-
-
-
-
-
-
-
(3)
(3)
3
-
Sale/liquidation of subsidiaries
-
-
-
-
(5)
1
-
4
-
-
-
Appropriation of reserves
-
-
-
-
56
-
-
(56)
-
-
-
Payment of AT1 dividend
-
-
-
-
-
-
-
(70)
(70)
-
(70)
Reverse Merger and netting off
-
-
1,125
-
-
-
(1,125)
-
-
-
-
Dividend distribution
-
-
-
-
-
-
-
(182)
(182)
-
(182)
Share Capital increase expenses
-
-
-
-
-
-
-
(3)
(3)
-
(3)
Other
-
-
-
-
(1)
-
-
(17)
(18)
-
(18)
Balance 31.12.2025
671
(106)
5,909
700
(7)
(14)
(1,125)
2,777
8,805
19
8,824
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
256 | ANNUAL FINANCIAL REPORT
The attached notes (pages 258-455) form an integral part of these consolidated financial statements
Bank
(Amounts in millions of Euro)
Note
Share
Capital
Share
premium
Special Reserve from
Share Capital Decrease
Other Equity
Instruments
Reserves
Amounts directly recognized in
equity and associated with
assets classified as held for sale
Retained
earnings
Total Equity
Reported Balance 1.1.2024
4,678
1,125
246
400
(145)
3
1,068
7,375
Impact from change in accounting policy
2
-
-
-
-
-
-
3
3
Restated Balance 1.1.2024
4,678
1.125
246
400
(145)
3
1,071
7,378
Profit/(Loss) for the year, after income tax as restated
-
-
-
-
-
-
650
650
Other comprehensive income for the year, after income tax
-
-
-
-
22
-
(10)
12
Total comprehensive income for the year, after income tax
-
-
-
-
22
-
640
662
Shares awarded to employees
-
-
-
-
(6)
-
6
-
Transfer of cumulative income and expenses recognised directly in equity that relate
to assets classified as held for sale
-
-
-
-
(3)
3
-
Valuation reserve of employee stock award program
-
-
-
-
5
-
-
5
Payment of AT1 dividend
-
-
-
-
-
-
(48)
(48)
AT1 Capital instrument Issuance
-
-
-
300
-
-
-
300
Appropriation of ordinary reserve
-
-
-
-
35
-
(35)
-
Dividend distribution
-
-
-
-
-
-
(122)
(122)
Restated Balance 31.12.2024
4,678
1,125
246
700
(89)
-
1,515
8,175
*
Certain figures of the previous year have been restated as described in note 2.
Bank
(Amounts in millions of Euro)
Note
Share
Capital
Treasury
shares
Share
premium
Special Reserve
from Share
Capital Decrease
Other Equity
Instruments
Reserves
Merger Reserve
Retained
earnings
Total Equity
Balance 1.1.2025, as restated
4,678
-
1,125
246
700
(89)
-
1,515
8,175
Profit/(Loss) for the year, after income tax
-
-
-
-
-
-
-
1,002
1,002
Other comprehensive income for the year, after income tax
-
-
-
-
-
17
-
5
22
Total comprehensive income for the year, after income tax
-
-
-
-
-
17
-
1,007
1,024
Valuation reserve of employee stock award program
-
-
-
-
-
11
-
-
11
Shares awarded to employees
-
3
-
-
-
(9)
-
6
-
Reverse Merger and netting off
(4,678)
-
4,784
-
-
770
(1,577)
15
(686)
Share capital increase due to merger
671
-
-
-
-
-
-
-
671
Payment of AT1 dividend
-
-
-
-
-
-
-
(71)
(71)
Purchases of treasury shares
-
(104)
-
-
-
-
-
-
(104)
Appropriation of reserves
-
-
-
-
-
43
-
(43)
-
Dividend distribution
-
-
-
-
-
-
-
(181)
(181)
Share Capital increase expenses
-
-
-
-
-
-
-
(3)
(3)
Balance 31.12.2025
671
(101)
5,909
246
700
743
(1,577)
2,245
8,836
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
257 | ANNUAL FINANCIAL REPORT
The attached notes (pages 258-455) form an integral part of these consolidated financial statements
Statement of Cash Flows
(Amounts in millions of Euro)
Note
Group
Bank
From 1 January to
31.12.2025
31.12.2024
as restated
31.12.2025
31.12.2024 as
restated
Cash flows from continuing operating activities
Profit/(Loss) before income tax from continued operations
904
818
964
862
Adjustments of profit/(Loss) before income tax for:
Depreciation, impairment, write-offs and net result from disposal of property, plant and
equipment
53
64
49
48
Amortization, impairment, write-offs of intangible assets
117
134
109
123
Impairment losses, provisions to cover credit risk and related expenses
403
504
319
426
Gains less losses on derecognition of financial assets measured at amortised cost
(27)
(31)
(28)
(31)
Fair value (gains)/losses on financial assets measured at fair value through profit or loss
(317)
(61)
(315)
(143)
Gain or losses from valuation of investment properties
(8)
4
(1)
(2)
Impairment of investments
-
-
(154)
(44)
(Gains)/losses from investing activities
(212)
(517)
(188)
(460)
(Gains)/losses from financing activities
200
257
199
278
Share of (profit)/loss of associates and joint ventures
(43)
3
-
-
1,070
1,175
954
1,057
Net (increase)/decrease in assets relating to continuing operating activities:
Due from financial institutions
406
(484)
(651)
(414)
Trading securities and derivative financial instruments
401
48
428
70
Loans and advances to customers
(3,346)
(3,523)
(2,753)
(3,281)
Other assets
413
(44)
37
33
Net increase/(decrease) in liabilities relating to continuing operating activities:
Due to banks
(6)
(388)
1,114
(457)
Due to customers
1,833
2,583
1,358
2,143
Other liabilities
(95)
(261)
111
(116)
Net cash flows from continuing operating activities before income tax
676
(894)
598
(965)
Income tax paid
(3)
(15)
-
-
Net cash flows from continuing operating activities
673
(909)
598
(965)
Net cash flows from discontinued operating activities
(12)
(176)
-
-
Cash flows from continuing investing activities
Proceeds from disposals of subsidiaries
8
300
-
-
Outflow from aquisition οf subsidiaries
(341)
-
-
-
Dividends received and returns of share capital of associate and joint ventures
97
6
45
11
Investments in subsidiaries, associates and joint ventures
-
(56)
(358)
(138)
Acquisitions of investment property, property, plant and equipment and intangible assets
27,28,29
(277)
(153)
(162)
(117)
Disposals of investment property, property, plant and equipment and intangible assets
19
15
27
91
Interest received from investment securities
434
331
408
319
Purchases of Greek Government Treasury Bills
(1,420)
(1,665)
(1,328)
(1,665)
Proceeds from disposal and redemption of Greek Government Treasury Bills
1,371
2,062
1,341
2,062
Purchases of investment securities (excluding Greek Government Treasury Bills)
(3,686)
(3,625)
(3,218)
(3,216)
Disposals/maturities of investment securities (excluding Greek Government Treasury Bills)
3,517
2,158
3,092
2,381
Net cash flows from continuing investing activities
(278)
(627)
(153)
(272)
Net cash flows from discontinued investing activities
62
(21)
-
-
Cash flows from continuing financing activities
Share Capital Increase expenses
(3)
-
(3)
-
AT1 issuance
-
296
-
300
Payments for AT1 issuance
(71)
(48)
(71)
(48)
Proceeds from issue of debt securities and other borrowed funds
1,073
977
1,073
981
Repayments of debt securities in issue and other borrowed funds
(493)
(769)
(495)
(769)
Interest paid on debt securities in issue and other borrowed funds
(179)
(178)
(198)
(185)
Payments of lease liabilities
(20)
(18)
(16)
(14)
Dividend payments
(182)
(61)
(182)
(122)
Treasury Shares
(108)
(55)
(105)
-
Net cash flows from continuing financing activities
17
144
3
143
Net cash flows from discontinued financing activities
(42)
(3)
-
-
Effect of foreign exchange changes on cash and cash equivalents
(1)
4
(1)
1
Net increase/(decrease) from continuing cash flows
411
(1,388)
447
(1,093)
Changes in cash equivalent from discontinued operations
8
(200)
-
-
Cash and cash equivalents at the beginning of the year from continuing operations
3,046
4,434
1,762
2,855
Cash and cash equivalents at the end of the year from continuing operations
3,457
3,046
2,209
1,762
*
Certain figures of the previous year have been restated as described in note 2.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
258 | The amounts are presented in millions of Euro unless otherwise indicated.
Notes to the Financial Statements
GENERAL
INFORMATION
The Alpha Bank Group (hereinafter the “Group”), which includes companies in Greece and abroad, offers the following services: corporate and
retail banking, financial services, investment banking and brokerage services, insurance services, real estate management and hotel services.
On 27 June 2025 the Group completed the Reverse Merger between Alpha Bank S.A (absorbing entity) and Alpha Services and Holdings (ASH,
the absorbed entity) by the method of absorption, thus Alpha Bank becoming the ultimate parent company of the Group. In particular, the
Absorbed Entity merged with Alpha Bank, through a merger by absorption, by way of consolidation of the assets and liabilities of the Merging
Entities. The merger used the provisions of Article 16 of the Greek Law 2515/1997 and the provisions of Articles 7 to 21 and 140 of Greek Law
4601/2019 as amended and in force.
The completion of the Reverse Merger, was subject to obtaining all necessary regulatory authorisations and corporate approvals, including :
(i) the prior approval by the ECB (acting through the SSM with the bank of Greece) under Article 16 of the Greek Law 2515/1997 in
conjunction with Articles 4 and 6 of the SSM Regulation, which was obtained on 30 May 2025;
(ii) the approval of the Ministry of Development, as well as
(iii) all necessary corporate approvals including those by the Extraordinary General Meeting of the Absorbed Entity held on 23 June
2025 and the Extraordinary General Meeting of the Absorbing Entity held on 12 June 2025.
The managements of the Merging Entities settled on the decision to proceed with the procedure of the Reverse Merger by taking into
account, on the one hand, the strategic goals, and on the other hand, the prospects of this specific Reverse Merger by way of which Alpha
Bank, as a single entity licensed to provide banking services is following the completion of the Reverse Merger, the head of the group of
companies of the Absorbed Entity thus achieving:
• simplification of the corporate, organisational and capital structure of the group, aiming at the improvement and the rationalisation
of the organisation of its operation;
• saving operational cost by achieving economies of scale on the operational and management expenses of the Merging Entities; a nd
• the consolidation of the Merging Entities which are supervised entities, in a single legal entity therefore resulting in the
simplification and the limitation of procedures and requirements for the fulfilment of the obligations which derive from the
applicable supervisory legislation.
Following the completion of the Reverse Merger, the assets and liabilities of the Absorbed Entity were transferred to Alpha Bank by way of
universal succession and the shareholders of the Absorbed Entity became shareholders of Alpha Bank.
Leading or parent entity of the Group is Alpha Bank S.A., has its registered office at 40 Stadiou Street, Athens and is listed in the General
Commercial Register with registration number 159029160000.
Its duration has been set until 2101 and can be extended following a decision of the General Assembly.
The Bank’s scope of business, as stated in article 4 of its Articles of Incorporation, is the conducting, serving its own interests or those of third
parties, in Greece or abroad, independently or in cooperation, including joint ventures, under third parties, of the entirety, under no limitation
or other distinction, of (primary and ancillary) works, activities, transactions and services permitted to be conducted by credit institutions
under the applicable (domestic, communal, foreign) legislation. For its fulfillment, the Bank may conduct any actions, works or transactions
that, directly or indirectly, are consistent, supplementary or auxiliary to the aforementioned.
The Bank is managed by the Board of Directors, which represents the Bank and is qualified to resolve every action concerning its
management, the administration of its property and the promotion of its scope of business in general.
The tenure of the Board of Directors which was elected by the Extraordinary General Meeting of Shareholders on 22.7.2022 is quadrennial
and may be extended until the termination of the deadline for the convocation of the next Ordinary General Meeting and until the respective
resolution has been adopted.
The composition of the Board of Directors as at December 31, 2025, is as follows:
***
**
****
****
CHAIR (Non-Executive Member) INDEPENDENT NON-EXECUTIVE MEMBERS *****Aspasia F. Palimeri /Dimitris C. Tsitsiragos****/EXECUTIVE MEMBERS Panagiotis I. – K. Papazoglou */Vassilios E. Psaltis, Chief Executive Officer (CEO) Jean L. Cheval **/Lazaros A. Papagaryfallou, Deputy CEO Elanor R. Hardwick **/NON- EXECUTIVE MEMBERS Diony C. Lebot ********//Annalisa G. Areni Johannes Herman Frederik G. Umbgrove INDEPENDENT NON-EXECUTIVE MEMBERS SECRETARY */****Elli M. Andriopoulou Eirini E. Tzanakaki * Member of the Audit Committe e ** Member of t he Risk Management Committee *** Member of the Remuneration Committ ee **** Member of Cor porate Gove rnance, Sustainabi lity and Nominatio ns Committee
The Board of Directors can set up the Executive Committee to which it delegates certain powers and responsibilities. The Executive
Committee acts as a collective corporate body of the Bank. The powers and authorities of the Committee are determined by way of a CEO
Act, delegating powers and authorities to the Committee.
Indicatively, the main responsibilities of the Committee include, but are not limited to the following.
The Executive Committee:
- prepares the strategy, the business plan and the annual Budget of the Bank and the Group, including the strategy on Environmental, Social
and Governance (ESG) issues, for submission to and approval by the Board of Directors;
- prepares and submits for approval by the Board of Directors the annual and interim Financial Statements;
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
259 | The amounts are presented in millions of Euro unless otherwise indicated.
- prepares the Internal Capital Adequacy Assessment Process (ICAAP) Report and the Internal Liquidity Adequacy Assessment Process Report
(ILAAP) for submission to and approval by the Board of Directors, manages their implementation and reports accordingly to the Board o f
Directors;
- reviews and approves, in the framework of its authorities, the Bank’s Policies and informs the Board of Directors accordingly or submits
them, as the case may be, to the latter for approval;
- discusses issues related to the Group’s Purpose and Values, culture and human resources as well as approves and manages any c ollective
program proposed by Human Resources for the Staff (including any bonus schemes, voluntary separation schemes, etc.).
Furthermore, the Committee is responsible for the implementation of (i) the overall risk strategy, including the Bank’s risk appetite and its risk
management framework, (ii) an adequate and effective internal governance and internal control framework, (iii) an adequate and effective
framework for the implementation of the Bank’s strategy on ESG issues, (iv) the selection and suitability assessment process for Key Function
Holders, (v) the amounts, types and distribution of both internal capital and regulatory capital to adequately cover the risks of the Bank, (vi)
the means for achieving targets for the liquidity management of the Bank and (vii) any arrangements aimed at ensuring the integrity of the
accounting and financial reporting systems, including financial and operational controls, risk management and compliance with the law and
the relevant standards.
The composition of the Executive Committee as at 31.12.2025 consisted of:
CHAIR
Vassilios E. Psaltis, Chief Executive Officer (CEO)
MEMBERS
Lazaros A. Papagaryfallou, Deputy CEO
Spiros A. Andronikakis, Chief Risk Officer (CRO)
Ioannis M. Emiris, Chief of Wholesale Banking
Nikos V. Salakas, Chief of Corporate Center and General Counsel
Panayotis K. Georgiopoulos, Chief Retail Client Strategies Officer
Stefanos N. Mytilinaios, Chief Integration and Group Initiatives Officer
Fragiski G. Melissa, Chief Human Resources Officer (CHRO)
Georgios V. Michalopoulos, Chief Wealth Management Officer
Vasilis G. Kosmas, Chief Financial Officer (CFO)
Michalis V. Tsarbopoulos, Chief Digital and Technology Officer
Following the successful completion of the acquisition of AXIA and the retirement of the Bank’s Chief Risk Officer (CRO), Alpha Bank
proceeded with further enhancements to its Executive Committee as of 1.1.2026. These changes are reinforcing its capacity to drive
sustainable growth, strengthen risk governance, and unlock new value creation opportunities.
The composition of the Executive Committee as of 1.1.2026 is the following:
CHAIR
Vassilios E. Psaltis, Chief Executive Officer (CEO)
MEMBERS
Lazaros A. Papagaryfallou, Deputy CEO
Ioannis M. Emiris, Chief of Wholesale Banking
Nikos V. Salakas, Chief of Corporate Center and General Counsel
Panayotis K. Georgiopoulos, Chief Retail Client Strategies Officer
George D. Linatsas, Chief of Investment Banking
Konstantinos G. Sarafopoulos, Chief Risk Officer (CRO)
Fragiski G. Melissa, Chief Human Resources Officer (CHRO)
Stefanos N. Mytilinaios, Chief Integration and Group Initiatives Officer
Georgios V. Michalopoulos, Chief Wealth Management Officer
Vasileios G. Kosmas, Chief Financial Officer (CFO)
Michalis V. Tsarbopoulos, Chief Digital and Technology Officer
There has been no change in the composition of the Executive Committee from 1.1.2026 and until the publication date of the financial report.
The share of the company “Alpha Bank Societe Anonyme” is listed in the Athens Stock Exchange since 1925 and is constantly inc luded among
the companies with the higher market capitalization. Additionally, the Bank’s share is included in a series of internat ional indices, such as the
MSCI Emerging Markets, MSCI Greece, FTSE All World and FTSE4Good Emerging Index. Apart from the Greek listing, the share of the Company
is traded over the counter in New York (ADRs). Total ordinary shares in issue as at 31 December 2025 were 2,315,261,358 ordinary, registered
voting, dematerialized shares with a face value of each equal to € 0.29. During the year of 2025, the average daily volume of the share per
session was €10,979,781.
According to the announcement made by UniCredit S.p.A. (“UniCredit”) on 30.10.2025, UniCredit has received ECB authorization to acquire a
direct stake in Alpha Bank S.A. of up to 29.9%.
On 5.1.2026 Unicredit announced the conversion of a c. 20% synthetic position in Alpha Bank S.A. having received all necessary legal and
regulatory approvals, taking its share ownership and effective voting rights to 29.796% of the total. As per the same announcement UniCredit
has entered into certain financial instruments with Alpha Bank S.A. shares as underlying security, which instruments provide for cash
settlement as the default method and physical settlement as an alternative, subject to receiving all necessary regulatory approvals. If physical
settlement is opted for, it may result in the acquisition of additional common shares with voting rights corresponding to 2.272% of the total
voting rights of Alpha Bank S.A. resulting in a total holding of 32.069% of voting rights. It is noted that until - and subject to - the physical
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
260 | The amounts are presented in millions of Euro unless otherwise indicated.
settlement of the relevant financial instruments, UniCredit S.p.A. does not have any influence over the exercise of the voting rights attached
to the shares underlying such financial instruments.
The present Consolidated financial statements of the Company have been approved by the board of directors on 26th February 2026.
Commission Delegated Regulation (EU) 2019/815, as amended by Regulation (EU) 2020/1989 introduces the obligation for issuers of
securities traded on a regulated EU market to prepare the annual financial report in HTML format, in accordance with the European Single
Electronic Format. For the year ended 31.12.2025 the consolidated financial statements, included in the annual financial report, have been
marked with XBRL tags (XBRL ‘tags’), according to the ESEF Taxonomy (ESEF Taxonomy), using the Inline XBRL (“iXBRL” specifications).
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
261 | The amounts are presented in millions of Euro unless otherwise indicated.
1.
Accounting policies applied
1.1
Basis of presentation
The financial statements for the current period ending at 31.12.2025 include both the financial statements of the Bank and the financial
statements of the Group. They have been prepared in accordance with International Financial Reporting Standards (IFRS), as adopted by the
European Union, in accordance with Regulation 1606/2002 of the European Parliament and the Council of the European Union on 19 July
2002.
The accounting policies applied by the Bank and the Group in preparing the financial statements are the same as those stated in their
published financial statements for the year ended on 31.12.2024, after taking into account:
• The amendment to IAS 21 which was issued by the International Accounting Standards Board (IASB), adopted by the European
Union and applied on 1.1.2025, for which further analysis is provided in note 1.1.2.
• The change in the presentation of collateralized loan obligations which meet the following characteristics: the underlying portfolio
consists of loans, the debt securities are primarily covered by the Bank and the Group and are not traded in an active market. From
30.6.2025, these debt securities are presented in the line "Loans and advances to customers" instead of the line "Investment
securities". Considering that the above change constitutes a change in accounting policy, it was applied retrospectively (note 2).
• The change in the measurement method of investment properties which, from 31.12.2025, are measured at fair value and not at
acquisition cost. This change constitutes a change in accounting policy and was applied retrospectively (note 2).
• The change in the presentation of the Income Statement so that the results related to the management of investment properties are
presented separately and their sum constitutes a new subtotal called “Net income from investment property management”. As the
aforementioned change also constitutes a change in accounting policy, it was applied retrospectively (note 2).
The financial statements have been prepared on the historical cost basis except for specific financial instruments measured at fair value either
through profit or loss or through other comprehensive income and investment properties which are measured at fair value.
The financial statements are presented in Euro, rounded to the nearest million, unless otherwise indicated. Any differences between the
amounts presented in the primary financial statements and the relevant amounts presented in the accompanying notes are due to rounding.
1.1.1 Going concern
The financial statements as at 31.12.2025 have been prepared based on the going concern principle. For the application of this principle, the
Board of Directors considered current economic developments and made estimates for the formation, in the near future, of the economic
environment in which it operates. In this context, the Board of Directors assessed the following areas which are considered important during
its assessment:
Developments in the macroeconomic environment
The macroeconomic environment is characterized by uncertainty, which is mainly caused by the following:
• Trade protectionism, geopolitical developments and inflationary pressures: For Greece, the new tariffs are not expected to have
significant direct effects, as trade relations with the United States are relatively limited (surplus trade balance, equal to Euro 0.25
billion in 2024). The effects are more likely to be indirect, especially in the potential adoption of new trade protectionist policies, as
any slowdown in global trade could result in reduced demand for Greek products and services, with corresponding negative effects
on economic activity. At the same time, as a factor of uncertainty, trade protectionism may also act as a deterrent for the
implementation of investments.
• The possible resurgence of geopolitical tensions in the Middle East, particularly in Iran, which is one of the most important oil
producing countries, as well as in the Red Sea, could lead, among other things, to an increase in international oil prices and transport
costs, as well as to delays in the supply chain, with a subsequent resurgence in inflation.
• The risks to the Greek economy arising from potential natural disasters or any impacts of climate change, such as the extreme
weather events that have affected various regions of the country in recent years
• Any delays in the absorption of the Recovery and Resilience Fund funds and the implementation of the program, as well as possible
delays in the implementation of structural reforms.
Despite, however, the uncertainty that characterizes the economic environment, the Greek economy is expected to remain resilient, achieving,
according to the forecasts of the Bank of Greece (Monetary Policy Interim Report, December 2025), a GDP growth rate of 2.1% in both 2025
and 2026. This performance is estimated to be supported by private consumption, the strengthening of the extroversion of Greek businesses,
as well as the implementation of investments both in the context of the absorption of the resources of the Recovery and Resilience Fund and
the Public Investment Budget.
Liquidity
The liquidity levels of the Bank and the Group are particularly satisfactory, as evidenced by the liquidity ratios (liquidity coverage ratio and net
stable liquidity ratio) which remain at high levels and significantly exceed the regulatory limits set (not e 49.3) and the liquidity stress tests
conducted internally, which demonstrate that the Bank remains viable in all scenarios. Finally, in March 2025, Moody’s upgraded the credit
rating of the Bank’s senior debt to Baa2 with a positive outlook, in May 2025 the Bank received an Investment Grade rating (BBB/Stable) from
the rating agency Scope, while in October 2025 the Bank’s rating was upgraded by Fitch to BBB- with a stable outlook. These upgrades confirm
the Bank's potential to achieve higher sustainable profitability, while improving the resilience of its balance sheet.
Capital Adequacy
The Bank and the Group, due to the strong profitability of recent years and the successful completion of the planned bond issues, maintain a
strong capital base from both a financial and regulatory perspective (note 50), while the formulation of the MREL ratio provides an adequate
safety margin against the MREL requirements that must be met.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
262 | The amounts are presented in millions of Euro unless otherwise indicated.
Strategic Plan
Taking into account the actions taken in the context of the implementation of the Group's strategic plan as well as the fact that so far the goals
that had been set have been achieved, a significant improvement in profitability and qualitative structure of the balance sheet is expected, as
well as the creation of capital, which ensure the availability of the required resources for the continuation of the Group's activities and its
further development. It is also noted that the recent acquisitions made by the Group are expected to further enhance future revenues in its
areas of operation.
Based on the above, the Board of Directors estimates that the financial statements of the Bank and the Group have been prepared on the
going concern basis.
1.1.2 Adoption of new standards and of amendments to existing standards
The following is the amendment to IAS 21 applied from 1.1.2025:
Amendment to the International Accounting Standard 21 “The Effects of Changes in Foreign Exchange Rates”: Lack of exchangeability
(Regulation 2024/2862/12.11.2024)
On 15.8.2023, the International Accounting Standards Board issued an amendment to IAS 21 regarding currencies that lack exchangeability.
The amendment clarifies how an entity should assess whether a currency is exchangeable and how it should determine a spot exchange rate
when exchangeability is lacking.
The adoption of the above amendment had no impact on the financial statements of the Bank and the Group.
In addition, the European Union has adopted the following amendments to standards which are effective for annual periods beginning after
1.1.2025 and have not been early adopted by the Bank and the Group.
Amendment to International Financial Reporting Standard 7 “Financial Instruments: Disclosures” and to International Financial Reporting
Standard 9 “Financial Instruments”: Amendments to the Classification and Measurement of Financial Instruments (Regulation
2025/1047/27.5.2025)
Effective for annual periods beginning on or after 1.1.2026
On 30.5.2024 the International Accounting Standards Board issued amendments to IFRS 7 and IFRS 9 to address matters identified during the
post-implementation review of IFRS 9 regarding classification and measurement of financial instruments. More specifically, the amendments
clarify issues relating to the derecognition of a financial liability settled through electronic matter and the assessment of whether the cash
flows of a financial asset are solely payments of principal and interest while they provide for disclosures for equity instruments measured at
fair value through other comprehensive income and contractual terms that could change the timing or amount of contractual cash flows on
the occurrence of a contingent event.
No impact is expected from the adoption of the above amendments on the financial statements of the Bank and the Group.
Amendment to International Financial Reporting Standard 7 “Financial Instruments: Disclosures” and to International Financial Reporting
Standard 9 “Financial Instruments”: Contracts Referencing Nature-dependent Electricity (Regulation 2025/1266/30.6.2025)
Effective for annual periods beginning on or after 1.1.2026
On 18.12.2024, the International Accounting Standards Board issued an amendment to IFRS 9 to specify the factors that should be considered
to determine whether contracts referencing nature-dependent electricity are within its scope and under what conditions a contract for nature
dependent renewable electricity can be designated as a hedging instrument. IFRS 7 was also amended to include disclosures regarding such
contracts.
No impact is expected from the adoption of the above amendments on the financial statements of the Bank and the Group.
Annual Improvements – Volume 11 (Regulation 2025/1331/9.7.2025)
Effective for annual periods beginning on or after 1.1.2026
As part of the annual improvements project, the International Accounting Standards Board issued on 18.7.2024 non-urgent but necessary
amendments to IFRS 1, IFRS 7, IFRS 9, IFRS 10 and IAS 7.
The Bank and the Group are examining the impact from the adoption of the above amendments on their financial statements.
Also, the International Accounting Standards Board has issued the following standards and amendments to standards, which have not yet
been adopted by the European Union and have not been early applied by the Bank and the Group.
Amendment to International Financial Reporting Standard 10 “Consolidated Financial Statements” and to International Accounting Standard
28 “Investments in Associates and Joint Ventures”: Sale or contribution of assets between an investor and its associate or joint venture.
Effective date: To be determined.
On 11.9.2014 the International Accounting Standards Board issued an amendment to IFRS 10 and IAS 28 in order to align the accounting
treatment of a transaction of sale or contribution of assets between an investor and its associate or joint venture
The Bank and the Group are examining the impact from the adoption of the above amendments on their financial statements.
International Financial Reporting Standard 14 “Regulatory deferral accounts”.
Effective date: To be determined (under the standard, effective date was the annual periods beginning on 1.1.2026, however endorcement
from European Union has been postponned)
On 30.1.2014 the International Accounting Standards Board issued IFRS 14. The new standard, which is limited-scope, addresses the
accounting treatment and the disclosures required for regulatory deferral accounts that are maintained in accordance with local legislation
when an entity provides rate-regulated goods or services.
It is noted that European Union has decided not to launch the endorsement of this standard and to wait for the final standard.
The above standard does not apply to the financial statements of the Bank and the Group.
International Financial Reporting Standard 18 “Presentation and Disclosure in Financial Statements” Effective for annual periods beginning on
or after 1.1.2027
On 9.4.2024 the International Accounting Standards Board issued IFRS 18. IFRS 18 replaces IAS 1 and sets out presentation and disclosure
requirements for financial statements.
To meet this objective, IFRS 18 introduces:
•
two new defined subtotals in the statement of profit or loss: operating profit and profit before financing and income taxes,
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
263 | The amounts are presented in millions of Euro unless otherwise indicated.
•
disclosures about management-defined performance measures (“MPM’s”), and
•
enhanced requirements for grouping of information (aggregation and disaggregation) in the financial statements.
IFRS 18 requires that a company presents income and expenses in separate operating, investing and financing categories. The operating
category consists of all income and expenses that are not classified in the investing, financing, income taxes or discontinued operations
categories.
The Bank and the Group are examining the impact from the adoption of the above standard on their financial statements.
International Financial Reporting Standard 19 “Subsidiaries without Public Accountability: Disclosures”.Effective for annual periods beginning
on or after 1.1.2027. On 9.5.2024 the International Accounting Standards Board issued IFRS 19. IFRS 19 specifies reduced disclosure
requirements that an eligible entity (it is subsidiary, does not have public accountability and has an ultimate or intermediate parent that
publishes IFRS consolidated financial statements) is permitted to apply instead of the disclosure requirements in other IFRS Accounting
Standards. Also, on 21.8.2025 the International Accounting Standards Board issued an amendment to IFRS 19 in order to reduce the disclosure
requirements provided for by the standards and amendments to standards issued between February 2021 and May 2024.
The above standard does not apply to the financial statements of the Bank and the Group.
Amendment to the International Accounting Standard 21 “The Effects of Changes in Foreign Exchange Rates”: Translation to a
hyperinflationary presentation currency
Effective for annual periods beginning on or after 1.1.2027
The International Accounting Standards Board issued an amendment to IAS 21 on 13.11.2025 to clarify how entities should translate financial
statements from a non-hyperinflationary currency to a hyperinflationary currency.
The above amendment is not expected to have any impact on the financial statements of the Bank and the Group.
1.2
Material accounting policies
1.2.1 Basis of consolidation
The consolidated financial statements include the parent company Alpha Bank, its subsidiaries, associates and joint ventures. The financial
statements used to prepare the consolidated financial statements have been prepared as at 31.12.2025 and the accounting policies applied in
their preparation, when necessary, were adjusted to ensure consistency with the Group accounting policies.
a. Subsidiaries
Subsidiaries are entities controlled by the Group.
The Group takes into account the following factors, in assessing control:
•
power over the investee,
•
exposure, or rights, to variable returns from its involvement with the investee, and
•
the ability to use its power over the investee to affect the amount of the investor’s return.
Power arises from currently exercisable rights that provide the Group with the current ability to direct the relevant activities of the investee. In
a straightforward case, rights that provide power are derived from voting rights granted by equity instruments such as shares. In other cases,
power results from contractual arrangements.
The Group’s returns are considered variable, when these returns have the potential to vary as a result of the investee’s performance.
Variability of returns is judged based on the substance of the arrangement, regardless of their legal form.
The Group, in order to evaluate the link between power and returns, assesses whether it exercises its power for its own benefit or on behalf of
other parties, thus acting as either a principal or an agent, respectively. If the Group determines that it acts as a principal, then it controls the
investee and consolidation is required. Otherwise, control does not exist and there is no requirement to consolidate.
In cases where the power over an investee arises from voting rights, the Group primarily assesses whether it controls the investee through
holding more than 50% of the voting rights. However, the Group can have power even if it holds less than 50% of the voting rights of the
investee, through:
•
a contractual arrangement between the investors and other vote holders,
•
rights arising from other contractual arrangements,
•
the size of the investor’s holding of voting rights relative to the size and dispersion of holdings of the other vote holders,
•
potential voting rights.
In cases of structured entities where the voting rights relate to administrative tasks only and the relevant activities are directed by means of
contractual arrangements (i.e. securitization vehicles or mutual funds), the Group assesses the existence of control based on the following:
•
the purpose of the entity and the contractual rights of the parties involved,
•
the risks to which the investee was designed to be exposed, the risks it was designed to pass on to the parties involved with the investee
and the degree of exposure of the Group to those risks,
•
indications of a special relationship with the entity, which suggests that the Group has more than a passive interest in the investee.
The Group, based on the above criteria, controls structured entities established for the securitization of loan portfolios.
The Group reassess whether it controls an investee if facts and circumstances indicate that there are changes to one or more of the elements
of control.
The financial statements of subsidiaries are fully consolidated from the date that control commences until the date that control ceases.
The acquisition method is applied when the Group obtains control of other companies or units that meet the definition of a business.
Application of the acquisition method requires identifying the acquirer, determining the acquisition date and measuring the consideration
transferred, the identifiable assets acquired, the liabilities assumed and any non controlling interest in the acquiree, in order to determine the
amount of goodwill or gain arising from the business combination.
The consideration transferred is measured at fair value on acquisition date.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
264 | The amounts are presented in millions of Euro unless otherwise indicated.
The identifiable assets acquired and liabilities assumed are initially recognised on acquisition date at their fair value, except from specific
assets or liabilities for which a different measurement basis is required. Any non controlling interests are recognised at either fair value or at
their proportionate share in the acquiree’s identifiable net assets, as long as they are present ownership interests and entitle their holders to a
proportionate share of the entity’s net assets in the event of liquidation. Otherwise, they are measured at their acquisition date fair values.
Any difference between:
•
the sum of the consideration transferred, the fair value of any previously held equity interest of the Group in the acquiree and the
amount of any non – controlling interests, and
•
the net of the acquisition date amounts of the identifiable assets acquired and the liabilities assumed,
is recognised as goodwill if the above difference is positive or as a gain in profit or loss if the difference is negative.
During the measurement period, the provisional amounts recognized at the acquisition date are adjusted in order to reflect new information
obtained about facts and circumstances that existed as of the acquisition date and, if known, would have affected the measurement of the
amounts recognized as of that date. These adjustments affect accordingly the amount of goodwill. The measurement period ends as soon as
the information about facts and circumstances existed as of the acquisition date has been obtained. However, the measurement period shall
not exceed one year from the acquisition date.
When the Group’s interest in a subsidiary increases as a result of an acquisition, the difference between the consideration paid and the share
of net assets acquired is recognized directly in retained earnings.
Sales of ownership interests in subsidiaries that do not result in a loss of control for the Group are accounted for as equity transactions and the
gain or loss arising from the sale is recognized directly in retained earnings.
Intercompany transactions are eliminated, unless the transaction provides evidence of impairment of the asset transferred, in which case, it is
recognized in the consolidated balance sheet.
b. Associates
Associates are entities over which the Group has significant influence but not control. Significant influence is generally presumed to exist when
the Group holds, directly or indirectly, more than 20% of the share capital of the company concerned without having control or joint control,
unless the ownership of more than 20% does not ensure significant influence, e.g. due to lack of representation of the Group in the company’s
Board of Directors or due to the Group’s non-participation in the policy making process. Additionally, significant influence may exist when less
than 20% of the share capital is held, when the Group participates in the process of formulating the company's policies through its
participation in its Board of Directors and when, based on the shareholders' agreement, there is the possibility of exercising a veto on
significant decisions.
Investments in associates are accounted for using the equity method of accounting. The investment is initially recognised at cost and adjusted
thereafter for the post acquisition change in the Group’s share of net assets of the associate. In case the losses according to the equity method
exceed the investment in ordinary shares, they are recognized as a reduction of other elements that are essentially an extension of the
investment in the associate.
The Group’s share of the associate’s profit or loss and other comprehensive income is separately recognized in the income statement and in
the statement of comprehensive income, accordingly.
c. Joint ventures
The Group applies IFRS 11 which deals with the accounting treatment of interests in joint arrangements. All joint arrangements in which the
Group participates and has joint control are joint ventures, which are accounted for by using the equity method.
A detailed list of all Group subsidiaries, associates and joint ventures, as well as the Group’s ownership interest in them, is provided in note 46.
d. Investments in subsidiaries, associates, and joint ventures in the Bank's separate financial statements
The Bank's investments in subsidiaries, associates and joint ventures are measured at acquisition cost, which also includes their acquisition
costs, less any impairment losses. The acquisition cost also includes the issues of subsidiaries, associates and joint ventures that are
recognized as elements of their equity and which are held by the Bank.
e. Intragroup corporate reorganizations
In case of corporate reorganizations under the same group which are made through the acquisition of a subsidiary or a business that meets
the definition of a business, the Bank assesses whether the transaction has economic substance. If it does, the provisions on business
combinations referred to above apply. If it does not, the Bank recognises the assets and liabilities acquired at their carrying amount and any
difference between the acquisition price and the total carrying amount of such assets at the date of the transaction is recognised in equity. In
any case, the results and balance sheet of the acquired entity are incorporated from the date of the transaction.
If the assets and liabilities transferred to not constitute a business, the Bank measures each asset and liability acquired at its fair value.
Finally, corporate reorganizations which are made through the establishment of a new company that absorbs assets and liabilities of another
company which satisfy the definition of business under IFRS 3, are not business combinations since the new company does not satisfy the
definition of an acquirer. Under the policy applied by the Bank, those transactions are accounted for by transferring assets and liabilities at the
book values in the books of the company that makes the transfer. Additionally, both in the separate and group financial statements of the new
company, information is included from the date of the corporate reorganization. However, in case corporate reorganization is inextricably
linked to the subsequent transfer of the company that proceeded with the acquisition or of the transferred assets and liabilities to a third
party investor, the transfer of the assets and liabilities is accounted for at their fair value at the date of the corporate reorganization.
1.2.2 Operating Segments
Operating segments are determined and measured based on the information provided to the Executive Committee of the parent Company
Alpha Bank, which is the body responsible for the allocation of resourses between the Group’s operating segments and the assessment of
their performance.
Based on the above, and given the Group’s administrative structure and activities, the following operating segments have been determined:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
265 | The amounts are presented in millions of Euro unless otherwise indicated.
•
Retail
•
Wholesale
•
Wealth Management
•
International
•
Non Performing Assets
•
Corporate Center
Since the Group operates in various geographical areas, apart from the operating segments identified above, the financial statements contain
information based on the below distinction:
•
Greece
•
Other Countries
It is noted that the methods used to measure operating segments for the purpose of reporting to the Executive Committee are not different
from those required by the International Financial Reporting Standards.
Detailed information relating to operating segments is provided in note 48.
1.2.3 Transactions in foreign currency and translation of foreign operations
a. Transactions in foreign currency
The financial statements are presented in Euro, which is the functional currency and the currency of the country of incorporation of the parent
company Alpha Bank.
Items included in the financial statements of the subsidiaries are measured in the functional currency of each subsidiary which is the currency
of the company’s country of incorporation or the currency used in the majority of the transactions held.
Transactions in foreign currencies are translated into the functional currency of each subsidiary at the closing exchange rate at the date of the
transaction.
Monetary assets and liabilities denominated in foreign currencies are translated into the functional currency at the closing exchange rate at
the balance sheet date. Foreign exchange differences arising from the translation are recognized in the income statement.
Non-monetary assets and liabilities are translated using the rate of exchange at the transaction date, except for non-monetary items
denominated in foreign currencies that are measured at fair value which are translated at the exchange rate of the date that the fair value is
determined. The exchange differences relating to these items are part of the change in fair value and they are recognized in the income
statement or recorded directly in equity depending on the classification of the non-monetary item.
b. Translation of foreign operations
The financial statements of all group entities that have a functional currency that is different from the presentation currency of the Group’s
and the Bank’s financial statements are translated as follows:
• Assets and liabilities are translated to Euro at the closing rate applicable on the balance sheet date.
• Income and expense items are translated to Euro at average exchange rates applicable for each period presented.
The resulting exchange difference from the retranslation and those arising from other monetary items designated as a part of the net
investment in the entity are recorded in equity. When a foreign entity is sold, the exchange differences are reclassified to the income
statement as part of the gain or loss on sale.
1.2.4 Cash and cash equivalents
For the purposes of the cash flow statement, cash and cash equivalents consists of:
• Cash on hand
• Non-restricted balances with Central Banks and
• Short-term balances due from banks and Reverse Repo agreements
Short-term balances due from banks are those that upon initial recognition mature within three months.
Non-restricted placements with Central Banks, short-term balances due from banks and Reverse Repo agreements are measured at amortised
cost.
1.2.5 Classification and measurement of financial instruments
Initial recognition
The Bank and the Group recognise financial assets or financial liabilities in their statement of financial position when they become a party to
the terms of the contract.
At initial recognition financial assets and liabilities are measured at fair values. Financial instruments not measured at fair value through profit
or loss are initially recognised at fair value plus or minus transaction costs and income or fees that are directly attributable to the acquisition
or issue of the financial instrument.
Regular way purchases and sales of financial instruments are recognized at the settlement date with the exception of equity shares and
derivatives that are recognized on trade date. For bonds that are measured at fair value, the change in fair value during the period between
the trade date and the settlement date is recognized in profit or loss or in other comprehensive income based on the bond’s classification
category.
Subsequent measurement of financial assets
Financial assets are classified for measurement purposes as:
a. Financial assets measured at amortised cost
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
266 | The amounts are presented in millions of Euro unless otherwise indicated.
b. Financial assets measured at fair value through other comprehensive income, with gains or losses reclassified in profit or lo ss
on derecognition
c. Equity instruments measured at fair value through other comprehensive income, with no reclassification in gains or losses to
profit or loss on derecognition
d. Financial assets measured at fair value through profit or loss.
For each of the above categories the following apply:
a. Financial assets measured at amortised cost
In this category are classified the financial assets that satisfy both of the following criteria:
• are held within a business model whose objective is to hold financial assets in order to collect contractual cash flows,
• the contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments of principal and
interest (SPPI) on the principal amount outstanding.
The above category is measured at amortised cost using the effective interest method and is periodically assessed for expected credit losses,
as it is further described in note 1.2.13.
Cash and balances with central banks, due from financial institutions, loans and advances to customers that meet the above criteria and
investment securities measured at amortized cost are included in this category.
Due from financial institutions include receivables arising from the transactions of the Treasury business area with credit institutions and
related companies that are not governed by loan agreements.
b. Financial assets measured at fair value through other comprehensive income, with gains or losses reclassified in profit or loss on
derecognition
In this category are classified the financial assets that satisfy both of the following criteria:
• are held within a business model whose objective is a both to collect contractual cash flows and selling financial assets,
• the contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments of principal and
interest (SPPI) on the principal amount outstanding.
The above category is periodically assessed for expected credit losses, as it is further described in note 1.2.13.
Investment securities measured at fair value through other comprehensive income are included in this category.
c. Equity instruments measured at fair value through other comprehensive income, with no reclassification in gains or losses to profit or
loss on derecognition
In this category are classified equity instruments that are neither held for trading nor contingent consideration arising from a business
combination for which it is opted, at initial recognition, to be measured at fair value through other comprehensive income. This decision is
irrevocable. With the exception of dividends, which are directly recognized in profit or loss, all other gains and losses arising from those
instruments are directly recognized in other comprehensive income and are not reclassified to profit or loss. For those equity instruments
there is no impairment assessment.
d. Financial assets measured at fair value through profit or loss
Financial assets included in this category are:
• those acquired principally for the purpose of selling in the near term to obtain short term profit (held for trading).
The Bank and the Group have included in this category bonds, treasury bills and a limited number of shares.
• those that do not meet the criteria to be classified into one of the above categories a-c.
In particular, this category includes loans and advances to customers that are not measured at amortized cost, investment securities measured
at fair value through profit or loss and derivative financial assets.
• those the Bank and the Group designated, at initial recognition, as at fair value through profit or loss.
This classification option, which is irrevocable, is used when the designation eliminates an accounting mismatch which would otherwise arise
from measuring financial assets and liabilities on a different basis (i.e. amortised cost) in relation to another financial asset or liability (i.e.
derivatives which are measured at fair value through profit or loss).
As at the reporting date, the Bank and the Group had not designated, at initial recognition, any financial assets as at fair value through profit
or loss.
Business Model assessment
The business model reflects how the Bank and the Group manage their financial assets in order to generate cash flows. That is, the business
model determines whether cash flows will result from collecting contractual cash flows, selling financial assets or both. The business model is
determined at a level that reflects how groups of financial assets are managed together to achieve a particular business objective. Accordingly,
business model does not depend on management’s intentions for an individual instrument but it is determined on a higher level of
aggregation.
The business models are determined by the Asset Liability Committee (ALCO) or the Executive Committee (ExCo) which decide on the
determination of the business model both for the loans and advances to customers and the securities portfolio. In this contex t:
• For loans and advances to customers the Bank and the Group have identified the following business models:
• Business model whose objective is to hold financial instruments in order to collect their contractual cash flows (hold to collect)
and
• Business model whose objective is the sale of financial instruments which is applied only to syndicated loans that the Group
grants in order to sell them.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
267 | The amounts are presented in millions of Euro unless otherwise indicated.
• Due from financial institutions are included in the business model whose objective is to hold financial assets in order to collect
contractual cash flows (hold to collect).
• For bonds and in general for fixed income investments, the Bank and the Group have identified the following business models:
• Business model whose objective is to hold financial instruments in order to collect their contractual cash flows (hold to collect)
• Business model that aims both at collecting contractual cash flows and selling (hold to collect and sell)
• Trading portfolio
• Business model whose objective is achieved by the sale/distribution of the financial assets.
The classification in the above business models is carried out at the level of the individual business units/companies based on the framework
set at the group level and after an assessment of the way financial instruments are managed by the business units/companies.
At each reporting date, business models are reassessed in order to be confirmed that there has been no change compared to the prior period
or application of a new business model. In the context of the reassessment of the hold to collect business model, past sales as well as
expected future sales are taken into account within specific criteria of significance and frequency. It is noted that the sales of non-performing
exposures that take place due to the deterioration of the borrowers' credit rating, with the exception of those created by the Bank and the
Group and characterized as credit impaired upon initial recognition, do not affect the hold to collect business model.
Solely Payments of Principal and Interest (SPPI) assessment of the contractual cash flows
For the purposes of applying the SPPI assessment:
• Principal is the fair value of the asset at initial recognition, which may change over the life of the financial asset (for example if
there are repayments of principal).
• Interest is the consideration for the time value of money, for the credit risk associated with the principal amount outstandi ng
during a particular period of time and for other basic lending risks (i.e. liquidity risk) and costs, as well as a profit margin.
Contractual terms that introduce exposure to risks and volatility in the contractual cash flows that are not related to a basic lending
arrangement, such as exposure to changes in equity prices or commodity prices, do not give rise to contractual cash flows that are solely
payments of principal and interest on the principal amount outstanding.
In this context, in assessing whether contractual cash flows are SPPI, the Bank and the Group assess whether the instrument contains
contractual terms that change the timing or amount of contractual cash flows such as conversion to equity terms and terms based on which
the performance of the instruments is affected by equity or commodity prices.
Especially in the case of financing of a special purpose vehicle, in order for the loan to meet the criterion that its cash flows are solely
payments of principal and interest on the principal amount outstanding factors such as the capital structure of the debtor and the LTV (Loan to
Value) ratio are taken into account.
In addition, in determining whether contractual cash flows are solely payments of principal and interest on the principal amount outstanding,
it is assessed whether time value of money element has been modified. The time value of money element does not provide consideration for
other risks or costs associated with holding the financial asset. However, in some cases, the time value of money element may be modified.
That would be the case, for example, if a financial asset’s interest rate is periodically reset but the frequency of that reset does not match the
tenor of the interest rate or if a financial asset’s interest rate is periodically reset to an average of particular short- and long-term interest
rates. In such cases, the modification is assessed to determine whether the contractual cash flows represent solely payments of principal and
interest on the principal amount outstanding. The objective of the assessment is to determine how different the contractual (undiscounted)
cash flows could be from the (undiscounted) cash flows that would arise if the time value of money element was not modified (benchmark
test). The effect of the modified time value of money element must be considered in each reporting period and cumulatively over the life of
the instrument. If the Bank and the Group conclude that the contractual (undiscounted) cash flows could be significantly different (based on
specified limits) from the (undiscounted) benchmark cash flows, the contractual cash flows are not solely payments of principal and interest
on the principal amount outstanding.
Reclassification of financial assets
Reclassifications of financial assets between measurement categories occur when, and only when, the Bank and the Group change their
business model for managing the assets and IFRS 9 requirements are met. In this case the reclassification is applied prospectively from the first
reporting period following the change in the business model. Changes in the business model that lead to the reclassification of financial assets
are expected to be rare. They arise from decisions of the Asset Liability Committee (ALCO) or the Executive Committee (ExCo) as a result of
external or internal changes which must be significant to the entity’s operations and demonstrable to external parties.
Derecognition of financial assets
The Bank and the Group derecognize financial assets when:
• the contractual rights to the assets cash flows expire.
• the contractual right to receive the cash flows of the financial assets are transferred and at the same time all the risks and
rewards of ownership are substantially transferred
In the case of transactions where despite the transfer of the contractual right to receive the cash flows from financial assets both the risk and
rewards remain with the Bank and the Group, no derecognition of these financial assets occurs. The amount received by the transfer is
recognized as a financial liability. The accounting practices followed by the Bank and the Group in such transactions are discussed in notes
1.2.20 and 1.2.21.
In the case of transactions, whereby the Bank and the Group neither retain nor transfer risks and rewards of the financial assets, but retain
control over them, the financial assets are recognized to the extent of the Bank’s and the Group’s continuing involvement. If the Bank and the
Group do not retain control of the assets then they are derecognised, and in their position the Bank and the Group recognize, distinctively, the
assets and liabilities which are created or retained during the transfer. No such transactions occurred upon balance sheet date.
• loans or investments in securities are no longer recoverable and consequently are written off,
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
268 | The amounts are presented in millions of Euro unless otherwise indicated.
• the contractual cash flows of the assets are significantly modified.
In case of a change in the contractual terms of a financial asset, when the change is considered significant it results in the derecognition of the
original financial asset and the recognition of a new one. Significant modifications that lead to derecognition include criteria such as, for
example, a change in issuer/borrower and a change in currency.
In case of derecognition due to significant modification, the difference between the carrying amount of the original asset and the fair value of
the new asset is directly recognized in the Income Statement, as specifically mentioned in notes 1.2.26 and 1.2.27. Additionally, in case the
original asset was measured at fair value through other comprehensive income, the cumulative gains or losses recognized in other
comprehensive income are transferred to profit or loss.
In contrast, if the change in contractual cash flows is not significant, the gross carrying amount of the asset is recalculated by discounting new
contractual cash flows with the original effective interest rate and the difference compared to the current gross carrying amount is directly
recognized in profit or loss (modification gain or loss) in the line item “Impairment losses and provisions to cover credit risk”. Fees related to
the modification adjust the carrying amount of the asset and are amortised over the remaining term of the modified financial asset through
the effective interest method.
Subsequent measurement of financial liabilities
The Group classifies financial liabilities in the following categories for measurement purposes:
a. Financial liabilities measured at fair value through profit or loss
This category includes financial liabilities held for trading, that is:
•
financial liabilities acquired or incurred principally with the intention of selling or repurchasing in the near term for short term profit, or
•
derivatives not used for hedging purposes. Liabilities arising from either derivatives held for trading or derivatives used for
hedging purposes are presented as “derivative financial liabilities” and are measured according to the principles set out in note
1.2.6.
•
This category also includes financial liabilities which are designated by the Bank and the Group as at fair value through profit or loss
upon initial recognition, when doing so results in more relevant information, because either:
•
it eliminates or significantly reduces a measurement or recognition inconsistency that would otherwise arise from measuring
assets or liabilities or recognising the gains and losses on them on different bases; or
•
a group of financial liabilities or financial assets and financial liabilities is managed and its performance is evaluated on a fair
value basis, in accordance with a documented risk management or investment strategy, and information about the group is
provided internally on that basis to the Bank’s and Group’s key management personnel;
•
Finally, this category includes contracts containing one or more embedded derivatives and the Bank and the Group measure the
compound financial instruments as financial liabilities measured at fair value through profit or loss.
It is noted that in the above case, the amount of the change in fair value attributable to the Bank’s and the Group’s credit risk is recognized in
other comprehensive income, unless this treatment would create or enlarge an accounting mismatch in profit or loss. Amounts recognized in
other comprehensive income are never reclassified to profit or loss.
As at the reporting date, the Bank and the Group had not designated, at initial recognition, any financial liabilities as at fair value through
profit or loss.
b. Financial liabilities carried at amortised cost
Liabilities to credit institutions and customers, debt securities issued by the Bank and the Group and other loan liabilities are classified in this
category.
The liabilities classified in this category are measured at amortised cost using the effective interest method.
In cases when financial liabilities included in this category are designated as the hedged item in a hedge relationship, the accounting principles
applied are those set out in note 1.2.6.
c. Liabilities arising from financial guarantees and commitments to provide loans at a below market interest rate
A financial guarantee contract is a contract that requires the issuer to make specified payments to reimburse the holder for a loss it incurs
because a specified debtor fails to make a payments when due in accordance with the agreed terms.
The financial guarantee contracts and the commitments to provide loans at a below market interest rate are initially recognized at fair value,
and measured subsequently at the higher of:
• the amount of the provision determined during expected credit loss calculation (note 1.2.13),
• the amount initially recognised less cumulative amortization which is calculated based on the term of the instrument.
d. Financial liabilities that arise when a transfer of a financial asset does not qualify for derecognition or when the continuing involvement
approach applies
In the first case the liability should be equal to the amount received during the transfer while in the second case it should measured in such a
way that the net carrying amount of the transferred asset and the associated liability is:
• The amortised cost of the rights and obligations retained by the Bank and the Group, if the transferred asset is measured at
amortised cost or
• Equal to the fair value of the rights and obligations retained by the Bank and the Group when measured on a stand-alone basis,
if the transferred asset is measured at fair value.
e. Contingent consideration recognized by an acquirer in a business combination
Such contingent consideration is subsequently measured at fair value with changes recognized in profit or loss.
Derecognition of financial liabilities
Financial liabilities (or part thereof) are derecognized when the contractual obligation is been discharged, cancelled or expires.
When a financial liability is exchanged for another liability with substantially different terms, the exchange is accounted for as an
extinguishment of the original financial liability and the recognition of a new one. The same applies in cases of a substantial modification of
the terms of an existing financial liability or a part of it (whether or not attributable to the financial difficulty of the debtor). The terms are
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
269 | The amounts are presented in millions of Euro unless otherwise indicated.
considered substantially different if the discounted present value of the cash flows under the new terms (including any fees paid net of any
fees received), discounted using the original effective interest rate, is at least 10% different from the present value of the remaining cash flows
of the original financial liability.
In cases of derecognition, the difference between the carrying amount of the financial liability (or part of the financial liability) extinguished or
transferred to another party and the consideration paid, including any non-cash assets transferred or liabilities assumed, is recognised in profit
or loss.
Offsetting financial assets and financial liabilities
Financial assets and liabilities are offset and the amount are reported net on the balance sheet, only in cases when the Group has the legally
enforceable right to offset recognized amounts and there is the intention to settle on a net basis, or to realize the asset and settle the liability
simultaneously.
1.2.6 Derivative financial instruments and hedge accounting
Derivative financial instruments
Derivatives are financial instruments that upon inception have a minimal or zero fair value that subsequently changes in accordance with a
particular underlying instrument or indices defined in the contract (foreign exchange, interest rate, index or other variable).
Derivatives are entered into for either hedging or trading purposes and they are measured at fair value irrespective of the purpose for which
they have been transacted.
The change in the fair value of the interest and currency derivatives, excluding options, is separated into interest, foreign exchange differences
and other gains or losses from financial transactions.
All derivatives are recognized as assets when their fair value is positive and as liabilities when their fair value is negative.
In case a derivative is embedded in a financial asset, the embedded derivative is not separated and the hybrid contract is accounted for based
on the classification requirements mentioned in note 1.2.5.
In case a derivative is embedded in a host contract, other than a financial asset, the embedded derivative is separated and measured at fair
value through profit or loss when the following conditions are met:
• the economic characteristics and risks of the embedded derivative are not closely related to the economic characteristics and
risks of the host,
• a separate instrument with the same terms as the embedded derivative would meet the definition of a derivative; and
• the hybrid contract is not measured at fair value with changes in fair value recognised in profit or loss.
The Bank and the Group use derivatives as a means of exercising Asset-Liability management within the guidelines established by the Asset-
Liability Committee (ALCO).
Valuation differences arising from derivatives are recognized in “Gains less losses on financial transactions” except when derivatives
participate in hedging relationships in which case the principles for hedge accounting mentioned below apply.
It is noted that the Bank and the Group use FX swaps in order to economically hedge the exposures arising from customer loans and deposits.
The result arising from these derivatives is recognized as interest and foreign exchange differences, in order to match with the interest
element and foreign exchange differences resulting from the deposits and loans, and as other gains less losses on financial transactions.
Hedge accounting
Hedge accounting establishes the valuation rules to offset the gain or loss of the fair value of a hedging instrument and a hedged item which
would not have been possible if the normal measurement principles were applied. It is noted that the Bank and the Group have opted to
continue to apply the provisions for hedge accounting of IAS 39.
Documentation of the hedging relationship upon inception and of the effectiveness of the hedge on an on-going basis are the basic
requirements for the adoption of hedge accounting.
The hedge relationship is documented upon inception and the hedge effectiveness test is carried out upon inception and is repeated at each
reporting date.
A hedge is regarded as highly effective only if both of the following conditions are met:
• at the inception of the hedge and in subsequent periods the hedge is expected to be highly effective in achieving offsetting
changes in fair value or cash flows attributable to the hedged risk during the period for which the hedge is designated,
• the actual results of the hedge are within a range of 80%-125%.
The main causes that may lead to hedging ineffectiveness are the following:
• The credit risk (counterparty risk) of the hedging instruments used to hedge interest rate or currency risk, which is minimized
by using derivatives with high credit rating counterparties
• The timing difference in the cash flows of the hedging instruments and the hedged items.
A hedging relationship is disccontinued prospectively when:
• the hedging instrument expires, sold, terminated or excercised,
• the hedge ceases to be effective (in this case the discontinuation is applied from the last date the effectiveness criteria were
met),
• the Bank and the Group revoke the designation,
• the forecast transaction (in case of a hedge of a forecast transaction) is no longer expected to occur.
a. Fair value hedges
A fair value hedge of a financial instrument offsets the change in the fair value of the hedged item in respect of the risks being hedged.
The Bank and the Group use interest rate swaps (IRS’s) to hedge risks relating to borrowings, deposits, loans and bonds. The Bank also hedges
foreign exchange risks related to investments in subsidiaries through the use of foreign exchange derivatives. For all interest rate risk hedging
relationships, the Bank and the Group define at the inception of the relationship the reference interest rate related to the hedged risk (euro
interest rate) and calculate the changes in the fair value of the hedged instrument as changes in the euro interest rate curve.
Changes in the fair value of both the hedging instrument and the hedged item, in respect of the specific risk being hedged, are recognized in
the income statement.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
270 | The amounts are presented in millions of Euro unless otherwise indicated.
When the hedging relationship no longer exists, the hedged items continue to be measured based on the classification and valuation
principles set out in note 1.2.5. Specifically any adjustment, due to the fair value change of a hedged item for which the effective interest
method is used, up to the point that the hedging relationship ceases to be effective, is amortised to interest income or expense based on a
recalculated effective interest rate, over its remaining life.
Especially with regard to deposits, it is noted that the Bank and the Group apply interest rate risk hedge accounting on a deposit portfolio
using the hedge accounting provisions adopted by the European Union (EU Carve-out).
b. Cash flow hedge
A cash flow hedge changes the cash flows of a financial instrument from a variable rate to a fixed rate.
The Bank and the Group define at the inception of the hedging relationship the reference interest rate related to the hedged risk (euro interest
rate) and measure the changes in the fair value of the hedging instrument and a hypothetical derivative in relation to changes in the euro
interest rate curve. The floating leg of the hypothetical derivative simulates the cash flows of the hedged item while the cash flows of the fixed
leg are defined in a way that makes the valuation of the hypothetical derivative zero at the inception of the hedge.
The effective portion of the gain or loss on the hedging instrument is recognized directly in other comprehensive income, in cash flow hedge
reserve, whereas the ineffective portion is recognized in “Gains less losses on financial transactions”. The accounting treatment of the hedged
item does not change.
When the hedging relationship is discontinued, the amount recognized in equity remains there separately until the cash flows or the future
transaction occur. When the cash flows or the future transaction occur the following apply:
• If the result is the recognition of a financial asset or a financial liability, the amount is reclassified to profit or loss in the same
periods during which the hedged forecast cash flows affect profit or loss.
• If the result is the recognition of a non-financial asset or a non-financial liability or a firm commitment for which fair value
hedge accounting is applied, the amount recognized in equity either is reclassified to profit or loss in the same periods during
which the asset or the liability affect profit or loss or adjusts the carrying amount of the asset or the liability.
When a forecasted transaction or the expected cash flows are no longer expected to occur, the cumulative gain or loss that was recognized in
equity is reclassified to profit or loss. In particular, the amount that has been recognized in equity, as a result of revoked cash flow hedging
relationships for term deposits, is linearly amortised as interest expense in the periods during which the hedged cash flows from the
aforementioned term deposits affect profit or loss.
c. Hedges of net investment in a foreign operation
The Group, following the decision of the Asset-Liability Committee (ALCO), uses foreign exchange derivatives, mainly cross currency interest
rate swaps and foreign exchange swaps, to hedge foreign exchange risks arising from investment in foreign operations. To hedge the currency
risk of the net investment in a foreign operation, the net assets are measured at the current exchange rate and the resulting exchange
differences are compared with the exchange differences of the derivative.
Hedge accounting of net investment in a foreign operation is similar to cash flow hedge accounting. The cumulative gain or loss recognized in
equity is reversed and recognized in profit or loss, at the time that the disposal of the foreign operation takes place.
1.2.7 Fair Value Measurement
Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market
participants at the measurement date, in the principal market for the asset or liability or, in the absence of a principal market, in the most
advantageous market for the asset or liability.
The Bank and the Group measure the fair value of assets and liabilities traded in active markets based on available quoted market prices. A
market is regarded as active if quoted prices are readily and regularly available from an exchange, dealer, broker, pricing service or regulatory
agency, and those prices represent actual and regularly occurring market transactions on an arm’s length basis.
The fair value of financial instruments that are not traded in an active market is determined by the use of valuation techniques, appropriate in
the circumstances, and for which sufficient data to measure fair value are available, maximizing the use of relevant observable inputs and
minimizing the use of unobservable inputs. If observable inputs are not available, other model inputs are used which are based on estimations
and assumptions such as the determination of expected future cashflows, discount rates, probability of counterparty default and
prepayments. In all cases, the Bank and the Group use the assumptions that ‘market participants’ would use when pricing the asset or liability,
assuming that market participants act in their economic best interest.
Assets and liabilities which are measured at fair value or for which fair value is disclosed are categorized according to the inputs used to
measure their fair value as follows:
• Level 1 inputs: quoted market prices (unadjusted) in active markets
• Level 2 inputs: directly or indirectly observable inputs
• Level 3 inputs: unobservable inputs used by the Bank and the Group, to the extent that relevant observable inputs are not
available
In particular, the Bank and the Group apply the following:
Financial instruments
For financial instruments the best evidence of fair value at initial recognition is the transaction price, unless the fair value can be derived by
other observable market transactions relating to the same instrument, or by a valuation technique using mainly observable inputs. In these
cases, if the fair value differs from the transaction price, the difference is recognized in the statement of comprehensive income. In all other
cases, fair value is adjusted to defer the difference with the transaction price. After initial recognition, the deferred difference is recognized as
a gain or loss only to the extent that it arises from a change in a factor that market participants would take into account when pricing the
instrument.
When measuring fair value, the Bank and the Group take into consideration the effect of credit risk. Specifically, for derivative contracts, the
Bank and the Group estimate the credit risk of both counterparties (bilateral credit valuation adjustments).
The Bank and the Group measure fair value for all assets and liabilities separately. Regarding derivative exposures, however, that are managed
as a group on a counterparty basis and for which information is provided to the key management personnel, the fair value measurement for
credit risk is performed based on the net risk exposure per counterparty. Credit valuation adjustments arising from the aforementioned
process are allocated to either assets or liabilities, depending on whether the net exposure to the counterparty is long or short respectively.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
271 | The amounts are presented in millions of Euro unless otherwise indicated.
Furthermore, the fair value of deposit accounts with a demand feature (such as saving deposits) is no less than the amount payable on
demand, discounted from the first date that the amount could be required to be paid.
Non- financial assets and liabilities
The most important category of non- financial assets for which fair value is estimated is real estate property.
The process, mainly, followed for the determination of the fair value is summarized below:
• Assignment to the engineer - valuer
• Case study- Setting of additional data
• Autopsy - Inspection
• Data processing - Calculations
• Preparation of the valuation report
To derive the fair value of the real estate property, the valuer chooses among the three following valuation techniques or a combination of
two of them in cases required by the special characteristics of the property or in cases that special conditions prevail such as for example an
energy crisis:
• Market approach (or sales comparison approach), which measures the fair value by comparing the property to other identical
ones for which information on transactions is available.
• Income approach, which capitalizes future cash flows arising from the property using an appropriate discount rate.
• Cost approach, which reflects the amount that would be required currently to replace the asset with another asset with similar
specifications, after taking into account the required adjustment for impairment.
Examples of inputs used to determine the fair value of properties and which are analysed to the individual valuations, are the following:
• Commercial property: price per square meter, rent growth per annum, long-term vacancy rate, discount rate, expense rate of
return, lease term, rate of non leased properties/units for rent.
• Residential property: Net return, reversionary yield, net rental per square meter, rate of continually non leased
properties/units, expected rent value per square meter, discount rate, expense rate of return, lease term etc.
• General assumptions such as the age of the building, residual useful life, square meter per building etc are also included in the
analysis of the individual valuation assessments.
It is noted that the fair value measurement of a property takes into account a market’s participant ability to generate economic benefits by
using the asset in it’s highest and best use or by selling it to another market participant that would use the asset in it’s highest and best use.
1.2.8 Property, Plant and Equipment
This caption includes: land, buildings used by branches or for administrative purposes, additions and improvements of leased property and
equipment. It also includes right of use assets in case those assets are used by the Bank and the Group (the accounting policies applicable to
those assets are presented in note 1.2.11).
Property, plant and equipment are initially recognised at cost which includes any expenditure directly attributable to the acquisition of the
asset.
Subsequently, property, plant and equipment are measured at cost less accumulated depreciation and impairment losses.
Subsequent expenditure is recognized on the carrying amount of the item when it increases future economic benefit.
Expenditure on repairs and maintenance is recognized in profit or loss as an expense as incurred.
Depreciation is charged on a straight line basis over the estimated useful lives of property, plant and equipment and it is calculated on the
asset’s cost minus residual value.
Under the Group policy, the estimated useful lives are as follows:
• Buildings:
• commercial properties with office / shop use and residential properties:
• up to 50 years for properties with high criteria for construction - reconstruction - renovation and which are characterized as
sustainable. In some cases, for newly built properties with very high criteria and construction elements, the useful life can
reach 70 years.
• up to 45 years for the remaining properties that do not meet the above characteristics
• for industrial - craft and other commercial properties:
• up to 45 years for properties with high criteria for construction - reconstruction - renovation and which are characterized as
sustainable
• up to 40 years for the remaining properties that do not meet the above characteristics
• embedded mechanical equipment: up to 25 years.
• Additions to leased fixed assets and improvements: duration of the lease
• Equipment and vehicles: up to 33 years
Land is not depreciated but is tested for impairment.
The residual value of property and equipment and their useful lives are periodically reviewed and adjusted if necessary at each reporting date.
Property, plant and equipment are reviewed on an annual basis to determine whether there is an indication of impairment and if they are
impaired the carrying amount is adjusted to its recoverable amount with the difference recorded in profit or loss.
In case of sale of property, plant and equipment as well as when no economic benefits are expected, the fixed asset is derecognised. When
selling the asset, the difference between the sale price and its carrying amount is recognized in profit or loss.
1.2.9 Investment property
This category includes buildings or portions of buildings together with their respective portion of land that are held for the purpose of long-
term lease or for capital appreciation. It also includes right of use assets when the Bank and the Group are intermediate lessors in an
operating lease (the accounting policies applicable to those assets are presented in note 1.2.11).
Investment property is initially recognised at cost which includes any expenditure directly attributable to the acquisition of the asset.
Subsequently investment property is measured at fair value with changes in fair value recognized directly in profit or loss. Fair value is
calculated on a semi-annual basis.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
272 | The amounts are presented in millions of Euro unless otherwise indicated.
Subsequent expenditure is recognized on the carrying amount of the item when it increases future economic benefit and can be measured
reliably. All costs for repairs and maintenance are recognized in profit or loss as incurred.
Transfers to and from the category of investment property are made when the property meets (or ceases to meet) the definition of
investment property and there is evidence of change in its use. In particular, the property is reclassified in “Property, pla nt and equipment” if
the Bank and the Group decide to use it while it is reclassified in the category of other assets if it is intended for sale or in property held for
sale if the criteria referred to in paragraph 1.2.16 are met. Conversely, for property no t classified within “Investment Property”, the
commencement of its lease constitutes a proof of change of use and may lead to the reclassification to investment property.
In case of sale of investment property as well as when no economic benefits are expected, the fixed asset is derecognised. When selling the
asset, the difference between the sale price and its carrying amount is recognized in profit or loss.
1.2.10 Goodwill and other intangible assets
Goodwill
Positive goodwill is recorded to “Goodwill and other intangible assets”, if it relates to the acquisition of a subsidiary, and it is tested for
impairment at each balance sheet date. Goodwill on acquisitions of associates or joint ventures in consolidated financial statements is part of
the caption“Investment in associates and joint ventures”.
Negative goodwill is recognized in profit or loss.
Other intangible assets
This caption includes:
a. Intangible assets which are recognized from business combinations or which are individually acquired. These intangible assets include the
value attributed to the acquired customer relationships and to deposit bases. Intangible assets arising from business combinations are initially
measured at fair value while those individually acquired are initially measured at cost. Subsequently, they are depreciated, using the straight
line method, their useful life, which has been set up to 10 years, and are assessed for impairment when there are triggers for impairment.
b. Software, which is measured at cost less accumulated amortization and impairment losses. Expenditure incurred to maintain software
programs is recognized in the income statement as incurred. Software that is considered to be an integral part of hardware is classified in
property, plant and equipment.
More specifically, separately acquired software is initially measured at cost which comprises its purchase price and any directly attributable
cost of preparing the software for its intended use, including employee benefits or professional feesSoftware acquired as part of a business
combination is initially measured at fair value. Both software separately acquired and acquired as part of a business combination is
depreciated during its useful life which has been set up to 15 years both for the Bank and the Group
Regarding internally generated software, the Bank and the Group recognize an intangible asset when they can demonstrate all of the following
at the development phase:
• the technical feasibility of completing the intangible asset so that it will be available for use or sale;
• their intention to complete the intangible asset and use or sell it;
• their ability to use or sell the intangible asset;
• how the intangible asset will generate probable future economic benefits;
• the availability of adequate technical, financial and other resources to complete the development and to use or sell the
intangible asset;
• their ability to measure reliably the expenditure attributable to the intangible asset during is development.
Expenditure incurred during the research phase is directly recognized in profit or loss.
Consequently, the cost of an internally generated intangible asset is the sum of expenditure incurred from the date when the intangible asset
first meets the above criteria, including employee benefits arising from the generation of the software.
Internally generated software is depreciated, using the straight line method, during its useful life which has been set up to 15 years both for
the Bank and the Group
All intangible assets are assessed for impairment when there are triggers for impairment (note 1.2.14).
No residual value is estimated for intangible assets.
In case of sale of an intangible asset the intangible asset is derecognised, while when no economic benefits are expected for the Bank and
Group, its value is fully impaired. When selling the asset, the difference between the sale price and its carrying amount is recognized in profit
or loss.
1.2.11 Leases
The Bank and the Group enter into leases either as a lessee or as a lessor. At inception, it is assessed whether a contract is or contains a lease.
The lease term is determined as the non-cancellable period of a lease, together with both periods covered by an option to extend the lease if
the lessee is reasonably certain to exercise that option and periods covered by an option to terminate the lease if the lessee is reasonably
certain not to exercise that option.
a. When the Group is the lessor
When the risks and rewards incident to ownership of an asset are transferred to the lessee they are classified as finance leas es.
All other lease agreements are classified as operating leases:
i. Finance leases:
For finance leases where the Bank and the Group are the lessor the present value of lease payments is recognized as loans and advances.
The difference between the present value (net investment) of lease payments and the aggregate amount of lease payments is recognized as
unearned finance income and is deducted from loans and advances.
The finance lease receivables are subject to the same impairment testing as applied to customer loans and advances as described in note
1.2.13.
ii. Operating leases:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
273 | The amounts are presented in millions of Euro unless otherwise indicated.
When the Bank and the Group are the lessors of assets under operating leases, the leased asset is recognized and measured depending on its
classification category. Income arising from the leased asset is recognized as other income on an accrual basis.
b. When the Group is the lessee
The Bank and the Group, as lessees, recognize for all leases a right of use asset and a lease liability at the commencement of the lease. The
right of use asset is initially measured at cost, comprising the initial lease liability amount, any initial direct costs and an estimate of the
obligation for costs to refurbish the asset, less any lease incentives received.
Right-of use assets are subsequently measured at cost less any accumulated depreciation, any accumulated impairment losses and adjusted
for any remeasurement of the lease liability expect for righ-of-use assets classified within investment property which are measured at fair
value.
Depreciation is charged on a straight line basis from the commencement date to the earlier of the end of the useful life of the right-of-use
asset or the end of the lease term. Right-of-use assets classified within property, plant and equipment are reviewed at each reporting date to
determine whether there is an indication of impairment and if they are impaired the carrying amount is adjusted to its recoverable amount
with the difference recorded in profit or loss (note 1.2.14).
For short-term leases (lease term of 12 months or less) and leases for which the underlying asset is of low value (less than 5.000 EUR when
new) the Bank and the Group do not recognize a right-of-use asset and a lease liability but instead recognize the lease payments as an expense
on a straight-line basis over the lease term.
The lease liability is initially measured at the present value of lease payments that are not paid at that date, net of cash lease incentives. Lease
payments are discounted using the lessee’s incremental borrowing rate. Incremental borrowing rate is determined by using as reference rate
the estimated cost of the Bank’s secured funding rate, adjusted for different currencies and taking into consideration government yield curves,
where applicable.
After the commencement date, the Bank and the Group measure the lease liability by increasing the carrying amount to reflect interest,
reducing the carrying amount to reflect lease payments made and remeasuring the carrying amount to reflect any reassessment or lease
modifications.
In case of a sale and leaseback transaction only the amount related to the rights that have been transferred to the buyer-lessor is recognized in
profit or loss.
Right of use assets are included within Property, plant and equipment and the lease liability is included in Other liabilities. In cases where the
Bank and the Group are intermediate lessors in an operating lease, right of use assets recognized for the head lease are included within
Investment property while in case the Bank and the Group are intermediate lessors in a finance lease right of use asset, or the part of it which
is subleased, is derecognized and a finance lease receivable is recognized.
Specifically for the Bank, the duration of the professional lease contracts is defined in most cases for three years, with the possibility of
unilateral extension in some of them by the Bank for an additional period of time. The Bank decides whether to make use of this option by
evaluating current conditions, while it retains the right to terminate the lease at any time during the term of the contract. The Bank's policy is
to renew these contracts if it wishes to remain in the properties.
Finally, in the leases of premises for the Off Site ATM operation, their duration, in their majority, is set at one or two years and if they are
renewed, as the contract provides for their conversion to an indefinite period, it is estimated that the duration of the lease will be ten years.
1.2.12 Insurance activities
a. Insurance contracts
The Group through its subsidiary company Alpha Life enters into insurance contracts. Insurance contracts are contracts under which the
insurance company accepts significant insurance risk from the policyholder by agreeing to compensate the policyholder if a specified
uncertain future event adversely affects the policyholder.
For the Group, insurance risk is significant when the amount paid in the event of insurance risk exceeds 5% of the total benefit arising from the
contract.
The contracts that Alpha Life enters into and which do not involve a significant insurance risk are classified as investment contracts, are
included in caption “Due to customers” in the balance sheet and are measured as financial liabilities under IFRS 9.
b. Level of aggregation of insurance contracts
Insurance contracts are grouped into portfolios of contracts. A portfolio comprises contracts subject to similar risks and managed together.
Contracts included in a group of contracts are issued less than 12 months apart while the annual basis is determined as the calendar year, i.e.
the period from 1.1 to 31.12.
c. Measurement
The insurance contracts of the Group are contracts with direct participation features and are measured based on the variable fee approach. In
particular, on initial recognition, groups of insurance contracts are measured at the total of:
• the fulfillment cash flows, which comprise:
• estimates in present value of future cash flows within the boundary of each contact and
• a risk adjustment for non-financial risk,
• the contractual service margin.
Fulfillment future cash flows are those that relate directly to the contract, such as premiums, payments to policyholders, insurance
acquisition cash flows, administration costs etc. while the contract boundary is determined by its duration as this is stated in
the insurance contract. In the actuarial models are also included expenses which are within the scope of IFRS 17 and which are
allocated based on their nature.
To discount cash flows, the Group uses discount rates based mainly on the interest rate curve as determined by the European Insurance and
Occupational Pensions Authority (EIOPA) applying zero liquidity premium.
The risks covered by the risk adjustment for non-financial risk are insurance risk and other non-financial risks such as lapse risk and expense
risk. The cost of capital approach is used for the calculation of the adjustment. A confidence level of 99.5% is used to determine the risk
adjustment for non-financial risk.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
274 | The amounts are presented in millions of Euro unless otherwise indicated.
In accordance with the Group policy, changes in the risk adjustment for non-financial risk are not disaggregated and as a result the total
change is included in the insurance service result.
On initial recognition, the contractual service margin is measured at an amount that results in no income or expenses arising from:
• the initial recognition of an amount for the fulfilment cash flows,
• the derecognition at the date of initial recognition of any asset or liability recognised for insurance acquisition cash flows , and
• any cash flows arising from the contracts in the group at that date.
Subsequently, the contractual service margin is adjusted for the change in the Group’s share of the fair value of the underlying items, the
effect of any new contracts added, the changes in fulfilment cash flows relating to future service and the amount recognised as insurance
revenue because of the transfer of services in the period.
At the end of each reporting period, the carrying amount of a group of insurance contracts is the sum of the following:
• the liability for remaining coverage (fulfillment cash flows related to future service and the contractual service margin) and
• the liability for incurred claims (fulfillment cash flows related to past service).
The methodology for the identification of coverage units is determined by considering for each contract the quantity of the benefits provided
under a contract as well as its expected coverage duration, in particular by taking into consideration the fund value.
d. Presentation
The liabilities from insurance contracts that fall within the scope of the IFRS 17 are presented in the line "Liabilities from insurance contracts"
while receivables from reinsurance contracts are presented in the line "Reinsurance contracts assets".
Regarding the Income Statement, insurance revenue and insurance service expenses are presented separately in captions “insurance revenue”
and “insurance expenses” respectively, whereas their total is presented in caption “Net Insurance income”. In addition, insurance finance
income or expenses are separately presented in caption “Finance income/(expense) from insurance contracts”.
It is noted that as Alpha Life, from which the insurance contracts arise, has been classified as held for sale and its results as arising from
discontinued operations, the liabilities from insurance contracts are included in "Liabilities related to assets classified as held for sale" and the
results from insurance contracts in "Net profits/(loss) after income tax, from discontinued operations".
1.2.13 Provisions – Expected credit losses
The Bank and the Group, at each reporting date, recognize a loss allowance for expected credit losses on all debt financial instrumentss
measured at amortised cost or at fair value through other comprehensive income as well as for off-balance sheet exposures (letters of
guarantee, letters of credit, undrawn loan commitments) and finace lease receivables.
The loss allowance is based on expected credit losses related to the probability of default within the next twelve months (Stage 1), unless
there has been a significant increase in credit risk from the date of initial recognition or the instrument has become impaired in which cases
expected credit losses are recognized over the life of the instrument (Stages 2 or 3). In addition, if the financial asset falls under the definition
of purchased or originated credit impaired (POCI) financial assets, a loss allowance equal to the lifetime expected credit losses is recognized.
Purchased or originated credit impaired exposures include:
• Exposures that at the time of acquisition meet the criteria to be classified as non-performing exposures.
• Exposures for which there has been a change in repayment terms, either due to financial difficulty or not, which resulted in
derecognition and recognition of a new impaired asset (POCI) except when derecognition is due to the change of debtor of a
corporate loan in which case the creditworthiness of the new debtor is reassessed.
Especially for investments in debt securities, the following apply:
• The instrument (or the issuer) is characterised as purchased or originated credit impaired when it has an external rating tha t
corresponds to default at the time of acquisition
• Corporate bonds resulting from debt restructuring are classified as purchased or originated credit impaired, based on the
guidelines applicable to the loan portfolio.
When a debt security has been purchased at a large discount and does not fall into any of the categories mentioned above, the transaction is
examibed in detail (transaction price, recovery rate, issuer’s financial condition at the time of purchase, etc.) in order to be determined
whether it should be recognised as purchased or originated credit-impaired (POCI). Classification in this category requires documentation and
approval by the relevant committees of the Bank and the Group.
Finally, for receivables from customers derived from the Bank’s and the Group’s commercial, other than loan, activity, the loss allowance for
receivables from customers is measured at an amount equal to the lifetime expected credit losses (there is no stage allocation) based on the
simplified approach provided by IFRS 9.
Default definition
For credit exposures, the Bank and the Group have adopted the default definition defined in the EBA Guidelines (GL/2016/07). It is noted that
the Bank and the Group have harmonized the perimeter of exposures recognized as “Defaulted Exposures”, as “Non-Performing Exposures”
and as “IFRS 9 Impaired Exposures”.
Due from financial institutions and bonds are considered impaired when the external rating of the issuer/counterparty is equivalent to default
(D). In case there is no external rating, then the instrument is characterized as impaired based on internal rating. If there is also an exposure to
the corporate issuer/counterparty to the loan portfolio which has been classified as impaired, the instrument is also characterized as impaired.
Calculation of expected credit loss
The measurement of expected credit losses is made as follows:
•
For financial assets, a credit loss is the present value of the difference between:
•
the contractual cash flows and
•
the cash flows that the Group expects to receive
•
For undrawn loan commitments, a credit loss is the present value of the difference between:
•
the contractual cash flows that are due if the holder of the loan commitment draws down the loan; and
•
the cash flows that the Group expects to receive if the loan is drawn down.
•
For letters of guarantee and letters of credit, the loss is equal to the expected payments to reimburse the holder for a credit loss that it
incurs less any amounts that the Group expects to receive from the holder.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
275 | The amounts are presented in millions of Euro unless otherwise indicated.
For present value calculation, original effective interest rate is used as a discount rate. Especially for POCI assets credit-adjusted effective
interest rate is used.
More information on the calculation of expected credit loss (individual/collective assessment, credit risk parameters, incorporation of future
information, adjustments by management) is included in note 49.1.
Presentation of expected credit losses in financial statements
Loss allowances for expected credit losses are presented in the Balance Sheet as follows:
• Financial assets measured at amortised cost and finance lease receivables: loss allowance is presented as a deduction from the
gross carrying amount of the assets.
• Financial assets measured at fair value through other comprehensive income: for those assets no loss allowance is recognized
in the Balance Sheet, however, its amount is disclosed in the notes to the financial statements.
• Letters of credit/letters of guarantee: loss allowance is recognized in line “Provisions” of liabilities in Balance Sheet.
• Undrawn loan commitments: When there is not also a loan, loss allowance is recognized in line “Provisions” of liabilities in
Balance Sheet. If a financial asset includes both a loan and an undrawn loan commitment, the accumulated expected credit
losses of the loan commitment are presented together with the accumulated expected credit losses of the loan, as a deduction
from its gross carrying amount. To the extent that the combined expected credit losses exceed the gross carrying amount of
the loan, the expected credit losses are recognized in line “Provisions” of liabilities in Balance Sheet.
The amount of expected credit losses for the period is presented in the caption “Impairment losses and provisions to cover credit risk”. In the
same caption the following are also recognized: recoveries from written-off loans measured at amortised cost, the amounts received from
financial guarantee contracts as well as the reimbursements received from synthetic securitization transactions, modification gains or losses of
loans measured at amortised cost as well as the favourable changes in expected credit losses of POCI assets in case expected credit losses are
less than the amount of expected credit losses included in the estimated cash flows on initial recognition.
Write-offs
The Bank and the Group proceed with the write-off of loans and advances to customers when it has no reasonable expectations for their
recovery. In this case, the loss allowance is used against the carrying amount of the financial asset. Write-off is an event of derecognition.
1.2.14 Impairment losses on investments and non-financial assets
The Bank and the Group assess as at each balance sheet date their investments in subsidiaries, associates and joint ventures as well as non-
financial assets for impairment, particularly, right of use assets measured at cost, goodwill and other intangible assets and at least annually
property, plant and equipment.
In assessing whether there is an indication that an asset may be impaired both external and internal sources of information are considered, of
which the following are indicatively mentioned:
• The asset’s market value has declined significantly, more than would be expected as a result of the passage of time or normal
use.
• Significant changes with an adverse effect have taken place during the period or will take place in the near future, in the
technological, economic or legal environment in which the entity operates or in the market to which the asset is dedicated.
• Significant unfavorable changes in foreign exchange rates.
• Market interest rates or other rates of return of investments have increased during the period, and those increases are likely to
affect the discount rate used in calculating an asset’s value in use.
• The carrying amount of the net assets of the entity is greater than its market capitalization.
• Evidence is available of obsolescence or physical damage of an asset.
Specifically for right of use assets measured at cost, triggers for impairment include:
• The existence of leased properties that are neither used nor leased by the Bank and the Group.
• The fact that the present value of the leases received in the event of a sublease is lower than the value of the rents paid under
the lease.
An impairment loss is recognized in profit or loss when the recoverable amount of an asset is less than its carrying amount. The recoverable
amount of an asset is the higher of its fair value less costs to sell and its value in use.
For the valuation of property, plant and equipment, the calculation of the recoverable amount includes all improvements which render the
asset perfectly suitable for its use by the Bank and the Group.
An impairment loss recognised in prior periods shall be reversed in case of a change in the estimates for the determination of the recoverable
amount. The increased carrying amount of the asset attributable to the reversal of an impairment loss shall not exceed the carrying amount
that would have been determined had no impairment loss been recognised. An impairment loss recognised for goodwill shall not be reversed.
1.2.15 Income tax
Income tax consists of current and deferred tax.
Current tax for a period includes the expected amount of income tax payable in respect of the taxable profit for the current reporting period,
based on the tax rates enacted at the balance sheet date. It also includes the impact from the application of the OECD Pillar II rules (note 45).
Deferred tax is the tax that will be paid or for which relief will be obtained in future periods and it is calculated based on the temporary
differences between the tax base of assets and liabilities and their respective carrying amounts in the financial statements.
Deferred tax assets and liabilities are calculated using the tax rates that are expected to apply when the temporary difference reverses, based
on the tax rates (and laws) enacted at the balance sheet date. As provides by IAS 12, the application of the OECD Pillar II rules is not taken into
account in deferred tax assets and liabilities measurement.
A deferred tax asset is recognized to the extent that it is probable that future taxable profits will be available against which the asset can be
utilized.
In addition, deferred tax assets are not recognized from the initial recognition of an asset or liability in a transaction that is not a business
combination and at the time it takes place affects neither accounting profit nor taxable profit.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
276 | The amounts are presented in millions of Euro unless otherwise indicated.
Furthermore, regarding investments in subsidiaries, associates and joint ventures, deferred tax assets are recognized only when it is probable
that the temporary difference will reverse in the foreseeable future and taxable profit will be available against which the temporary difference
can be utilized.
Income tax, both current and deferred, is recognized in profit or loss except when it relates to items recognized directly in equity. In such
cases, the respective income tax is also recognized in equity. In this context, the tax related to the dividend distribution, as assessed to
constitute the payment of the return on the AT1 instrument, is recognized in profit or loss.
1.2.16 Non-current assets held for sale
Non-current assets or disposal groups that are expected to be recovered principally through a sale transaction, along with the related
liabilities, are classified as held-for-sale.
The above classification is used if the asset is available for immediate sale in its present condition and its sale is highly probable. The sale is
considered highly probable when it has been decided by the competent bodies of the Management, an active programme to locate a buyer
has been initiated, the asset is actively marketed for sale at a price which is reasonable in relation to its current fair value and the sale is
expected to be completed within one year. In the event that the sale is not completed within one year, the asset remains classified as held for
sale when the cause of the delay is beyond the Bank’s and the Group's control and/or when the Bank and the Group are still committed to the
plan for its disposal and the sale is considered probable. Non-current assets that are acquired exclusively with a view to their subsequent
disposal are classified as held for sale at the acquisition date when the one-year requirement is met and it is highly probable that the
remaining criteria will be met within a short period following the acquisition (usually within three months).
Before their classification as held for sale, the assets are remeasured in accordance with the respective accounting standard.
Assets held for sale are initially recognised and subsequently remeasured at each balance sheet date at the lower of their carrying amount and
fair value less cost to sell. As an exception, the method of measurement does not change for investment properties and financial instruments
due to the reclassification to held for sale.
Any loss arising from the above measurement is recorded in profit or loss and can be reversed in the future. In this case, the gain from any
subsequent increase in fair value less costs to sell cannot exceed the cumulative impairment losses that have been recognized. When the loss
relates to a disposal group it is allocated to assets within the disposal group with the exception of specific assets that are not within the scope
of IFRS 5. The impairment loss on a disposal group is first allocated to goodwill and then to the remaining assets and liabilities on a pro-rata
basis.
Assets in this category are not depreciated.
Gains or losses from the sale of these assets are recognized in the income statement.
Non-current assets held for sale, that the Bank and the Group subsequently decide either to use or to lease, are reclassified to the categories
of property, plant and equipment or investment property respectively. Also, assets cease to be classified as held for sale when the
classification criteria are no longer met. During their reclassification, they are measured at the lower of their recoverable amount and their
carrying amount before they were classified as held for sale, adjusted for any depreciation, amortization or revaluation that would have been
recognized had the assets not been classified as held for sale.
Non - current assets that the Bank and the Group intend to sell but which are not available for immediate sale or are not expected to be sold
within a year are included in Other Assets and are measured at the lower of cost (or carrying amount) and net realizable value in accordance
with IAS 2. Net realizable value is considered equal to fair value less cost to sell.
1.2.17 Defined contribution and defined benefit plans
The Bank and the Group have both defined benefit and defined contribution plans.
A defined contribution plan is where the Bank and the Group pay fixed contributions into a separate entity and they have no legal or
constructive obligation to pay further contributions if the fund does not have sufficient assets to pay all employees the benefits relating to
employee service in current or prior years. The contributions are recognized as employee benefit expense on an accrual basis. Prepaid
contributions are recognized as an asset to the extent that a cash refund or a reduction in the future payments is available.
A defined benefit plan is a pension plan that defines an amount of pension benefit that an employee will receive on retirement which is
dependent, among others, on years of service and salary on date of retirement and it is guaranteed by the entity of the Group.
The defined benefit obligation is calculated, separately for each plan, based on an actuarial valuation performed by independent actuaries
using the projected unit credit method.
The net liability recognized in the financial statements is the present value of the defined benefit obligation less the fair value of plan assets.
The present value of the defined benefit obligation is calculated based on the return of high quality corporate bonds with a corresponding
maturity to that of the obligation, or based on the return of government bonds in cases when there in no deep market in corporate bonds.
Interest on the net defined benefit liability (asset), which is recognised in profit or loss, is determined by multiplying the net defined benefit
liability (asset) by the discount rate used to discount post-employment benefit obligation, as determined at the start of the annual reporting
period, taking into account any changes in the net defined benefit liability (asset).
Service cost, which is also recognised in profit or loss, consists of:
• Current service cost;
• Past service cost, and
• Any gain or loss on settlement.
Past service cost, in particular, is directly recognized to profit or loss at the earliest of the following dates:
• When the plan amendment or curtailment occurs and
• When the Bank and the Group recognize related restructuring costs (according to IAS 37) or termination benefits.
Likewise, the Bank and the Group recognize a gain or loss on the settlement when the settlement occurs.
Remeasurements of the net defined benefit liability (asset) which comprise:
• actuarial gains and losses;
• return on plan assets, excluding amounts included in net interest on the net defined benefit liability (asset); and
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
277 | The amounts are presented in millions of Euro unless otherwise indicated.
• any change in the effect of the limitation in the asset recognition, excluding amounts included in net interest on the net
defined benefit liability (asset),
are recognized directly in other comprehensive income and are not reclassified in profit or loss in a subsequent period.
Finally, when the Bank and the Group decide to terminate the employment before retirement or the employee accepts the offer of benefits in
exchange for termination of employment, the liability and the relative expense for termination benefits are recognized at the earlier of the
following dates:
• when the Bank and the Group can no longer withdraw the offer of those benefits; and
• when the Bank and the Group recognize restructuring costs which involve the payment of termination benefits.
1.2.18 Variable remuneration
a. Variable remuneration paid in cash
The obligation to pay variable remuneration to employees in cash, either through payroll or under a profit-sharing scheme, is recognized in the
fiscal year for the performance of which the benefit is provided or during the servicing period in case the payment is deferred in order to be
paid gradually in future years, provided that the employee remains in service. The cost of the remuneration is recognized in Staff Costs.
b. Share options on Bank’s shares granted to employees
The granting of share options on Bank’s shares to the employees, their exact number, the price and the exercise date are decided by the Board
of Directors of the Bank in accordance with the Shareholders’ Meeting approvals and after taking into account the current legal framework.
The fair value calculated at grant date is recognized during the servicing period and recorded in staff costs with an increase of a reserve in
equity respectively. When there are no vesting conditions, it is considered that services have been received. On the contrary, when there are
service vesting conditions or non-market performance conditions the expense is recognized as the relative services are received. In case there
are conditions that are not vesting conditions, they are taken into account in share options valuation. When options are vested, the amount of
their fair value is transferred from the formed reserve to retained earnings.
c. Stock awards granted to employees
The granting of stock awards to the employees is decided by the Board of Directors of the Bank within the framework approved by the
Shareholders’ Meeting.
The fair value of the award, determined at the grant date, is recognized in staff costs (expense) with a corresponding increase in an equity
reserve, during the period when the relevant services are provided by the employees. When there are no vesting conditions, it is considered
that services have been received. On the contrary, when there are service vesting conditions or non- market performance conditions the
expense is recognized as the relative services are received. In case there are conditions that are not vesting conditions, they are taken into
account in the award’s valuation. At the time of registration of the shares in the portion of the beneficiaries, the fair value of the award
corresponding to those shares is transferred from the formed reserve to retained earnings.
1.2.19 Provisions and contingent liabilities
A provision is recognized if, as a result of a past event, the Bank and the Group have a present legal or constructive obligation that can be
estimated reliably, and it is probable that an outflow of economic benefits will be required to settle the obligation.
Provisions are, also, recognized in cases of restructuring plans with which management attempts either to change the subject of a corporate
activity or the manner in which it is conducted (e.g. close down business locations). The recognition of provision is accompanied with the
relevant, authorized by the Management, program and with the suitable actions of disclosure. A restructuring provision includes only the
direct expenditures arising from the restructuring, which are those that are both necessarily entailed by the restructurings and not associated
with the ongoing activity of the Bank and the Group.
The amount recognized as a provision shall be the best estimate of the expenditure required to settle the present obligation at the end of the
reporting period. Where the effect of the time value of money is material, the amount of the provision is equal to the present value of the
expenditures expected to settle the obligation.
Amounts paid for the settlement of an obligation are set against the original provisions for these obligations. Provisions are reviewed at the
end of each reporting period.
If it is no longer probable that an outflow of resources embodying economic benefits will be required to settle the obligation, the provision is
reversed. Additionally, provisions are not recognized for future operating losses.
Future events that may affect the amount required to settle the obligation, for which a provision has been recognized, are taken into account
when sufficient objective evidence exists that they will occur.
Reimbursements from third parties relating to a portion of or all of the estimated cash outflow are recognized as assets, only when it is
virtually certain that they will be received while their amount shall not exceed the amount of the provision. The expense recognized in profit
or loss relating to the provision is presented net of the amount of the reimbursement provided that both amounts are recognized within the
same fiscal year.
The Bank and the Group do not recognize in the statement of financial position contingent liabilities when it is not probable that an outflow of
resources will be required to settle the obligation or the amount of liability cannot be measured reliably or in cases where the obligation is
possible only to the extent that one or more uncertain future events occur, which are not only within the control of the Bank and the Group.
The Bank and the Group provide disclosures for contingent liabilities taking into consideration their materiality.
1.2.20 Securities sale and repurchase agreements and securities lending
The Bank and the Group enter into purchases of securities under agreements to resell at a certain date in the future at a fixed price (reverse
repos). Securities purchased subject to commitments to resell them at future dates are not recognized in the balance sheet.
The amounts paid, including interest accruals, are recognized in “Loans and advances to customers” or “Due from financial institutions”. The
difference between the purchase price and the resale price is recognized as interest income using effective interest method.
Similarly, securities that are sold under agreements to repurchase (repos) are not derecognized but they continue to be measured in
accordance with the accounting policy of the category that they have been classified.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
278 | The amounts are presented in millions of Euro unless otherwise indicated.
The proceeds from the sale of the securities are reported as “Due to customers” or “Due to banks”. The difference between the sales price and
the repurchase price is recognized as interest expense using effective interest method.
Securities borrowed by the Bank and the Group under securities lending agreements are not recognized in the balance sheet except when
they have been sold to third parties whereby the liability to deliver the security is recognized and measured at fair value.
1.2.21 Securitization
The Bank and the Group securitize financial assets by transferring these assets to special purpose entities, which in turn issue bonds.
In each securitization of financial assets the assessment of control of the special purpose entity is considered, based on the circumstances
mentioned in note 1.2.1, so as to examine whether it should be consolidated. In addition, the contractual terms and the economic substance
of transactions are considered, in order to decide whether the Bank and the Group should proceed with the derecognition of the securitised
financial assets, as referred in note 1.2.5.
1.2.22 Equity
Distinction between debt and equity
Financial instruments issued by Bank and other Group companies to obtain funding are classified as equity when, based on the substance of
the transaction, the Bank and the Group does not undertake a contractual obligation to deliver cash or another financial asset or to exchange
financial instruments under conditions that are potentially unfavorable to the issuer.
AT1 titles have been classified in this category since they are perpetual and there is no oblligation to pay either principal or interest.
In cases when the Bank and other Group companies are required to issue equity instruments in exchange for the funding obtained, the
number of equity instruments must be fixed and determined on the initial contract, in order for the obligation to be classified as equity.
Distributions to the holders of equity instruments are directly recognized by debiting the equity of the Bank and the Group.
Incremental costs of share capital increase
Incremental costs directly attributable to the issue of new shares are shown in equity as a deduction, net of tax, from retained earnings.
Share premium
Share premium includes the difference between the nominal value of the shares and the consideration received in the case of a share capital
increase.
It also includes the difference between the nominal value of the shares issued and their market value, in cases of exchanges of shares as
consideration for the acquisition of a business by the Bank and the Group.
Treasury shares
The cost of acquiring treasury shares is recognized as a reduction of equity. Subsequent gains or losses from the sale of treasury shares, after
deducting all direct costs and taxes, are recognized directly in retained earnings.
Dividends
Dividends are deducted from retained earnings or specific equity reserves and recorded as a liability in the period that the dividend is
approved by the Shareholders in General Meeting. Interim dividend is deducted from equity when it is assessed that the possibility of
revocation by the General Meeting is remote.
Distributions of non-cash assets to the Bank
Distributions of non-cash assets to the Bank are out of scope of IFRIC 17 since the Bank continues to control the assets distributed. Under the
accounting policy applied, those distributions are accounted for in the book value of the assets distributed.
1.2.23 Interest income and expense
Interest income and expense is recognized in the income statement for all interest bearing financial assets and liabilities.
Interest income and expense is recognised on an accrual basis and measured using the effective interest method, with the exception of
derivatives as described in detail in note 1.2.6. Especially for POCI assets, interest income is calculated using credit-adjusted effective interest
rate.
Effective interest rate is the rate that exactly discounts estimated future cash payments or receipts through the expected life of the financial
asset or financial liability to the gross carrying amount of a financial asset or to the amortised cost of a financial liability. When calculating the
effective interest rate, the Bank and the Group estimate the expected cash flows by considering all the contractual terms of the financial
instrument but does not consider the expected credit losses. The calculation includes all fees and points paid or received between parties to
the contract that are an integral part of the effective interest rate.
For financial assets, in particular, the following apply:
• For those financial assets classified within Stage 1 or Stage 2 for the purpose of expected credit losses measurement, interest
income is calculated by applying effective interest rate to the gross carrying amount of the asset.
• For those financial assets classified within Stage 3 for the purpose of expected credit losses measurement, interest income i s
calculated by applying the effective interest rate to the amortised cost of the asset.
• For purchased or originated credit impaired financial assets interest income is calculated by applying the credit-adjusted
effective interest rate to the amortised cost of the asset.
In case of negative interest rates, interest is presented within interest income for interest bearing financial liabilities and within interest
expense for interest bearing financial assets.
Borrowing costs that are directly attributable to assets that require a substantial period of time to get ready for their intended use or sale are
capitalized as part of the cost of the asset. Capitalisation ceases when substantially all the activities necessary to prepare the asset for its
intended use are complete.
1.2.24 Fee and commission income
Fees and commission income from contracts with customers are recognized based on the consideration specified in the contract when the
Bank and the Group satisfy the performance obligation by transferring the service to the customer. With the exception of specific portfolio
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
279 | The amounts are presented in millions of Euro unless otherwise indicated.
management fees which are calculated on the basis of the size and performance of the portfolio, the services provided have a fixed price.
Variable portfolio management fees are recognized when all related uncertainties are resolved.
For commissions on services provided over time, revenue is recognized as the service is being provided to the customer, such as commissions
to provide account management services, fees for administration of loans, fees for portfolio management and investment services advice as
well as management fees and fees for collection of receivables.
For transaction-based fees, the execution and completion of the transaction executed signals the point in time, in which the service is
transferred to the customer and the revenue is recognized, such as currency transactions, purchases / sales of securities as well as issue and
disposal of syndicated loans and bonds.
Transaction revenues relating to the recognition of a financial instrument not measured at fair value through profit or loss are capitalized and
amortised in the income statement using the effective interest method over the life of the financial instrument and included in interest
income.
1.2.25 Dividend Income
Dividend income from investments in shares is recognised in the income statement when the dividend distribution is approved by the
appropriate body of the company that the Bank and the Group have invested in. Interim dividend is recognized in the income statement when
approved by the appropriate body of the investee and revocation is considered remote.
1.2.26 Gains less losses on financial transactions
Gains less losses on financial transactions include:
• fair value changes of financial assets and liabilities,
• gains and losses arising from the modification of the contractual terms of financial assets measured at fair value through profit
or loss,
• gains and losses arising from the derecognition of financial assets and liabilities due to early repayment, including conversion
of loans into shares, disposal or significant modification of the contractual terms, except for gains and losses arising from the
derecognition of financial assets measured at amortised cost which are recognized in a separate line item of the Income
Statement and
• exchange differences arising from the translation of financial instruments denominated in foreign currencies.
1.2.27 Gains less losses on derecognition of financial assets measured at amortised cost
Gains less losses on derecognition of financial assets measured at amortised cost include:
• Gains and losses from the derecognition of financial assets measured at amortised cost
• The difference, at initial recognition, between the nominal and the fair value of a financial asset measured at amortised cost
that is the result of the derecognition of another financial asset due to significant modification of its contractual terms.
1.2.28 Impairment losses on fixed assets and equity investments
Impairment losses on fixed assets and equity investments include the impairment or write-off losses recognized on:
• property, plant and equipment,
• intangible assets,
• right of use assets classified within property, plant and equipment
• fixed assets classified within other assets as inventories,
• investments in subsidiaries, associates and joint ventures and
• non-financial assets or disposal groups classified as held for sale.
1.2.29 Gains/(losses) from the disposal of fixed assets and equity investments
The line item “Gains/(losses) from the disposal of fixed assets and equity investments” includes gains and losses from the disposal of:
• property, plant and equipment and investment property,
• intangible assets,
• fixed assets classified within other assets as inventories,
• investments in subsidiaries, associates and joint ventures and
• non-financial assets or disposal groups classified as held for sale.
1.2.30 Provisions (Income Statement)
The "Provisions" line of the Income Statement includes changes in provisions for the period (except those related to credit risk coverage),
including restructuring plan and operational risk provisions, as well as related expenses.
1.2.31 Transformation costs
The line item “Transformation costs” include the costs recognized on an accrued basis and related to those projects carried out by the Bank
and the Group that lead to significant changes in their operation (transformation costs) and which do not meet the criteria to be recognized as
a provision for a restructuring plan under IAS 37.
1.2.32 Expenses relating to credit risk management
The line item "Expenses relating to credit risk management" includes:
• servicing costs relating to overdue loans and
• the protection fee paid in the context of synthetic securitization transactions as well as the costs of said transactions.
1.2.33 Discontinued operations
A discontinued operation is a component of the Bank and the Group that either has been disposed of, or has been classified as held for sale
and represents:
• a separate-major line of business or geographical area of operations or
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
280 | The amounts are presented in millions of Euro unless otherwise indicated.
• part of a single co-ordinated plan to dispose of a separate major line of business or geographical area of operations or
• a subsidiary acquired exclusively with a view to resale.
When assessing whether a component meets the definition of a major line of business, its contribution to the Bank’s and Group's total assets
and profit or loss is taken into account, as well as the extent to which discrete information is provided to the Executive Committee for that
component.
The profit or loss after tax from discontinued operations and any losses recognized on the measurement to fair value less costs to sell of the
disposal group are presented in a separate line in the face of the income statement after net profit from continuing operations.
The comparative financial statements are restated only for the income statement and the cash flow statement.
1.2.34 Related parties definition
According to IAS 24, a related party is a person or entity that is related to the entity that is preparing its financial statements. For the Bank and
the Group, in particular, related parties are considered:
•
An entity that constitutes for the Bank and the Group:
•
a subsidiary (applies to the Bank)
•
a joint venture,
•
an associate
•
the Post-employment Benefit Plan, in this case the TEA Group Alpha Bank
•
A person or an entity (including its subsidiaries) that have control, or joint control, or significant influence over the Bank and the Group.
•
A person and his close family members, if that person is a member of the key management personnel.
The Bank and the Group consider as key management personnel all the members of the Bank’s Board of Directors and of the Bank’s Executive
Committee while as their close family members they consider their children and spouses or domestic partners and their dependants and the
dependants of their spouses or domestic partners.
Related parties are also considered the entities controlled or jointly controlled by the above mentioned persons and more specifically the
entities in which the above persons participate with more than 20%.
1.2.35 Earnings per share
Basic earnings per share are calculated by dividing profit or loss attributable to ordinary equity holders of the Bank by the weighted average
number of ordinary shares outstanding during the period.
Diluted earnings per share are calculated using the same method as the calculation of basic earnings per share, however, both the nominator
and the denominator are adjusted for the effects of all dilutive potential ordinary shares.
1.2.36 Comparatives
To the extent considered necessary the comparatives have been adjusted to facilitate changes in presentation of the current year amounts.
1.3
Significant accounting judgments and key sources of estimation uncertainty
Significant accounting judgments
The Bank and the Group, in the context of applying accounting policies, make judgments and assessments which have a significant impact on
the amounts recognized in the financial statements. Those judgements relate to the following:
Business Model Assessment (note 1.2.5)
The Bank and the Group, on the initial recognition of a debt financial asset, exercise judgment in order to determine the business model in
which it would be classified, taking into account the way of evaluating its performance, the risks associated with it as well as the expected
frequency and value of sales. Also, on a quarterly basis, they exercise judgment in order to reassess the business models, taking into account
the sales that have been made as well as any changes in the management operating model of the assets. Based on this assessment, they
decide whether they should define new business models or in rare circumstances proceed with the reclassification of financial assets to
another business model.
Assessment of whether contractual cash flows of a debt financial instrument represent solely payments of principal and interest on the
principal amount outstanding (SPPI) (note 1.2.5)
The Bank and the Group, at initial recognition of a debt financial asset, assess whether cash flows are solely payments of principal and interest
on the principal amount outstanding. The assessment requires judgement mainly on:
•
Whether contractual terms that affect the performance of the instrument relate solely to credit risk, other basic lending risks and profit
margin.
•
For loans in special purpose entities, whether there is a non-recourse feature. The assessment is based on specific index thresholds as
well as on the evaluation of the adequacy of equity and of the collaterals that are not related to the asset being financed.
•
Whether in case of prepayment or extension the compensation received is considered fair.
•
Whether in loans with ESG (Environmental, Social, Governance) criteria, the change in credit spread based on the satisfaction of those
ESG criteria is borrower specific and whether it relates to the change in credit risk and/or change in profit margin.
The application of different judgments could affect the amount of financial assets measured at fair value through profit or loss.
Significant judgements relating to the selection of methodologies and models for expected credit losses calculation (note 49.1)
The Bank and the Group, in the context of the application of their accounting policies for the measurement of the expected credit losses
makes judgments in order to identify:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
281 | The amounts are presented in millions of Euro unless otherwise indicated.
•
the criteria that indicate a significant increase in credit risk,
•
the selection of appropriate methodologies for expected credit loss estimation (expected credit loss calculation on an individual or on a
collective basis),
•
the selection and development of appropriate models used to calculate the exposure at default (EAD) by financial instrument category,
the probability of default (PD), the estimated expected credit loss at the time of default (LGD) as well as the selection of appropriate
parameters and economic forecasts used in them,
•
the selection of appropriate macroeconomic parameters affecting the expected credit risk loss,
•
the selection of the parameters used in the models to determine the expected life and the date of initial recognition of revolving
exposures,
•
the grouping of financial assets based on similar credit risk characteristics,
Applying different judgments could significantly affect the financial instruments classified in stage 2 and/ or significantly differentiate
expected credit loss calculations.
Income Tax (notes 18, 45)
The recognition of assets and liabilities for current and deferred tax is affected, inter alia, by the interpretation of the applicable tax
legislation, the practical implementation of the relevant legislation and the settlement of disputes that might exist with tax authorities. When
assessing the tax treatment of all significant transactions, the Bank and the Group take into account and evaluate all available data (Circulars
of the Ministry of Finance, case law, administrative practices, etc.) and / or opinions received from internal and external legal advisers. Future
tax audits and changes in tax legislation may result in the adjustment of the amount of assets and liabilities for current and deferred tax and
in tax payments other than those recognized in the financial statements of the Bank and the Group. In addition, from fiscal year 2024
onwards, the Bank and the Group are assessing the application of the OECD Pillar II rules, which introduce a minimum global tax rate of 15%
at the jurisdictional level. Given that the legislative and interpretative framework of Pillar II continues to evolve, any future clarifications or
interpretative guidance may affect the estimation of the supplementary tax and lead to an adjustment of the relevant amount recognized in
the financial statements.
Classification of non-current assets as held for sale (note 54)
The Bank and the Group classify non-current assets or disposal groups that are expected to be recovered principally through a sale
transaction, along with the related liabilities, as held-for-sale when the asset is available for immediate sale in its present condition and its
sale is highly probable to be completed within one year. The assessment of whether the above criteria are met requires judgment mainly as to
whether the sale is likely to be completed within one year from the classification of the non-current assets or disposal group as held for sale.
In the context of this assessment in which any previous experience from corresponding transactions is also considered, the Bank and the
Group take into account elements such as any requirement for approvals (both regulatory and those given by the General Meeting and the
Committees of the Bank and the Group), the existence of offers (binding or not) and the status of the signed agreements with investors as
well as of any conditions included in them. In addition, current economic conditions are taken into account which may affect the time of
completion of sales transactions. In the event that the sale is not completed within one year from the classification of the non-current assets
or disposal group as held for sale, judgment is exercised in order to assess whether the cause of the delay is outside the Bank’s and Group's
control as well as whether the Bank and the Group continue to be committed to the program for their disposal and the sale is considered
likely to occur.
Assessment of the existence of control, joint control or significant influence over companies (note 46)
The Bank and the Group exercise judgment in order to determine whether they have control, joint control or significant influence over
companies either through its participation in their share capital or through other agreements.
The main cases in which judgments were applied concern:
•
Special purpose entities established in the context of loan securitization transactions or synthetic securitization transactions and in which
the Bank and the Group assess the existence of control taking into account the ability to make decisions over their main activities, as well
as the degree of their exposure to the variability of their returns.
•
In associated companies in which the Bank and the Group hold less than 20% of the share capital, it is assessed whether significant
influence exists through the Bank’s and Group's participation in their Board of Directors and consequently through their par ticipation in
the policy-making process, as well as whether, based on the shareholders' agreement, there is the possibility of exercising a veto on
significant decisions.
Pending legal cases (note 45)
The Bank and the Group, in the context of the preparation of their financial statements, exercise judgment in order to assess the possibility of
a negative outcome of its pending legal cases. In this judgement, the substantial circumstances of each case, the legislation and the regulatory
framework, the relevant jurisprudence as well as the judicial course of the case are taken into account. As a result of this assessment, when
the probability of a negative outcome exceeds 50% and the determination of the financial outflow that will be required is considered reliable,
the Bank and the Group proceed with the recognition of a provision in the financial statements.
Key sources of estimation uncertainty
Key sources of estimation uncertainty used by the Bank and the Group in the context of applying their accounting principles and relating to
the carrying amount of assets and liabilities at the end of the reporting period are presented below. Final amounts in the next periods may be
significantly different from those recognised in these financial statements.
Fair value of assets and liabilities (notes 27, 31, 49.4, 54)
For assets and liabilities traded in active markets, the determination of their fair value is based on quoted, market prices. In all other cases the
determination of fair value is based on valuation techniques that use observable market data to the greatest extent possible. In cases where
there is no observable market data, the fair value is determined using data that are based on internal estimates and assumptions i.e.
determination of expected cash flows, discount rates, prepayment probabilities or counterparty default. Fair value measurement of
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
282 | The amounts are presented in millions of Euro unless otherwise indicated.
receivables arising from sale transactions is based on significant unobservable inputs such as the expected cash flows from the management
of the underlying receivables portfolio and the business plan of the companies sold.
Estimates included in the calculation of expected credit losses of financial instruments (notes 12, 49.1)
The measurement of expected credit losses requires the use of complex models and significant estimates of future economic conditions and
credit behavior, taking into account the events that have occurred until reporting date. The significant estimates relate to:
•
the determination of the alternative macroeconomic scenarios and the cumulative probabilities associated with these scenarios,
•
the probability of default during a specific time period based on historical data, assumptions and estimates for the future,
•
the determination of the expected cash flows and the flows from the liquidation of collaterals for financial instruments,
•
the determination of the adjustments to the models for the calculation of the parameters of expected credit loss when credit risk models
cannot incorporate certain risk factors in periods of uncertainty , the expected impact from management actions as well as the imapct
from the legislation for the haircut on the CHF loans, and
•
the integration of loan portfolio sales scenarios taking into account on the one hand any factors that may hinder the realization of the
sale and on the other hand the level of satisfaction of the conditions for the completion of the sale.
Impairment losses on investments in associates and joint ventures and on non - financial assets (notes 26, 29)
The Bank and the Group, at each reporting date, assess for impairment right-of-use assets measured at cost, goodwill and other intangible
assets, as well as their investments in subsidiaries, associates and joint ventures and at least on an annual basis property, plant and
equipment. Management estimates the recoverable amount of the assets, i.e. the higher between the fair value less costs to sell and value in
use by performing an impairment exercise, which includes inputs and assumptions that are inherently uncertain. In cases where the sale of
such items is imminent, the fair value derives from the estimated price of the transaction considering any other element that could impact the
recoverable amount upon the completion of the transaction.
Employee defined benefit obligations (note 36)
Defined benefit obligations are estimated based on actuarial valuations, which are mainly conducted on an annual basis, that incorporate
assumptions regarding discount rates, future changes in salaries and pensions, as well as the return on any plan assets. Any change in these
assumptions will affect the amount of obligations recognized.
Provisions (note 38)
The amounts recognized by the Bank and the Group in their financial statements as provisions are derived from the best estimate of the
possible outflow required to settle the present obligation. This estimate is determined by Management after taking into account factors such
as experience from relevant transactions, the degree of complexity of each case, the actions taken to settle it as well as expert reports when
considered necessary. In case the amount recognized as a provision is affected by a variety of factors, its calculation is based on the weighting
of all possible results. At each reporting date, provisions are revised to reflect current best estimates of the obligation.
Recoverability of deferred tax assets (notes 18 and 30)
The Bank and the Group recognize deferred tax assets to the extent that it is probable that they will have sufficient future taxable profit
available, against which, deductible temporary differences and tax losses carried forward can be utilized. The estimation of future taxable
profits is based on forecasts for the development of the accounting results, as these are formulated in accordance with the business plan of
the Group. In particular, the business plan includes actions aimed at enhancing profitability through:
•
the significant improvement in profitability and capital reallocation due to the reduction in non-performing exposures,
•
the improvement in operational efficiency and reduction of operating costs,
•
interest income increase through asset development, with a particular focus on business loans and
•
the increase in income from fees and commissions
The main categories of deferred tax assets which have been recognized by the Bank and the Group relate to tax losses carried forward, losses
from the Greek government bonds exchange program (PSI) and the December 2012 Greek government bond buyback program and to
deductible temporary differences arising from loans’ impairment.
Deferred tax assets for tax losses carryforward originate mostly from the Bank and relate to tax losses carryforward transferred from Alpha
Services and Holdings in the context of its absorption by the Bank in June of the current year. The tax losses may be offset against taxable
profits within five years from their formation. The Bank and the Group recognized deferred tax assets for that part of the tax losses carried
forward that, according to the estimate of the Bank's future taxable profits, for the following fiscal years until the expiration of the right to set
off tax losses, is recoverable even after deducting the deductible temporary differences expected to arise in those fiscal years.
Deferred tax assets associated with tax losses incurred by the PSI and the participation of the Bank in the December 2012 Greek government
bond buyback program were recognized as a “debit difference” according to Law 4046/14.2.2012, Law 4110/23.1.2013. Acc ording to Law
4110/23.1.2013 the “debit difference” is deductible for tax purposes, gradually in equal installments, within 30 years, while its remaining
amount is estimated that can be be offset against future taxable profits.
Regarding the temporary differences arising from loans’ impairment, there are no time constraints concerning their recovery, as is the case
for the other deferred tax assets categories. The Bank and the Group assessed their recoverability based on estimates for future taxable
profits, as these are forecasted on the basis of the aforementioned business plan. In order to assess deferred tax asset recoverability, the
Group’s business plan was extended for a limited number of years during which estimates were made regarding the production of new loans
and the evolution of the operating results.
In addition, tax losses resulting from the write-down of debts and the sale of loans, as specifically mentioned in note 18, are recognized as a
debit difference. It is noted that the debit difference is recognized gradually and equally over a period of 20 years, a fact which in accordance
with Bank’s and Group’s estimations provides sufficient time for offsetting against taxable p rofits. In addition, in accordance with the
amendment of article 27 of L. 4172/2013, the amount of the annual deduction of the debit difference due to credit risk that is not offset
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
283 | The amounts are presented in millions of Euro unless otherwise indicated.
against the taxable profits of the year is transferred in order to be deducted in subsequent tax years within the twenty-year period. If at the
end of the twenty-year depreciation period there are balances that have not been offset, they constitute a loss that can be carried forward in
order to be offset with future taxable profits within five years.
The Bank and the Group, based on the above, estimate that the total deferred tax assets recognized and that relate to temporary differences
and to tax losses carried forward is recoverable.
In addition, and regardless of the assessment of the recoverability of deferred tax assets that is carried out based on what is mentioned
above, Law 4303/2014 provides that in case that the after tax accounting result for the period is a loss, deferred tax assets arising from the PSI
debit difference and from the accumulated provisions and other general losses due to credit risk are eligible to be converted into a final and
settled claim against the Greek State, as described in detail in note 18.
The main uncertainties concerning the estimations for the recoverability of the deferred tax assets relate to the achievement of the goals set
in the Group’s business plan, which is affected by the general macroeconomic environment in Greece and internatio nally. These goals mainly
concern the reduction of non-performing exposures, the production of new loans as well as the evolution of operating results. At each
balance sheet date, the Bank and the Group reassess their estimation regarding the recoverability of deferred tax assets in conjunction with
the development of the factors that affect it.
The estimates and judgments applied by the Bank and the Group in making decisions and in preparing the financial statements are based on
historical information and assumptions which at present are considered appropriate. The estimates and judgments are reviewed on an
ongoing basis in order to take into account current conditions, and the effect of any changes is recognized in the period in which the estimates
are revised.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
284 | The amounts are presented in millions of Euro unless otherwise indicated.
REVERSE
MERGER
On 27.6.2025, reverse merger which is the corporate transaction through which Alpha Services and Holdings was absorbed by the Bank was
implemented, and the Bank became the ultimate parent company of the Group. The transaction was implemented following the receipt of
the required approvals. More specifically:
On 30.5.2025 the ECB notified Alpha Services and Holdings and Alpha Bank S.A. for its decision to:
a) authorise the merger by absorption of Alpha Services and Holdings. into Alpha Bank S.A. (the “Bank” or “Alpha Bank”) and
b) approve the amendments to the statutes of the Supervised Entity in order to reflect the merger above.
On 12.6.2025, the Bank’s Extraordinary Shareholder General Meeting (“EGM”), approved the Reverse Merger while on 23.6.2025 the
Extraordinary General Meeting of Alpha Services and Holdings S.A. approved:
a) the merger by absorption between the Bank, acting as the absorbing entity, and Alpha Services and Holdings
b) the Draft Merger Agreement and the Merger Documentation.
The above corporate transaction meets the criteria to be classified as a business combination, however, as it is an intra-group transaction it
does not fall within the scope of IFRS 3. Additionally, taking into account that it is a transaction without substance for the investors (as,
among others, there are no third-party rights that are affected, it is not carried out in terms of fair value, and no cash consideration is
provided) and that, in relation to previous intra-group business combinations that have taken place in the Group, it has the particularity that it
is a transaction in which the subsidiary absorbs its parent company with the aim of restoring the original structure before the hive down that
took place in 2021, it is considered more appropriate to apply the treatment applied to an intra-group reorganization.
According to this treatment, the assets and liabilities of the acquired entity are not measured at fair value and no goodwill arises.
More specifically:
a. Separate Financial Statements
In the Bank's separate financial statements, the absorption transaction was presented as follows:
• The Bank recognized the carrying amounts of the assets and liabilities of Alpha Services and Holdings as they were reflected in the
books of the Holding company at the time of absorption.
• Alpha Services and Holdings' investment in the Bank was eliminated with its share capital and other elements of its equity. The
difference arising from the above elimination was recognized in a special equity reserve.
• The shares of Alpha Services and Holdings were cancelled while the Bank issued new shares.
• Upon cancellation of Alpha Services and Holdings treasury shares acquired in the context of the share buyback program, the
amount exceeding their nominal value, which was recognized as a deduction from the share capital, was recognized as a deduction
from retained earnings.
• Intercompany assets and liabilities were eliminated and any difference arose upon elimination was recognized directly in the special
reserve of equity, which includes the differences from the corporate transformation.
In line with the policy applied during the hive down of the banking sector in 2021, the absorption was not recognized retrospectively, which
means that comparative information was not restated.
b. Consolidated Financial Statements
As an intra-group transaction, the absorption transaction did not affect the consolidated financial statements, with the exception of the
cancellation of Alpha Services and Holdings' treasury shares, which was recognized as a reduction in the share capital, by the amount
corresponding to the nominal value of the shares cancelled, and as a reduction in retained earnings for the remaining amount. Additionally,
the structure of the Group's equity was affected by the structure of the Bank's equity due to the corporate transformation, as the Bank is the
parent company of the Group.
It is also noted that based on the substance of the transaction, the Group of Alpha Bank represents the continuation of the Alpha Services and
Holdings Group. Therefore, the comparative figures of the consolidated financial statements are those of the Alpha Services and Holdings
Group.
The table below presents the assets, liabilities and equity reserves transferred to the Bank, at the reverse merge date, as well as the
adjustments in the context of the application of the accounting treatment.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
285 | ANNUAL FINANCIAL REPORT
Alpha Services
and Holdings
S.A. 27.6.2025
(a)
Alpha
Bank S.A
27.6.2025
(b)
Alpha Bank
S.A. Total
27.6.2025
(c)=(a)+(b)
Cancelation of Alpha
Services and Holdings
S.A. participation due to
the merger (d)
Cancellation
of Treasury
Shares (e)
Other
Merger
Eliminations
(f)
Alpha Bank
S.A. Total
27.6.2025 (g)
=
(c)+(d)+(e)+(f)
ASSETS
Cash and balances with central banks
1,422
1,422
1,422
Due from financial institutions
11
3,368
3,378
(11)
3,368
Trading securities
49
49
49
Derivative financial assets
711
711
(94)
618
Loans and advances to customers
37,154
37,154
(20)
37,133
Investment securities
- Measured at fair value through other
comprehensive income
1,052
1,052
1,052
- Measured at amortized cost
1,025
15,418
16,444
(1,025)
15,418
- Measured at fair value through profit or loss
226
226
226
Investment in subsidiaries, associates and
joint ventures
6,954
2,848
9,802
(6,938)
2,864
Investment property
64
64
64
Property, plant and equipment
513
513
513
Goodwill and other intangible assets
413
413
413
Deferred tax assets
4,679
4,679
23
4,703
Other assets
31
737
767
(11)
756
8,020
68,654
76,674
(6,938)
-
(1,137)
68,599
Assets classified as held for sale
16
628
645
645
Total Assets
8,036
69,282
77,319
(6,938)
-
(1,137)
69,244
LIABILITIES
Due to banks
20
7,992
8,012
(20)
7,992
Derivative financial liabilities
740
740
740
Due to customers
48,124
48,124
(11)
48,114
Debt securities in issue and other borrowed
funds
1,017
3,088
4,105
(1,032)
3,073
Liabilities for current income tax
78
78
78
Deferred tax liabilities
2
2
(2)
-
Employee defined benefit obligations
22
22
22
Other liabilities
12
852
863
(11)
852
Provisions
113
113
113
Total Liabilities
1,051
61,009
62,060
-
-
(1,076)
60,984
EQUITY
Equity attributable to holders of the Bank
Share capital
683
4,678
5,361
(4,678)
(11)
671
Share premium
4,784
1,125
5,909
5,909
Merge Reserve
(1,507)
(70)
(1,577)
Special Reserve from Share Capital Decrease
246
246
246
Other Equity Ιnstruments
700
700
1,400
(700)
700
Reserves
796
(35)
761
(34)
9
735
Retained earnings
84
1,559
1,643
(18)
(50)
1,575
Less: Treasury shares
(61)
(61)
61
-
Total Equity
6,986
8,273
15,259
(6,938)
-
(61)
8,260
Total Liabilities and Equity
8,036
69,282
77,319
(6,938)
-
(1,137)
69,244
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
286 | ANNUAL FINANCIAL REPORT
2.
Restatement of financial statements
a. In the context of improving the presentation of the Balance Sheet, the Bank decided in the second quarter of 2025, to present
Collateralised Loans Obligations (CLO) as “Loans and advances to Customers” instead of “Investment Securities measured at Amortised
Cost” to better reflect the substance of the Debt Securities.
b. In the context of the decision taken to increase the size of investment properties portfolio at Group level and implement a more dynamic
management of investment properties and investments in entities engaged in property management, resulting in a corresponding
increase in the income arising from this portfolio it was decided to change the Group's accounting policy governing investment properties
in order to better align it with the new business model.
The change, which is applied from 31.12.2025 with a restatement of the comparative period, consists of both the change in the
measurement method from the cost to the fair value model and the way in which the results arising from the management of investment
properties are presented in the Income Statement.
Specifically, with regard to the presentation of the Income Statement, the results related to the management of investment properties,
namely rental income, income from services provided to the tenants of investment properties, expenses such as maintenance, cleaning,
management, insurance, utilities and fees as well as the change in the fair value of the said properties are now presented separately and
their sum constitutes a new subset called "Net income from investment property management".
The restatements of the Balance Sheet, the Income Statement, the Statement of Comprehensive Income and the Statement of Cash Flows for
the comparative period for the Group and Bank are presented in the following tables. All subsequent notes have been restated accordingly.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
287 | ANNUAL FINANCIAL REPORT
Balance Sheet as at 31.12.2023
Group Bank 31.12.2023 31.12.2023 31.12.2023 Investment 31.12.2023 Investment as CLO as CLO as Properties as restated Properties pub lished published restated ASSETS Cash and balanc es with ce ntral banks 4,219 4,219 2,910 2,910 Due from fi nancial institutio ns 1,572 1,572 1,764 1,764 Trading securi ties 33 33 9 9 Derivat ive financial ass ets 727 727 789 789 Loans and adv ances to cust omers 36,161 465 36,626 34,625 465 35,090 Investment s ecurities - Measured at f air value t hrough other comprehe nsive income 1,369 1,369 1,259 1,259 - Measured at a mortized cost 14,490 (465) 14,025 14,008 (465) 13,543 - Measured at f air value t hrough profit or l oss 159 159 360 360 Investments in subsidiari es 2,439 2,439 Investments in associates and joint ventures 100 4 104 77 77 Investment p roperty 301 30 331 65 4 69 Property, plant and equipment 501 501 470 470 Goodwill and other intangibl e assets 467 467 450 4 50 Deferre d tax assets 4,978 4,978 4,940 (1) 4,9 39 Other ass ets 945 945 806 806 66,022 - 34 66,056 64,971 - 3 64,974 Assets cl assified as held f or sale 6,399 6,399 568 568 Total Assets 72,421 - 34 72,455 65,539 - 3 65,542 LIABILITIES Due to ban ks 6,921 6,921 7,201 7,201 Derivat ive financial liabi lities 934 934 935 935 Due to c ustomers 48,449 48,449 46,126 46,126 Debt sec urities in issue and o ther borrowed f unds 2,920 2,920 2,952 2,952 Liabilitie s for current inco me tax 4 4 18 18 Deferre d tax liabilities 25 6 31 Employee def ined benefit obl igations 24 24 23 23 Other liabi lities 919 919 808 808 Provisions 120 120 101 101 60,316 - 6 60,322 58,164 - - 58,164 Liabilitie s related to assets classified as held fo r sale 4,782 4,782 Total Liabi lities 65,098 - 6 65,104 58,164 - - 58,164 EQUITY Equity attributabl e to holders of the Bank Share capit al 682 682 4,678 4,678 Share premium 4,783 4,783 1,125 1,125 Special R eserve from Share Capit al Decrease 246 246 Other Equi ty Instruments 400 400 400 400 Reserve s (111) (111) (145) (145) Amounts dire ctly recognized in equity and are a ssociated wit h (64) (64) 3 3 assets cl assified as held for sale Retaine d earnings 1,626 28 1,654 1,068 3 1,071 Less: Treasur y shares (11) (11) 7,305 - 28 7,333 7,375 3 7,378 Non-controlli ng interests 18 18 Total Equity 7,323 - 28 7,351 7,375 3 7,378 Total Liabi lities and Equity 72,421 - 34 72,455 65,539 3 65,542
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
288 | ANNUAL FINANCIAL REPORT
Balance Sheet as at 31.12.2024
Group Bank 31.12.2024 31.12.2024 31.12.2024 Investment 31.12.2024 Investment as CLO as CLO as Properties as restated Properties published published restated ASSETS Cash and balanc es with ce ntral banks 2,998 2,998 1,756 1,756 Due from fi nancial institutio ns 2,296 2,296 2,241 2,241 Trading securi ties 54 54 30 30 Derivat ive financial ass ets 628 628 740 740 Loans and adv ances to cust omers 39,050 775 39,825 37,10 6 775 37,88 1 Investment s ecurities - Measured at f air value t hrough other comprehe nsive income 1,009 1,009 935 935 - Measured at a mortized cost 16,420 (775) 15,645 15,484 (775) 14,709 - Measured at f air value t hrough profit or l oss 167 167 158 158 Investments in subsidiari es 2,632 2,632 Investments in associates and joint ventures 570 1 57 1 129 129 Investment p roperty 290 33 323 66 8 74 Property, plant and equipment 534 534 500 500 Goodwill and other intangibl e assets 438 438 419 419 Deferre d tax assets 4,815 (8) 4,8 07 4,770 (2) 4,76 8 Other ass ets 808 808 64 8 64 8 70,077 - 26 70,1 03 67,614 - 6 67,620 Assets cl assified as held f or sale 1,999 1,999 641 641 Total Assets 72,076 - 26 72,1 02 68,255 - 6 68,261 LIABILITIES Due to ban ks 6,533 6,533 6,744 6,744 Derivat ive financial liabi lities 793 793 800 800 Due to c ustomers 51,032 51,032 48,321 48,321 Debt sec urities in issue and o ther borrowed f unds 3,208 3,208 3,255 3,255 Liabilitie s for current inco me tax 69 69 65 65 Deferre d tax liabilities 20 (2) 18 Employee def ined benefit obl igations 23 23 22 22 Other liabi lities 894 894 760 760 Provisions 162 162 119 119 62,734 - (2) 62,7 32 60,086 - - 60,086 Liabilitie s related to assets classified as held fo r sale 1,153 1,153 Total Liabi lities 63,887 - (2) 63,885 60,086 - - 60,086 EQUITY Equity attributabl e to holders of the Bank Share capit al 682 682 4,678 4,678 Share premium 4,784 4,784 1,125 1,125 Special R eserve from Share Capit al Decrease 246 246 Other Equi ty Instruments 700 700 700 700 Reserve s (93) (93) (89) (89) Amounts dire ctly recognized in equity and are a ssociated wit h (14) (14) assets cl assified as held for sale Retaine d earnings 2,175 28 2,203 1,509 6 1,515 Less: Treasur y shares (61) (61) 8,173 - 28 8,201 8,169 - 6 8,175 Non-controlli ng interests 16 16 Total Equity 8,189 - 28 8,217 8,169 - 6 8,175 Total Liabi lities and Equity 72,076 - 26 72,102 68,255 - 6 68,261
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
289 | ANNUAL FINANCIAL REPORT
Income Statement 1.1-31.12.2024
Group Bank From 1 January to 31.12.2024 31.12.2024 Investment 31.12.2024 Investment 31.12.2024 as as Properties as restated Properties as restated published published Interest and similar inco me 4,408 4,408 4,284 4,284 Interest expense and simil ar charges (2,763) (2,763) (2,779) (2,779) Net interest incom e 1,645 - 1,645 1,505 - 1,505 - of which: net interest inco me based on th e effective int erest rate 1,730 1,730 1,591 1,591 Fee and commissi on income 480 480 421 421 Commission expense (60) (60) (57) (57) Net fee and co mmission income 420 - 420 364 - 364 Dividend income 6 6 11 11 Gains less losses on derec ognition of financial assets measured at amortised 31 31 31 31 cost Gains less losses on financial transactions 80 80 120 120 Other i ncome 40 (8) 32 29 (2) 27 Total income fro m banking operati ons 2,222 (8) 2,214 2,060 (2) 2,058 Income from l easing of inv estment properti es 7 7 2 2 Income from se rvices relat ing to investment p roperties 2 2 Expenses rel ated to investment propertie s management (8) (8) (2) (2) Gain or l osses from valuati on of investment pr operties (4) (4) 2 2 Net income fro m investment prope rty manage ment - (3) (3) - 2 2 Total income fro m Banking and i nvestment property management 2,222 (11) 2,211 2,060 - 2,060 Staff costs (370) (370) (304) (304) General a dministrative expenses (316) 8 (308) (254) 2 (252) Depreci ation and amorti zation (180) 6 (174) (162) 2 (160) Total expenses (866) 14 (852) (720) 4 (716) Impairment loss es and prov isions to cover cr edit risk (360) (360) (332) (332) Expenses rel ated to credit risk management (93) (93) (92) (92) Impairment loss es of fixed as sets and parti cipations (15) 2 (13) 33 33 Gains/(Loss es) on disposal of fixed assets and pa rticipations 27 27 3 3 Provisions (85) (85) (82) (82) Transformati on costs (14) (14) (12) (12) Share of pr ofit/(loss) of asso ciates and joint v entures (3) (3) Profit/(loss) befo re income tax 816 2 818 858 4 862 Income tax (219) (2) (221) (211) (1) (212) Net profit/(loss) fro m continuing operations for th e period after inco me tax 597 - 597 647 3 650 Net pro fit/(loss) for the period after income tax f rom discontinu ed operations 57 57 Net profit/(loss) for t he period 654 - 654 647 3 650 Net profit/(loss) at tributable to: Equity holders of th e Bank 654 - 654 647 3 650 - from continu ing operations 597 597 647 3 650 - from discont inued operat ions 57 57 Non-controlli ng interests - from continu ing operations Earnings/(losse s) per share Basic (€ p er share) 0.2619 (0.0028) 0.2591 0.0115 0.0001 0.0116 Basic (€ p er share) from cont inuing operati ons 0.2374 (0.0026) 0.2348 0.0115 0.0001 0.0116 Basic (€ p er share) from disc ontinued operati ons 0.0245 (0.0002) 0.0243 Diluted (€ per share) 0.2616 (0.0028) 0.2588 0.0115 0.0001 0.0116 Diluted (€ per share) fro m continuing operatio ns 0.2371 (0.0026) 0.2345 0.0115 0.0001 0.0116 Diluted (€ per share) fro m discontinued oper ations 0.0245 (0.0003) 0.0242
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
290 | ANNUAL FINANCIAL REPORT
Statement of Comprehensive Income 1.1 - 31.12.2024
Group Bank From 1 January 31.12.2024 31.12.2024 as Investment 31.12.2024 Investment 31.12.2024 as published Properties as restated Properties as restated published Net profit/(loss), after income ta x, recognized in t he Income Stat ement 654 - 654 647 3 650 Other comprehensi ve income Items that may b e reclassified sub sequently to the Inco me Statement Net change i n cash flow hedge reserve 31 31 31 31 Foreign curr ency translatio n net of investment h edges of forei gn operations 2 2 Income tax (7) (7) (9) (9) Items that may b e reclassified sub sequently to the Inco me Statement fr om 26 - 26 22 - 22 continuing operati ons Items that may b e reclassified sub sequently to the Inco me Statement fr om 53 - 53 - - - discontinued operati ons Items that will not be reclassified t o the Income Statement Gains/(lo sses) from inve stments in equity s ecurities measure d at fair value (13) (13) (14) (14) through ot her comprehensi ve income Income tax 4 4 4 4 Items that will not be reclassified t o the Income Statement from c ontinuing (9) - (9) (10) - (10) operations Other comprehensi ve income, aft er income tax, for t he period 70 70 12 12 Total comprehensi ve income for the year 724 - 724 659 3 662 Total comprehensi ve income for the year attributabl e to: Equity holders of th e Bank 724 724 659 3 662 - from continu ing operations 614 614 659 3 662 - from discont inued operat ions 110 110 Non controlling i nterests
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
291 | ANNUAL FINANCIAL REPORT
Group Statement of Cashflows
From 1 January to 31.12.2024 Investment 31.12.2024 CLO as published Properties as restated Cash flows fro m continuing operat ing activities Profit/(l oss) before income tax from continuing oper ations 816 2 818 Adjustments of pr ofit/(loss) befor e income tax for: Depreci ation, impairment, wri te-offs and net r esult from disposa l of property, p lant and equipment 73 (9) 64 Amortization, i mpairment, write-of fs of int angible assets 134 134 Impairment loss es, provisi ons to cover credit r isk and related expenses 504 504 Gains less losses on derec ognition of financial assets measured at amortised cost (31) (31) Fair value (gains)/losses on financial assets measured at f air value through prof it or loss (61) (61) Gain or l osses from valuati on of investment pr operties 4 4 (Gains)/lo sses from investi ng activities (552) 35 (517) (Gains)/lo sses from financing ac tivities 257 257 Share of (profit)/loss of asso ciates and joint ve ntures 3 3 1,140 35 - 1,175 Net (increase)/de crease in assets relating t o continuing operati ng activities: Due from fi nancial institutio ns (484) (484) Trading securi ties and deri vative financial i nstruments 48 48 Loans and adv ances to cust omers (3,213) (310) (3,523) Other ass ets (44) (44) Net increase/(dec rease) in liabi lities relati ng to continuing op erating activit ies: Due to ban ks (388) (388) Due to c ustomers 2,583 2,583 Other liabi lities (261) (261) Net cash flows fro m continuing op erating activit ies before income tax (619) (275) - (894) Income tax pai d (15) (15) Net cash flows fro m continuing op erating activit ies (634) (275) - (909) Net cash flows fro m discontinued op erating activiti es (176) - - (176) Cash flows fro m continuing investin g acti vities Proceeds f rom disposals o f subsidiaries 300 300 Dividend Received 6 6 Investments in associates and joint ventures (56) (56) Acquisiti ons of investment property, proper ty, plant and equ ipment and intangible a ssets (153) (153) Disposals of investment pro perty, property, plant and equipment and intangible asse ts 15 15 Interest received from inv estment securities 363 (32) 331 Purchases of Greek Government Treasury B ills (1,665) (1,665) Proceeds f rom disposal and r edemption of G reek Government Treasury Bills 2,062 2,062 Purchases of investment se curities (excluding Gr eek Government Treasury Bil ls) (4,214) 589 (3,625) Disposals/M aturities of invest ment securities (excluding Greek Go vernment Treasury Bills) 2,440 (282) 2,158 Net cash flows fro m continuing inv esting activit ies (902) 275 - (627) Net cash flows fro m discontinued i nvesting act ivities (21) - - (21) Cash flows fro m continuing finan cing activit ies AT1 issuance 296 296 Payments for AT1 issuance (48) (48) Proceeds f rom issue of de bt securities and o ther borrowe d funds 977 977 Repayments of debt securit ies in issue and othe r borrowed funds (769) (769) Interest paid on debt securit ies in issue and o ther borrowe d funds (178) (178) Payments of l ease liabiliti es (18) (18) Dividend payments (61) (61) Treasury Share s (55) (55) Net cash flows fro m continuing finan cing activiti es 144 - - 144 Net cash flows fro m discontinued fi nancing activiti es (3) - - (3) Effect of f oreign exchange changes on cash and c ash equivalent s 4 4 Net increase/(dec rease) from co ntinuing cash flow s (1,388) - - (1,388) Changes in cash equivalent from discontinue d operations (200) (200) Cash and cash equi valents at th e beginni ng of the year from continui ng operati ons 4,434 - - 4,434 Cash and cash equi valents at th e end of the year fro m continuing ope rations 3,046 - - 3,046
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
292 | ANNUAL FINANCIAL REPORT
Bank Statement of Cashflows
From 1 January to 31.12.2024 as Investment 31.12.2024 CLO published Properties as restated Cash flows fro m continuing operat ing activities Profit/(l oss) before income tax from continued operations 858 4 862 Adjustments of pr ofit/(loss) befor e income tax for: Depreci ation, impairment, wri te-offs and net r esult from disposa l of property, p lant and equipment 50 (2) 48 Amortization, i mpairment, write-of fs of int angible assets 123 123 Impairment loss es, provisi ons to cover credit r isk and related expenses 426 426 Gains less losses on derec ognition of financial assets measured at amortised cost (31) (31) Fair value (gains)/losses on financial assets measured at f air value through prof it or loss (143) (143) Gain or l osses from valuati on of investment pr operties (2) (2) Impairment of i nvestments (44) (44) (Gains)/lo sses from investi ng activities (495) 35 (460) (Gains)/lo sses from financing ac tivities 278 278 1,022 35 - 1,057 Net (increase)/de crease in assets relating t o continuing operati ng activities: Due from fi nancial institutio ns (414) (414) Trading securi ties and deri vative financial i nstruments 70 70 Loans and adv ances to cust omers (2,971) (310) (3,281) Other ass ets 33 33 Net increase/(dec rease) in liabi lities relati ng to continuing op erating activit ies: Due to ban ks (457) (457) Due to c ustomers 2,143 2,143 Other liabi lities (116) (116) Net cash flows fro m continuing op erating activit ies before income tax (690) (275) - (965) Income tax pai d - Net cash flows fro m continuing op erating activit ies (690) (275) - (965) Net cash flows fro m discontinued op erating activiti es Cash flows fro m continuing investin g acti vities Dividend Received 11 11 Investments in subsidiari es (138) (138) Investments in associates and joint ventures - Acquisiti ons of investment property, proper ty, plant and equ ipment and intangible a ssets (117) (117) Disposals of investment pro perty, property, plant and equipment and intangible asse ts 91 91 Interest received from inv estment securities 351 (32) 319 Purchases of Greek Government Treasury B ills (1,665) (1,665) Proceeds f rom disposal and r edemption of G reek Government Treasury Bills 2,062 2,062 Purchases of investment se curities (excluding Gr eek Government Treasury Bil ls) (3,805) 589 (3,216) Disposals/mat urities of inve stment securit ies (excluding Gre ek Government Treasur y Bills) 2,663 (282) 2,381 Net cash flows fro m continuing inv esting activit ies (547) 275 - (272) Net cash flows fro m discontinued i nvesting act ivities Cash flows fro m continuing finan cing activit ies AT1 issuance 300 300 Payments for AT1 issuance (48) (48) Proceeds f rom issue of de bt securities and o ther borrowe d funds 981 981 Repayments of debt securit ies in issue and othe r borrowed funds (769) (769) Interest paid on debt securit ies in issue and o ther borrowe d funds (185) (185) Payments of l ease liabiliti es (14) (14) Dividend payments (122) (122) Net cash flows fro m continuing finan cing activiti es 143 - - 143 Net cash flows fro m discontinued fi nancing activiti es Effect of f oreign exchange changes on cash and c ash equivalent s 1 1 Net increase/(dec rease) from co ntinuing cash flow s (1,093) - - (1,093) Changes in cash equivalent from discontinue d operations - Cash and cash equi valents at th e beginni ng of the year from continui ng operati ons 2,855 - - 2,855 Cash and cash equi valents at th e end of the year fro m continuing ope rations 1,762 - - 1,762
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
293 | ANNUAL FINANCIAL REPORT
INCOME
STATEMENT
3.
Net interest income
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Interest and simil ar income Due from fi nancial institutio ns 115 199 92 165 Loans and adv ances to cust omers measured at amor tized cost 1,718 1,980 1,614 1,876 Loans and adv ances to cust omers measured at f air value through pr ofit or loss 18 25 14 20 Trading securi ties 1 1 1 1 Investment s ecurities measur ed at fair value through other comprehensive inc ome 25 39 25 36 Investment s ecurities measur ed at fair value through profit o r loss 1 2 Investment s ecurities measur ed at amortized cost 411 367 387 355 Derivat ive financial instr uments 1,730 1,761 1,759 1,812 Finance le ase receivables 10 14 Other 9 21 6 17 Total 4,037 4,408 3,898 4,284 Interest expense an d similar cha rges Due to ban ks (185) (298) (198) (304) Due to c ustomers (302) (374) (265) (330) Debt sec urities in issue and o ther borrowed f unds (175) (191) (178) (193) Lease liab ilities (3) (2) (3) (2) Derivat ive financial instr uments (1,723) (1,843) (1,745) (1,896) Other (51) (55) (49) (54) Total (2,439) (2,763) (2,438) (2,779) Net interest incom e 1,598 1,645 1,460 1,505
Net interest income for the Group and the Bank for the period ended on 31.12.2025 decreased compared to the corresponding period of the
previous year mainly due to the decrease of interest rates that affected interest income linked with business loans and mortgages, partially
counterbalanced by reduced cost of funding and of deposits.
The following table presents interest income and interest expense calculated using the effective interest rate method, by financial asset
category:
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Financial a ssets measure d at amortised cost 2,212 2,520 2,050 2,359 Financial a ssets measure d at fair value thro ugh other comprehe nsive income 25 39 25 36 Financial a ssets measure d at fair value thro ugh profit or loss 20 27 15 23 Financial l iabilities measur ed at amortised cost (662) (856) (641) (827) Total 1,595 1,730 1,449 1,591
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
294 | ANNUAL FINANCIAL REPORT
4.
Net fee and commission income
Net fee and commission income
Net fee and commission income increased for the Group and the Bank compared to the period ended on 31.12.2024 mainly due to higher
volume of mutual fund transactions, increased loan fee commissions as well as higher commission income from loans for credit cards due to
the new partnership with VISA. This was partially counterbalanced by lower commissions from money transfers due to the Greek Government
measures announced in December 2024. It is noted that the commision income from loans relates to from loans that are not measured in fair
value through profit or loss.
During the year 2025, net fee and commission income includes the net fee and commission income from insurance brokerage € 20
(31.12.2024: € 19) for the Group and € 18 (31.12.2024: € 0) for the Bank, which is consisted of:
a) insurance contracts recognized upon sale (point in time) € 17 (31.12.2024: € 17) for the Group and € 17 (31.12.2024: € 0) for the Bank
b) success fees € 3 (31.12.2024: € 2) for the Group and € 1 (31.12.2024: € 0) for the Bank that are recognized over time based on the
achievement of the sales target.
Fee and commissions
The table below presents, per operating segment, the income from contracts, that fall within the scope of IFRS 15:
Group From 1 Janu ary to 31.12.2 025 Wealth Non-Perform ing Retail Wholesale Internation al Total Management Assets Fee and commissi on income Loans 7 70 1 (1) 77 Letter s of guarantee 2 51 1 2 56 Imports-exports 2 6 8 Credit car ds 106 3 109 Money tr ansfers 51 17 9 1 78 Mutual f unds 127 127 Advisory f ees and securit ies transaction fee s 5 5 Broker age services 19 19 Foreign excha nge fees 1 1 1 3 Insurance br okerage 19 1 20 Other 5 8 19 9 41 Total 193 158 165 25 2 543
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Loans 76 68 73 63 Letter s of guarantee 57 53 56 52 Imports-exports 7 6 7 6 Credit car ds 61 50 60 49 Money tr ansfers 78 93 67 84 Mutual f unds 127 88 88 59 Advisory f ees and securit ies transaction fee s 5 5 7 6 Broker age services 14 9 Foreign excha nge fees 3 2 2 1 Insurance br okerage 20 20 29 22 Other 28 26 17 22 Total 47 6 420 406 364
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
295 | ANNUAL FINANCIAL REPORT
Group From 1 Janu ary to 31.12.2 024 Wealth Non-Perform ing Retail Wholesale Internation al Total Management Assets Fee and commissi on income Loans 6 61 1 1 69 Letter s of guarantee 3 46 1 3 53 Imports-exports 2 4 6 Credit car ds 91 2 93 Money tr ansfers 68 16 8 1 93 Mutual f unds 88 88 Advisory f ees and securit ies transaction fee s 4 4 Broker age services 12 12 Foreign excha nge fees 1 1 2 Insurance br okerage 19 1 20 Other 11 5 16 8 40 Total 201 136 116 22 5 480 Bank From 1 Janu ary to 31.12.2 025 Wealth Non-Perform ing Retail Wholesale Internation al Total Management Assets Fee and commissi on income Loans 6 68 (1) 73 Letter s of guarantee 2 51 2 55 Imports-exports 2 6 8 Credit car ds 106 106 Money tr ansfers 51 17 1 69 Mutual f unds 88 88 Advisory f ees and securit ies transaction fee s 5 2 7 Foreign excha nge fees 1 1 2 Insurance br okerage 29 29 Other 6 8 17 31 Total 203 156 107 - 2 468 Bank From 1 Janu ary to 31.12.2 024 Wealth Non-Perform ing Retail Wholesale Internation al Total Management Assets Fee and commissi on income Loans 5 58 63 Letter s of guarantee 2 46 3 51 Imports-exports 2 4 6 Credit car ds 91 91 Money tr ansfers 68 16 1 85 Mutual f unds 59 59 Advisory f ees and securit ies transaction fee s 4 2 6 Foreign excha nge fees 1 1 Insurance br okerage 23 23 Other 12 8 16 36 Total 20 4 13 6 77 - 4 4 21
5.
Dividend income
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Equity sec urities of invest ing portfolio measured at fair value t hrough other Comprehe nsive Income (note 24) 2 2 1 1 Equity sec urities of invest ing portfolio measured at fair value t hrough profit or loss 21 4 18 2 Investments in subsidiari es and associates 31 8 Total 23 6 50 11
The Group line “Equity securities of investing portfolio measured at fair value through profit or loss” for the reporting period includes a
dividend of € 17 from Prodea S.A., followed by distributions by participations in other listed entities of total € 4. The line “Investment in
subsidiaries and associates” at Bank level includes mainly the dividends received by Alpha Life and Alpha Holdings S.M.S.A. amounting to € 19
and € 11 respectively.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
296 | ANNUAL FINANCIAL REPORT
6.
Gains less losses on derecognition of financial assets measured at amortised cost
The tables below present gains less losses for the year 2025 and 2024 from derecognition of financial assets measured at amortised cost as
well as their carrying amount before derecognition.
Group Bank From 1 January to 31.12.2025 Gains less Gains less Carrying (Losses) from Gains from Carrying (Losses) from Gains from losses from losses from Amount derecognition derecognition Amount derecognition derecognition derecognition derecognition Early repayments: - Loans and advanc es to customer s 2,375 (4) 5 1 2,290 (4) 4 - - Securities 75 75 - Sales: - Loans and advanc es to customer s 526 (3) (3) 526 (3) 2 (1) - Securities 1,210 (5) 33 28 1,210 28 28 Substantial modi fications: - Loans and advanc es to customer s 566 (1) 2 1 556 (1) 3 2 Total 4,7 52 (13) 40 27 4,657 (8) 37 29
“Gains less losses on derecognition of financial assets measured at amortized cost” for 2025 mainly relates to gains:
• € 4 from sale of Greek State bonds
• € 24 from sale of Other Sovereign bonds.
Group Bank From 1 January to 31.12.2024 Gains less Gains less Carrying (Losses) from Gains from Carrying (Losses) from Gains from losses from losses from Amount derecognition derecognition Amount derecognition derecognition derecognition derecognition Early repayments: - Loans and advanc es to customer s 2,035 (5) 4 (1) 1,961 (5) 4 (1) - Securities 79 3 3 79 3 3 Sales: - Securities 706 26 26 706 26 26 Substantial modi fications: - Loans and advanc es to customer s 579 (1) 4 3 579 (1) 4 3 Total 3,399 (6) 37 31 3,325 (6) 37 31 “Gain s less losses on derecognition of financial ass ets measured at amortiz ed cos t” for the Group for 2024 mainly rel ates to g ains:
• € 18 from sale of Greek State bonds
• € 8 from sale of Other Sovereign bonds
• € 3 from early repayment of Corporate bonds.
7.
Gains less losses on financial transactions
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Foreign excha nge difference s 16 25 18 20 Trading securi ties: - Bonds 6 5 6 5 - Equity secur ities 18 4 1 Financial a ssets measure d at fair value thro ugh profit or loss: - Loans (2) (9) (2) (10) - Equity secur ities (1) 18 17 - Bonds (3) (2) - Other sec urities 5 5 1 Financial a ssets measure d at fair value thro ugh other comprehe nsive income: - Bonds and tr easury bills 4 6 4 7 Derivat ive financial instr uments (6) 40 5 102 Sale transac tions earn out measur ed at fair value through profit or loss (22) 4 (20) 4 Other financ ial instrument s (10) (14) (24) Total 18 80 3 120
On a Group Level “Gains less losses on financial transactions” for the year 2025 has been reduced compared to 2024 mainly due the following:
• Lower gains for Equity Securities measured at fair value through profit or loss (2025 losses of € 1 compared to gains, of € 18 for
2024).
• Lower result from the derivative financial instruments (2025 losses of € 6, compared to gains of € 40 for 2024).
• Lower gains from Foreign exchange differences (2025 gains of € 16, compared to gains of € 25 for 2024).
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
297 | ANNUAL FINANCIAL REPORT
8.
Other Income
The table below presents, per operating segment, the income from contracts that fall within the scope of IFRS 15:
From 1 Janu ary to 31.12.2025 Wealth Non Perform ing Corporate Total Other Retail Wholesale Internation al Management Assets Center/Elim ination Center Group Group 1 6 10 17 Bank 1 5 4 10 From 1 Janu ary to 31.12.2024 Wealth Non Perform ing Corporate Total Other Retail Wholesale Internation al Management Assets Center/Elim ination Center Group Group 4 3 7 14 Bank 4 4 2 10
9.
Net income from investment property management
The Group's rental income for 2025 amounted to € 12, compared to € 7 for the prior year, which is attributed to the addition of new lease
agreements mainly following the acquisition of new properties and companies by the Group. Gain/(Losses) from valuation of investment
properties amounted to € 8 gains compared to € 4 losses, for the comparative period and is mainly related to market conditions.
For the year ended 31.12.2025 the operating expenses for the investment property generating income stood at € 6 (31.12.2024: € 8), out of
which € 2 relate to maintenance expenses (31.12.2024: €2).
10.
Staff costs
The total number of Group’s employees as at 31.12.2025 was 6,701 (31.12.2024: 6,045) out of which 5,812 (31.12.2024: 5,513) are employed
in Greece and 889 (31.12.2024: 532) are employed abroad. The increase is mainly driven by the acquisition of Astro Bank (317 employees).
The respective numbers for the Bank as at 31.12.2025 were 5,452 (31.12.2024: 5,197) out of which 5,438 (31.12.2024: 5,186) are employed in
Greece and 14 (31.12.2024: 11) are employed abroad.
Line “Wages and salaries” for the Group and Bank shows an increase compared to the previous year, mainly due to salary increases and the
new Sectoral Labor Agreement which was signed on the second quarter of 2025 and among others, provides for additional employe e
remuneration linked with the Bank’s annual profits. At Group level, the acquisition of Astro Bank contributed to an additional increase of € 4.
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 From operati ng lease inco me 3 4 1 3 - From which subl eases 1 1 1 1 Insurance c laims 7 1 7 Other 22 21 15 17 Total 25 32 17 27
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Income from l easing of inv estment properti es 12 7 1 2 Income from se rvices relat ing to investment p roperties 3 2 - - Expenses rel ated to investment propertie s management (6) (8) (2) (2) Gain/(Losse s) from valuatio n of investment prope rties 8 (4) 1 2 Σύνολο 17 (3) - 2
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Wages and salari es 278 267 220 215 Social sec urity contributi ons 56 63 48 54 Employee ind emnity prov ision due to retirement based on Law 2112/1920 3 3 3 3 Other be nefits and charges 37 37 30 32 Total 374 370 301 304
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
298 | ANNUAL FINANCIAL REPORT
In addition, “Wages and salaries” include costs relating to staff incentive schemes as a reward on the Bank’s employees’ according to the
performance remuneration program. The programs include awards in cash, as well as stock awards to employees the terms of which are
presented below.
Finaly the line "Social security contributions" for the year 2025 includes a credit amount of € 6 from the recognition of net receivable s from e -
EFKA relating to unduly amounts paid for prior year contributions.
Stock awards to employees
The Group has programs for granting free shares of the Bank to the members of Management and employees of the Bank and its affiliated
companies. According to the terms of the programs, a percentage of the grant vests during the initial vesting period, while the remaining
amount vests in equal annual installments over a period of four or five years. It is also noted that the entitlement to receive free shares
requires continued employment until the share allocation date while for the part of the awards granted in 2025 entitlement is also subject to
the satisfaction of long-term performance targets.
In the context of the above mentioned programs the following shares were awarded during the year:
- 5,745,429 shares awarded on 7.5.2025 by Alpha Services and Holdings (before reverse merger) with weighted average fair value of €
2.0646
- 71,735 shares were awarded on 1.8.2025 by the Bank (after the rever se merger) with weighted average fair value of € 2.7793
The fair value of the stock awards for each of the registration dates was based on the closing share price at the grant date and the respective
risk free rate. No dividend distribution has been assumed in the fair value of the stock awards.
From the implementation of the above programs, the Group recognised in Staff costs an amount of € 11 (31.12.2024: € 5) against a credit in
an equity reserve, while the Bank recognised in Staff costs an amount of € 11 (31.12.2024: € 5) against a credit in an equity reserve.
Awarding of stock options to employees
The Group has stock option programs for granting shares of the Bank to members of Management and employees of the Bank and its affiliated
companies. According to the terms of the program, within the first year from the date the compensation is granted, beneficiaries may exercise
60% of their total rights, while the remaining amount vests in equal annual installments over a period of three or four years. Rights that are
not exercised expire. Additionally, if a beneficiary ceases to be an employee or executive of the Group (with certain exceptions, such as
retirement or incapacity to work), ceases to have the right to purchase shares.
Changes in the number of existing stock options for the years 2025 and 2024 are presented in the tables below:
Group 202 5 202 4 Weighted aver age exerci se Weighted aver age exerci se price Number of Opt ions Number of Opt ions price Balance 1.1 9 86,842 0.295 2,310,021 0.294 Changes 1.1 – 31.12 Stock Optio ns exercised during the year (834,784) 0.296 (1,279,623) 0.294 Stock Optio ns expired dur ing the year (11,758) 0.290 (43,556) 0.290 Balance 31.12 140,300 0.290 9 86,842 0.295 Bank 2025 2024 Weighted aver age exerci se Weighted aver age exerci se price Number of Opt ions Number of Opt ions price Balance 1.1 9 86,372 0.295 2,307,471 0.294 Changes 1.1 – 31.12 Stock Optio ns exercised during the year (8 34,314) 0.296 (1,2 77,543) 0.294 Stock Optio ns expired dur ing the year (11,758) 0.290 (43,556) 0.290 Balance 31.12 140,300 0.290 9 86,372 0.295
The share price at the time options were exercised in January 2025 and in September 2025 was € 1.73 and € 3.49 respectively and the price at
the time options were exercised in January 2024 and in September 2024 was € 1.60 and €1.51 respectively.
The average duration of the outstanding stock options is 9 months (31.12.2024: 5 months) with an exercise price of € 0.29.
Defined contribution plans
All employees of the Group are insured for their:
• main pension by the Electronic National Social Security Entity (e-E.F.K.A.)
• supplementary pension by the Electronic National Social Security Entity (e-E.F.K.A.). For employees starting employment after
1.1.2022 and employees who opted for it, the supplementary pension fund is the Hellenic Auxiliary Pensions Defined Contributions
Fund (T.E.K.A.)
• healthcare coverage by the National Organization of Health Care (EOPYY) and welfare benefits in kind by the relevant Sector of the
former T.A.Y.T.E.K.O. or the former E.T.A.A., both of which have been incorporated, since 1.1.2017, into to the Electronic National
Social Security Entity (e-E.F.K.A.).
In addition, for the Bank’s employees, the following also apply:
a. Supplementary Pension
Especially for employees of the former Ionian and Laiki Bank of Greece the supplementary pension fund is T.A.P.I.L.T.A.T., a multi-employer
fund. The Bank has obtained legal opinions that indicate that it has no obligation if this fund does not have sufficient assets to cover employee
benefits. Therefore, the Bank considers that the fund is a defined contribution plan and has accounted for it as such.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
299 | ANNUAL FINANCIAL REPORT
b. Pre-retirement Benefit
Employees hired by the former Alpha Credit Bank and the former Emporiki Bank who are eligible for pre-retirement benefits, according to the
terms and conditions of retirement of the respective insurance entities (T.A.P.T.P. and T.E.A.P.E.T.E.) are insured at the Single Insurance of
Bank Employees Fund (E.T.A.T.) as per Law 3371/2005, which was incorporated into the Single Social Security Entity (E.F.K.A.) as of 1.1.2017,
as per Law 4387/2016 and was renamed to Electronic National Social Security Entity (e-E.F.K.A.) as of 1.3.2020, as per Law 4670/2020.
c. Lump Sum Benefit
Employees of the former Ionian and Laiki Bank of Greece and the former Emporiki Bank are insured for the lump sum benefit in the “Bank
Employee and Companies Common Benefit Plan” (T.A.Y.T.E.K.O.) which is a defined contribution plan with contributions paid only by
employees. In accordance with Law 4387/2016, the relevant Sectors of the “Bank Employee and Companies Common Benefit Fund”
(T.A.Y.T.E.K.O.) consist part of the E.T.E.A.E.P. (Joint Supplementary Insurance and Lump Sum Benefits Fund).
d. IORP Alpha Bank Group Personnel
The IORP of Alpha Bank Group was established in March 2023 is a post-employment benefit plan for the benefit of the employees of the
Group of Alpha Bank , and regards those employees with indefinite duration labor contracts or those having salaried mandate contracts
relationship.
Employee defined benefit obligations
The analysis of Defined Benefit Plans is disclosed in note 36.
11.
General Administrative expenses
General administrative expenses increase is mainly driven by increased IT Expenses and Maintenance of IT equipment, third party fees and
Tax and Duties.
12.
Impairment losses and provisions to cover credit risk
The following table presents the impairment losses and provisions to cover credit risk on loans and advances to customers and other financial
instruments, financial guarantee contracts, other assets, as well as recoveries:
The calculation of expected credit losses incorporates a sale scenario with 100% probability for the loan portfolios that are classified as Held for
Sale.
For the above-mentioned portfolios a charge of € 128 was recognised in Group Impairment (gains)/ losses for the period ended on 31.12.2025
and mainly regards:
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Building c osts 28 24 25 23 Card schemes c osts 8 9 7 9 IT expenses and Maintenanc e of IT equipment 80 66 71 56 Marketi ng and advertisi ng expenses 26 27 24 23 Operati onal costs 31 30 27 27 Taxes and Duti es (VAT, real est ate tax etc.) 86 76 68 59 Third part y fees 74 67 55 47 Regulator y fees and other r elated expenses 10 9 7 8 Other 2 2 Total 345 308 286 252
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Impairment (gains)/losses on loans 294 355 274 333 Impairment (gains)/losses on advances to customer s (2) 2 Provisions to cover credit risk on letters o f guarantee, l etters of credit and undrawn loan commitment s 1 (5) (7) (note 45) (Gains)/Loss es from modific ations of contr actual terms of lo ans and advances t o customers 30 16 30 15 Recoverie s (9) (10) (7) (9) Impairment loss es on other a ssets (1) 4 (1) Impairment losses and prov isions to cover cred it risk on loans an d advances to customers (a) 315 358 296 334 Impairment (gains)/losses on debt securit ies and other sec urities measured at amort ized cost 1 (2) Impairment (gains)/losses on debt securit ies and other sec urities measured at fai r value through ot her 1 1 1 1 comprehensi ve income Impairment (gains)/losses on due from financial i nstitutions (1) Impairment losses a nd provisions t o cover credit ri sk on other finan cial instru ments (b) 1 2 1 (2) Total (a) + (b) 316 360 297 332
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
300 | ANNUAL FINANCIAL REPORT
a. € 9 4 for non-performing mortgage and wholesale loans in the new “Athena” perimeter were classified as “Held for Sale” within second
quarter of 2025 (note 54),
b. € 1 5 additional impairment costs for the non-performing loans and assets portfolio in Cyprus (ACAC portfolio) (note 54),
c. € 11 for non-performing wholesale loans, in Solar perimeter from which € 6 regarded the expansion of the perimeter that have been
classified as “Held for Sale” within the first quarter of 2025. The transaction was completed on December 2025. (note 54).
Group “Impairment losses/(gains)” on loans for 2024 include a charge of € 216 for “Held for Sale” portfolios and refers mainly to “Assets Held for
Sale”:
a. € 137 loss for non-performing mortgage and wholesale loans the “GAIA II” perimeter that were classified as “Held for Sale” within the
second quarter of 2024.
b. € 40 loss for non-performing mortgage, consumer and wholesale loans in the “GAIA I” perimeter that were classified as “Held for Sale”
within the second quarter of 2024.
c. € 24 loss for non-performing loans in the Cyprus (ACAC portfolio) that were classified as “Held for Sale” within the second quarter of
2024.
As regards to post model adjustments (PMA) more information is provided in note 49.1.
The below amounts relate to loans and advances to customers for which there was modification of their contractual terms while they were
categorized as stage 2 or 3 or POCI.
Group Bank From 1 January to Loans modifi ed during the y ear 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Net carr ying amount befor e the modification 2,777 2,734 2,739 2,599 Net gain or (loss) due to t he modification (15) (15) (15) (15)
The following table represents the carrying amount of loans and advances to customers that were modified at a time when they had a
lifetime expected credit loss and for which the allowance is measured based on 12-month expected credit losses at the end of the year.
Group Bank From 1 January to Loans cate gorized at Stage 1 31.12.2025 31.12.202 4 31.12.2025 31.12.2024 Carrying amount before al lowance for expec ted credit lo sses at the end of the year 1,024 971 1,022 933
13.
Expenses relating to credit risk management
Loan servicing fees arise from the serving agreement of Non-Performing loans, while commission expense for credit protection includes the
commission amount paid by the Bank in the context of synthetic securitisation transactions, in order to receive protection against part of the
credit risk of a specific portfolio of performing corporate loans.
14.
Impairment losses on fixed assets and equity investments
“Impairment losses/write-offs on property plant and equipment,intangible assets and right-of-use assets” for the Group and Bank (€ 38 and €
34 respectively) for the period ended 31.12.2025 relate mainly to impairment losses from Intangible assets with NBV of € 34 which were fully
impaired during the year as no future economic benefits were expected from their use.
Regarding the line "Impairment losses / (Reversal of
Impairment losses) on equity investments", an impairment of € 3 in Nexi Greece Payments Institutions S.A has been recognised during the
period, which arose from the deterioration of the Company's financial performance, which resulted in a reduction of its net assets.
At Bank level, the corresponding amount of € 154 for the year 2025 primarily relates to the reversal of impairment of the subsidiary Alpha
International Holdings S.M.S.A. (Note 26).
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Loan servi cing fees 40 47 38 46 Commission expenses for c redit protection 43 46 43 46 Total 83 93 81 92
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Impairment loss es/write-off s on property pl ant and equipment,int angible assets and right-of-use ass ets 38 8 34 8 Impairment loss es / (Reve rsal of Impairment l osses) on equity investments (Note 26) 5 (154) (4 3) Impairment loss es on inve ntories 2 3 2 2 Impairment loss es on non-fina ncial assets or dispo sal groups held f or sale (Note 54) 6 2 1 Total 51 13 (118) (33)
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
301 | ANNUAL FINANCIAL REPORT
15.
Gains/(Losses) on disposal of fixed assets and equity investments
Within 2024, the line 'Gains/(losses) from disposal of non-financial assets or disposal groups held for sale' was affected by the completion of
the Skyline transaction where the Group recognised a gain from the sale of € 23. During the current year, gains of € 8 were recognised , of
which € 7 related to assets in the Skyline perimeter. (Note 54).
16.
Provisions
Line “Other provisions” for the period ended 31.12.2025 has been mainly affected by a release of € 23 for the Group and € 15 for the Bank
regarding provision claims of sale transactions. An additional provision of € 25 has been recognised for the Bank and the Group regarding
“Marietta Giannakou” school renovation programme following the announcement of the four systemic banks and the government for an
extension of the programme. It is also noted that additional corresponding contributions for the years 2026-2027 are subject to a relevant
evaluation of the progress of the “Marietta Giannakou” programme, its requirements, and the prevailing financial condition at that time and
subsequently no provisions has been recognized as at 31.12.2025.
17.
Transformation costs
The line item “Transformation costs” includes € 18 (31.12.2024: € 14) for the Group and € 17 (31.12.2024: € 12) for the Bank, that relate to
projects and initiatives carried out by the Group that lead to significant changes in its operational model, which is part of its Strategic Plan,
with the aim of enhancing the organization's efficiency, optimizing the commercial model and further strengthening the performance
measurement and reward systems in all functions.
18.
Income tax
Τhe income tax rate for legal entities is set to 22%, while for financial institutions the income tax rate is 29%.
**
For the subsidiaries and branches operating in other countries, the applicable nominal t ax rates for the year 202 5 are as follows: Country Rate % Country Rate % *Luxembourg 23.87 Cyprus 12.5 Bulgaria 10 Jersey 10 Serbia 15 United Kingdo m 25 Romania 16
The income tax in the Income Statement is analyzed as follows:
*
The corporate tax rate in Cyprus increased to 15% and applies to tax years starting from 1 January 2026 onwards
**
From 1.1.2025 the tax rate changed from 24,94% to 23,87%
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Gains/(Losse s) from disposal of equity investment s (1) (1) Gains/(Losse s ) from disposal of property, pl ant and equipment and intangible assets 1 Gains/(Losse s) from disposal of investment proper ty (1) Gains/(Losse s) from disposal of inventories 1 2 1 2 Gains/(Losse s) from disposal of non-financial asse ts or disposal group s held for sale (Not e 54) 8 25 5 1 Total 7 27 6 3
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Provisions for pending or under ar bitration legal cases 8 8 1 Provisions for voluntary separations schemes 55 49 Other pr ovisions 4 30 13 32 Total 12 85 21 82
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Current t ax 10 60 (10) 46 Deferre d tax (2 5) 161 (28) 16 6 Total (1 5) 221 (38) 21 2
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
302 | ANNUAL FINANCIAL REPORT
Deferred tax recognized in the income statement is attributable to temporary differences, the effect of which is analyzed in the table below:
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Debit diff erence of Law 4046/2012 45 45 45 45 Debit diff erence of Law 4465/2017 50 170 50 170 Write-offs, de preciation, i mpairment of plant, property and equi pment and leases an d valuation of 37 23 35 23 Investment Pr operties Loans 49 (99) 48 (99) Valuation of loans due to he dging (4) (4) Defined benefit obligati on (1) (1) Valuation of derivative fina ncial instruments 96 44 96 44 Valuation of liabilities t o credit institutio ns and other bo rrowed funds due to f air value hedge 13 (43) 13 (43) Valuation/Impai rment of inv estments 2 (4) 1 (4) Valuation/Impai rment of debt securities and ot her securities (1 11) 30 (110) 32 Tax losses car ried forwar d (207) 8 (209) Other t ax adjustments 6 (12) 7 (2) Total (25) 161 (28) 166
A reconciliation between the effective and nominal tax rate is provided below:
The nominal tax rate is the average weighted tax rate resulting from the income tax, based on the nominal tax rate, and the pre-tax results,
for the parent and for each of the Group’s subsidiaries.
During the first half of 2025, the Bank recognized a deferred tax asset of € 245, which is presented under the line item ‘Rec ognition of
deferred tax on carried-forward tax losses’. This amount relates to deferred tax arising from tax losses of the absorbe d entity Alpha Services
and Holdings S.A., which are expected to be utilized against future taxable profits. As at 31 December 2025, the deferred tax asset amounts to
€ 208, following the offset of part of these losses against the taxable profits of the year.
These losses are transferred to the absorbing company under the same conditions and the five-year time horizon that would have been
applied to the absorbed company, had the transformation not taken place, in accordance with paragraph 22 of article 16 of Law 2515/1997,
as added by paragraph 1 of article 221 of Law 5193/2025.
Line “Recognition of deferred tax for tax losses carried forward from previous years” also includes an amount of € 3, which relates to the
offsetting of tax losses by Alpha Bank Cyprus, through the tax losses carried forward from other Group entities operating in Cyprus (Tax Group
relief).
The Group falls within the scope of the Pillar II rules and, for the period ended 31 December 2025, performed an assessment of the potential
impact arising from the imposition of top-up tax. Based on this assessment, a top-up tax liability was identified in the jurisdictions of Greece
and Romania, and is included in line “Other tax differences”.
Line “Current tax” in the Consolidated Statement of Profit or Loss includes an amount of € 5 (31.12 2024: € 0), relating to the respective top-
up tax charge.
Group From 1 Janu ary to 31.12.2025 31.12.2024 % % Profit/(Loss) before in come tax 904 818 Income tax (nominal t ax rate) 27.54 249 29.10 238 Increase/(Decr ease) due to: Non-ta xable income (0.88) (8) (0.61) (5) Non-de ductible expe nses 1.66 15 1.10 9 Recognition of deferred tax for tax losses c arried forw ard from pre vious yea rs (2 7.43) (2 4 8) Non-r ecognition o f deferred tax for tax losses ca rried forwa rd 0.66 6 0.73 6 Other tax d ifferences (3.21) (29) (3.30) (27) Income tax (effectiv e tax rate) (1.66) (15) 27.02 221 Bank From 1 Janu ary to 31.12.2025 31.12.2024 % % Profit/(Loss) before in come tax 96 4 862 Income tax (nominal t ax rate) 29.00 28 0 29.00 2 50 Increase/(Decr ease) due to: Non-ta xable income (1.35) (13) (0.70) (6) Non-de ductible expe nses 0.93 9 0.70 6 Recognition of deferred tax for tax losses c arried forw ard from pre vious yea rs (25.39) (245) Other tax d ifferences (7.13) (69) (4.41) (3 8) Income tax (effectiv e tax rate) (3.94) (38) 24.5 9 21 2
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
303 | ANNUAL FINANCIAL REPORT
Income tax of other comprehensive income recognized directly in equity
From 1 Janu ary to Group 31.12.2025 31.12.2024 Before Income After Before Income After Income tax tax Income tax Income tax tax Income tax Amounts that may be reclassified to the Income Statement Net change i n the reser ve of debt securiti es measured at f air value through other (2) 11 9 11 (2) 9 comprehensi ve income Net change i n cash flow hedge reserve 26 (7) 19 31 (9) 22 Currency t ranslation differ ences from financi al statements an d net investment he dging 2 2 36 11 47 of foreign o perations Share of o ther comprehens ive income from Associ ates and Joint Vent ures 2 (1) 1 28 3 31 78 - 78 Amounts that wi ll not be reclassified to the Income Statement Gains/(Loss es) from equit y securities measured at fair value t hrough other 4 (1) 3 (12) 4 (8) comprehensi ve income 4 (1) 3 (12) 4 (8) Total 32 2 34 66 4 70
The amounts in the above table also include the amounts related to discontinued operations.
From 1 Janu ary to Bank 31.12.2025 31.12.2024 Before Income After Before Income After Income tax tax Income tax Income tax tax Income tax Amounts that may be reclassified to the Income Statement Net change i n the reser ve of debt securiti es measured at f air value through other (2) 1 (1) comprehensi ve income Net change i n cash flow hedge reserve 26 (8) 18 31 (9) 22 24 (7) 17 31 (9) 22 Amounts that wi ll not be reclassified to the Income Statement Gains/(Loss es) from equit y securities measured at fair value t hrough other 6 (1) 5 (14) 4 (10) comprehensi ve income 6 (1) 5 (14) 4 (10) Total 30 (8) 22 17 (5) 12
19.
Earnings/(losses) per share
a. Basic
Basic earnings/(losses) per share are calculated by dividing the net profit/(losses) for the year, attributable to ordinary equity holders of the Bank,
adjusted for the AT1 coupon payment, by the weighted average number of ordinary shares outstanding during the period, excluding the
weighted average number of own shares held, during the period.
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Profit / (Loss) attrib utable to eq uity holders of the Bank 943 654 1,002 6 50 Minus: Ret urn on capi tal instrumen ts “AT1” (70) (48) (71) (48) Adjusted Pro fit / (Loss) for the A T1 coupon payment 873 606 931 602 Weighted aver age number of o utstanding ordi nary shares 2,307,648,571 2,338,436,549 26,395,309,853 51,979,992,461 Basic ear nings /(losses) p er share (in €) 0.3783 0.2591 0.0353 0.0116 Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Profit / (Loss) from c ontinu ing operations attributab le to equ ity holders of the Ban k 919 597 1,002 650 Minus: Ret urn on capi tal instrumen ts “AT1” (70) (48) (71) (48) Adjusted Pro fit / (Loss) for the A T1 coupon payment 849 549 931 602 Weighted aver age number of o utstanding ordi nary shares 2,307,648,571 2,338,436,549 26,395,309,853 51,979,992,461 Basic ear nings /(losses) p er share (in €) 0.3679 0.2348 0.0353 0.0116
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
304 | ANNUAL FINANCIAL REPORT
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Profit / (Loss) from d iscontinued o perations attributab le to equi ty holder s of the Bank 24 57 - - Minus: Ret urn on capi tal instrumen ts “AT1” Adjusted Pro fit / (Loss) for the A T1 coupon payment 24 57 - - Weighted aver age number of o utstanding ordi nary shares 2,307,648,571 2,338,436,549 Basic ear nings /(losses) p er share (in €) 0.0104 0.0243
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
305 | ANNUAL FINANCIAL REPORT
b. Diluted
Diluted earnings/(losses) per share are calculated by adjusting the weighted average number of ordinary shares outstanding during the period
with the dilutive potential ordinary shares. The Bank holds shares of this category, which arise from a plan of awarding stock options rights and
stock awards to employees of the Bank and Group companies.
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Adjusted Pro fit / (Loss) attributa ble to equi ty holders of the Ban k 943 654 1,002 650 Minus: Ret urn on capi tal instrumen ts “AT1” (70) (48) (71) (48) Adjusted Pro fit / (Loss) for the A T1 coupon payment 873 606 931 602 Weighted aver age number of o utstanding ordi nary shares 2,307,648,571 2,338,436,549 26,395,309,853 51,979,992,461 Stock awards 3,802,823 2,033,796 1,970,830 Adjustment fo r stock options 221,968 924,452 103,458 Weighted aver age number of o utstanding ordi nary shares fo r diluted earnings per share 2,311,673,362 2,341,394,798 26,397,384,140 51,979,992,461 Diluted earnings /(losses) pe r share (in €) 0.3776 0.2588 0.0353 0.0116 Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Profit / (Loss) from c ontinu ing operations attributab le to equ ity holders of the Bank 919 597 1,002 650 Minus: Return on capita l instrumen ts “AT1” (70) (48) (71) (48) Adjusted Pro fit / (Loss) for the A T1 coupon payment 849 549 931 602 Weighted aver age number of o utstanding ordi nary shares 2,307,648,571 2,338,436,549 26,395,309,853 51,979,992,461 Adjustment fo r stock awards 3,802,823 2,033,796 1,970,830 Adjustment fo r stock options 221,968 924,452 103,458 Weighted aver age number of o utstanding ordi nary shares fo r diluted earnings per share 2,311,673,362 2,341,394,798 26,397,384,140 51,979,992,461 Diluted earnings /(losses) pe r share (in €) 0.3673 0.2345 0.0353 0.0116 Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.202 4 Profit / (Loss) from d iscontinued o perations attributab le to equi ty holder s of the Bank 24 57 - - Minus: Ret urn on capi tal instrumen ts “AT1” Adjusted Pro fit / (Loss) for the A T1 coupon payment 24 57 - - Weighted aver age number of o utstanding ordi nary shares 2,307,648,571 2,338,436,549 Adjustment fo r stock awards 3,802,823 2,033,796 Adjustment fo r stock options 221,968 924,452 Weighted aver age number of o utstanding ordi nary shares fo r diluted earnings per share 2,311,673,362 2,341,394,798 Diluted earnings /(losses) pe r share (in €) 0.0104 0.0242
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
306 | ANNUAL FINANCIAL REPORT
ASSETS
20.
Cash and balances with Central Banks
The movement in “Balances with Central Banks” reflects the increase in the overnight deposit in the European Central Bank.
Cash and cash equivalents (as presented in the Statement of Cash Flows)
21.
Due from financial institutions
The Bank from 2016 up to 2023 has contributed to the Single Resolution Fund (SRF) in cash and in the form of irrevocable payment
commitments (IPCs), the latter being fully backed by cash collateral. As of 31.12.2025 the notional amount of the collateral provided for IPCs
amounts to € 30.
During the year ended 31.12.2025, a Court of the European Union dismissed the appeal filed by a French bank for the cancellation of the IPCs
and the return of the financial guarantee following the revocation of its operating license. The Court’s decision w as based on the reasoning
that even if an entity ceases to conduct its activities as a credit institution, it does not affect its obligation to pay all pre-determined
contributions owed. The Court's decision was assessed as having no significant financial impact on the financial statements of the Bank and
the Group.
22.
Trading securities
The following table presents an analysis of the carrying amount of trading portfolio per type of security:
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Cash 468 448 455 443 Cheques rec eivables 8 11 1 1 Balances with Central B anks 2,993 2,539 1,767 1,312 3,469 2,998 2,223 1,756 Less: Deposi ts pledged to Central Banks (not e 45) (573) (504) (493) (470) Total 2,896 2,494 1,730 1,286
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Cash and balanc es with ce ntral banks 2,896 2,494 1,730 1,286 Securiti es purchased under a greements to r esell (Reverse R epos) 316 216 316 216 Short-term plac ements with other banks 245 336 163 260 Total 3,457 3,046 2,209 1,762
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Due from f inancial instit utions 254 311 309 234 Reverse Repos 1,628 985 1,628 984 Pledged deposi ts 981 1,0 70 1,004 1,093 Less: Allowanc e for expect ed credit losses (70) (70) (70) (70) Total 2,793 2,296 2,871 2,241
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Bonds: - Greek Gov ernment 28 4 28 4 - Other Sover eign 7 7 - Other iss uers 4 6 4 6 Treasury B ills: -Greek Gov ernment 5 11 5 12 Equity securit ies: - Listed 67 26 1 1 Total 104 54 38 30
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
307 | ANNUAL FINANCIAL REPORT
23.
Derivative financial instruments (assets and liabilities)
Assets
Liabilities
31.12.2025 31.12.2024 Contractual Fair Value Contractual Fair Value Group Nominal Nominal Assets Liabilit ies Amount Amount Derivatives held for trading purpose s a. Foreign ex change de rivatives Foreign excha nge forwards 944 8 7 696 14 12 Foreign excha nge swaps 1,879 5 8 1,043 1 10 Cross curr ency swaps 267 5 404 16 13 Currency o ptions 120 1 1 1 Total non-listed 3,210 14 21 2,144 31 35 b. Interest rate deriv atives Interest rate swaps 67,990 2,077 1,978 55,773 1,636 1,587 Interest rate options (caps an d floors, swaptions) 9,087 15 10 6,563 25 21 Total non-listed 77,077 2,092 1,988 62,336 1,661 1,608 Futures 4,505 2 430 1 Total li sted 4,505 2 - 430 1 - c. Commod ity derivatives Commodity s waps 106 3 3 111 4 4 Commodity f orwards 116 1 Total non-listed 222 4 3 111 4 4 d. Index der ivatives Index swaps 21 2 2 39 OTC options 749 32 32 627 24 25 Total non-listed 770 34 34 666 24 25 Futures 85 1 39 Total li sted 85 1 - 39 - - e. Other der ivatives GDP linke d security 697 2 Total-listed - - - 697 2 - Derivatives for hedg ing a. Foreign ex change de rivatives Foreign excha nge swaps 264 1 Cross curr ency swaps 103 1 153 2 Total non-listed 103 - 1 417 - 3 b. Interest rate deriv atives Interest rate swaps 17,864 370 73 16,772 234 294 Total non-listed 17,864 370 73 16,772 234 294 Grand Total before off set 103,836 2,517 2,120 83,612 1,957 1,969 Amounts used fo r offset withi n the Balance Sheet - (2,072) (1,402) - (1,329) (1,176) Grand Total after offset 103,836 445 718 83,612 628 793
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
308 | ANNUAL FINANCIAL REPORT
Hedging accounting
a. Fair value hedges
The Group uses interest rate swaps to hedge its exposure to changes in the fair values due to changes in market rates of fixed interest rate in
instruments such as: a) Bonds, b) specific corporate loan c) bond securities in issue and d) first demand deposits.
More specifically, with regards to deposits, it is noted that the Group applied interest rate hedging accounting on a portfolio basis, making use
of the provisions on hedge accounting adopted by the European Union (EU Carve-out).
The Group and the Bank also uses foreign currency swap to hedge the currency risk of its net investment in a subsidiary and in associates.
Duration, nominal amount, interest rate and currency rate of hedging instruments of 31.12.2025 and 31.12.2024 are summarized as follows:
Group 31.12.2025 31.12.2024 Nominal amount of Average fixed Nominal amount Average fixed Duration Hedging Relati onship the derivative interest of the derivative interest Interest rate risk <1 year Senior Pref erred Bonds 1,850 2.73% 1,750 2.98% 1 – 5 years 500 (0.27)%) 500 (0.27)% >5 years 138 (0.11)% <1 year Tier II Bon ds 500 3.01% 1,131 1.24% 1 – 5 years First Demand Deposits 8,150 2.77% 7,500 3.15% 1 – 5 years Bonds at a mortized cost (AC) 5,345 2.81% 4,850 2.73% >5 years Corporate loans 231 2.37% 236 2.37% >5 years 250 2.36% 1 – 5 years Senior se curitisation bo nds, classified as loans at amortised co st 700 2.54% 450 2.50% >5 years Securiti es measured at fair v alue through OCI 4 2.59% >5 years
Assets
Liabilities
31.12.2025 31.12.2024 Contractual Fair Value Contractual Fair Value Bank Nominal Nominal Assets Liabilit ies Amount Amount Derivatives held for trading purpose s a. Foreign ex change de rivatives Foreign excha nge forwards 944 8 7 1,003 15 12 Foreign excha nge swaps 1,834 6 7 1,429 1 12 Cross curr ency swaps 585 1 7 783 17 18 Currency o ptions 120 1 1 1 Total non-listed 3,483 16 22 3,216 33 42 b. Interest rate deriv atives Interest rate swaps 68,200 2,076 1,980 56,114 1,746 1,590 Interest rate options (caps an d floors) 9,237 15 10 6,713 25 21 Total non-listed 77,437 2,091 1,990 62,827 1,771 1,611 Futures 4,505 2 430 1 Total li sted 4,505 2 - 430 1 - c. Commod ity derivatives Commodity s waps 106 3 3 111 4 4 Commodity f orwards 116 1 Total non-listed 222 4 3 111 4 4 d. Index der ivatives Index swaps 21 2 2 39 OTC options 749 32 32 627 24 25 Total non-listed 770 34 34 666 24 25 e. Other der ivatives GDP linke d security 697 2 Total-listed - - - 697 2 - Derivatives for hedg ing a. Foreign ex change de rivatives Cross curr ency swaps 59 59 Total non-listed 59 - - 59 - - b. Interest rate deriv atives Interest rate swaps 17,864 370 73 16,772 234 294 Total non-listed 17,864 370 73 16,772 234 294 Grand Total before off set 104,340 2,517 2,122 84,778 2,069 1,976 Amounts used fo r offset withi n the Balance Sheet (2,071) (1,404) - (1,329) (1,176) Grand Total after offset 104,340 446 718 84,778 740 800
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
309 | ANNUAL FINANCIAL REPORT
Bank 31.12.2025 31.12.2024 Nominal Average fixed inte rest Nominal Average fixed Hedging Relati onship amount of the / Foreign Exchan ge amount of the interest / Forei gn Duration derivative rate GBP derivative Exchange rate G BP Interest rate risk <1 year Senior Pref erred Bonds 1,850 2.73% 1,750 2.98% 1 – 5 years 500 (0.27)% 500 (0.27)% >5 years 138 (0,11%) <1 year Tier II Bonds 500 3.01% 1,131 1.24% 1 – 5 year First Demand Deposits 8,150 2.77% 7,500 3.15% 1 – 5 years Bonds at a mortized cost (AC) 5,345 2.81% 4,850 2.73% >5 years Corporate loans 231 2.37% 236 2.37% >5 years 250 2.36% 1 – 5 years Senior se curitisation bo nds, classified as loans at amortised co st 700 2.54% 450 2.50% >5 years Securiti es measured at fair v alue through OCI 4 2.59% >5 years FX rate risk Investment i n Alpha Bank London in GBP 59 0.8726 59 0.8292 <1 year
The balance sheet and the income statement amounts relating to fair value hedging instruments and the hedge effectiveness are analyzed as
follows:
Group - 202 5 Carrying amoun t of Gain/(loss) from fair value Ineffectivene ss Financial line item in Financial line item in the hedging inst rument change of hedg ing gain/(loss) the Income Derivative balance shee t where the Hedging rela tionship instrument use d for recognized in the statement tha t Type hedging inst rument is Assets Liabilit ies calculating the hedge income statem ent included he dge included effectivenes s for 2025 for 2025 ineffect iveness Interest rate risk Bonds at a mortized cost 168 47 337 (1) (AC) Corporate Loans 11 12 Senior Bo nds issues 33 17 1 1 Interest Derivat ive Financial Gains less losses on Tier II Bonds issues 14 1 10 (1) rate swap Instruments financial transactions First Demand Deposits 131 3 (55) (2) Senior se curitisation bo nds, classified as loans at 14 18 (1) amortised cost Group - 2024 Carrying amoun t of Financial line item in Gain/(loss) from fair value Ineffectivene ss Financial line item in hedging inst rument the balance sheet change of hedg ing gain/(loss) the Income Derivative Hedging rela tionship where the hedg ing instrument use d for recognized in the statement tha t Type Assets Liabilit ies instrument is calculating the hedg e income statem ent included he dge included effectivenes s for 2024 for 2024 ineffect iveness Interest rate risk Bonds at a mortized cost (AC) 36 230 (65) 9 Corporate Loans 1 (2) Senior Bo nds issues 43 27 23 Tier II Bonds issues 8 16 33 1 First Demand Deposits Interest 147 5 Derivat ive Financial 64 (1) Gains less losses on rate swap Instruments financial transactions Senior se curitisation bo nds, (4) classified as loans at amorti sed 4 cost Securiti es measured at fair 1 value thr ough OCI
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
310 | ANNUAL FINANCIAL REPORT
The amounts related to balance sheet items designated as hedged items are analyzed as follows:
sheet where the hedged item is
Group - 202 5 Accumulated amou nt of fair Change in fair value Financial li ne item in the balance Carrying Amount value hedge adjust ments on th e of hedged item us ed Hedging relati onship hedged item for calculating t he included Assets Liabili ties Assets Liabili ties hedge effectiveness Interest rate risk Investment s ecurities measur ed at (338) Bonds at a mortized cost (AC) 6,114 (161) amortized co st Corporate Loan 238 (11) Loans and adv ances to cust omers (12) Senior Bo nd issues 2,380 (6) Debt sec urities in issue and o ther Tier II Bonds issues 640 (2) borrowed funds (11) First Demand Deposits 8,1 74 24 Due to Cust omers 54 Senior se curitisation bo nds, classified as Galaxy Seni or Bonds, classi fied as 1,058 (15) (19) loans at a mortised cost Loans at amor tised cost
financial transactions
financial transactions
Bank - 202 5 Carrying amoun t of Financial line item in Gain/(loss) from fair value Ineffectivene ss Financial line item in hedging inst rument the balance sheet change of hedg ing gain/(loss) Derivative the Income s tatement Hedging rela tionship where the hedg ing instrument use d for recognized in the Type that include d hedge Assets Liabilit ies instrument is calculating the hedge income statem ent ineffect iveness included effectivenes s for 2025 for 2025 Interest rate risk Bonds at a mortized cost (AC) 168 47 337 (1) Corporate Loans 11 12 Senior Bo nds issues 33 17 1 1 Tier II Bonds issues Interest 14 1 Derivat ive Financial 6 1 Gains less losses on rate swap Instruments 131 3 (55) (2) First Demand Deposits Senior se curitisation bo nds, classified as loans at 14 18 (1) amortised cost FX rate risk Investment i n Alpha Bank Derivat ive Financial Gains less losses on CCIRS (3) London in GBP Instruments financial transactions Bank - 2024 Carrying amoun t of Financial line item in Gain/(loss) from fair value Ineffectivene ss Financial line item in hedging inst rument the balance sheet change of hedg ing gain/(loss) Derivative the Income s tatement Hedging relati onship where the hedg ing instrument use d for recognized in the Type that include d hedge Assets Liabilit ies instrument is calculating the hedg e income statem ent ineffect iveness included effectivenes s for 2024 for 2024 Interest rate risk Bonds at a mortized cost (AC) 36 230 (65) 9 Corporate Loans 1 (2) Senior Bo nds issues 43 27 23 Tier II Bonds issues Interest 8 16 Derivat ive Financial 35 2 Gains less losses on rate swap Instruments 147 5 64 (1) First Demand Deposits Senior se curitisation bo nds, (4) classified as loans at 4 amortised cost FX rate risk Investment i n Alpha Bank Derivat ive Financial Gains less losses on FX Swaps (3) London in GBP Instruments financial transactions
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
311 | ANNUAL FINANCIAL REPORT
sheet where the hedged item is
D
sheet where the hedged item is
item used for calculating the
Group - 2024 Accumulated amou nt of Change in fair value of fair value hedge Carrying Amount Financial li ne item in the balance sheet hedged item us ed for Hedging relati onship adjustments on the h edged where the hedged i tem is included calculating the hed ge item effectiveness Assets Liabili ties Assets Liabili ties Interest rate risk Investment s ecurities measur ed at Bonds at a mortized cost (AC) 5,789 162 74 amortized co st Corporate Loan 244 1 Loans and adv ances to cust omers 2 Senior Bo nd issues 1,8 79 (6) Debt sec urities in issue and o ther (23) Tier II Bonds issues 1,1 24 (6) borrowed funds (32) First Demand Deposits 7,520 77 Due to Cust omers (65) Senior se curitisation bo nds, classified as Galaxy Seni or Bonds, classi fied as Loans 526 4 4 loans at a mortised cost at amortise d cost Securiti es measured at fair v alue through Securiti es measured at fair v alue 5 OCI through OCI Bank - 2025 Accumulated amou nt of fair Change in fair value of Financial li ne item in the balance Carrying Amount value hedge adjust ments on hedged item us ed for Hedging relati onship the hedged item calculating the hed ge included Assets Liabili ties Assets Liabili ties effectiveness Interest rate risk Investment s ecurities measur ed at (3 38) Bonds at a mortized cost (AC) 6,114 (162) amortized co st (12) Corporate Loan 238 (11) Loans and adv ances to cust omers Senior Bo nd issues 2,391 (6) ebt sec urities in issue and o ther Tier II Bonds issues 644 (2) borrowed funds (4) First Demand Deposits 8,174 24 Due to Cust omers 54 Senior se curitisation bo nds, classified as Galaxy Seni or Bonds, classi fied as 1,058 (15) (19) loans at a mortised cost Loans at amor tised cost FX rate risk Participat ion in Alpha B ank London in Investment i n subsidiarie s 59 3 (3) GBP Bank - 2024 Accumulated amou nt of fair Financial li ne item in the balance Change in fair value of hedged Carrying Amount value hedge adjust ments on Hedging relati onship the hedged item included hedge effectiveness Assets Liabili ties Assets Liabili ties Interest rate risk Investment s ecurities measur ed at Bonds at a mortized cost (AC) 5,789 162 74 amortized co st Corporate Loan 244 1 Loans and adv ances to cust omers 2 Senior Bo nd issues 1,888 (6) Debt sec urities in issue and o ther (23) Tier II Bonds issues 1,156 (6) borrowed funds (33) First Demand Deposits 7,520 77 Due to Cust omers (65) Senior se curitisation bo nds, classified as Galaxy Seni or Bonds, classi fied as 526 4 4 loans at a mortised cost Loans at amor tised cost Securiti es measured at fair v alue Securiti es measured at fair v alue 5 through OCI through OCI FX rate risk Participat ion in Alpha B ank London in Investment i n subsidiarie s 59 6 3 GBP
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
312 | ANNUAL FINANCIAL REPORT
b. Cash flow hedges
At 31.12.2025 the following cashflow hedge relationships are in effect:
Group Bank Duration 1 - 5 Duration 1 - 5 Risk Category years years Interest rate risk Loans with float ing rate at the amo unt of €200 Nominal amount of the deri vative 200 200 Average fixe d interest r ate 0.02% 0.02%
The balance sheet and the income statement amounts relating to open cash flow hedging relationships and the amortization of the reserve in
the current period that was formed at the date of termination of the cashflow hedge for term deposits are analyzed as follows:
Group - 31.12.2025 Carrying Change in fair value of Amounts reclas sified from Change in fair value of Income statement Amount hedging instru ment cash flow hedging r eserve to Derivative hedged item us ed for line affected by th e Hedging Relati onship recognized in ca sh flow the income statem ent in 2025 Type calculating the hed ge terminated hedgi ng hedging reserve in from terminated h edging Liabili ties effectiveness i n 2025 relationships 202 5 relationships Interest ra te risk Loans with floating rate at t he Interest 5 5 5 amount of €200 Net int erest income Rate Swap Term deposit s and renewal s (21) Bank - 31.12.2025 Carrying Change in fair value of Amounts reclas sified from Change in fair value of Income statement Amount hedging instru ment cash flow hedging r eserve to Derivative hedged item us ed for line affected by th e Hedging Relati onship recognized in ca sh flow the income statem ent in 2025 Type calculating the hed ge terminated hedgi ng hedging reserve in from terminated h edging Liabili ties effectiveness i n 2025 relationships 202 5 relationships Interest ra te risk Loans with floating rate at t he Interest 5 5 5 amount of €200 Net int erest income Rate Swap Term deposit s and renewal s (21)
The amounts that have been recognized in the cashflow hedge reserve at 31.12.2025 are analyzed as follows:
Group - 31.1 2.2025 Line item in the bal ance Cash flow hedgi ng reserve Cash flow hedgi ng reserve (before ta x) Cash flow hedgi ng sheet where the hedged (before tax) for act ive hedging for terminated h edging relationship s reserve (before ta x) item is included relationships Interest rate risk Loans with floating rate at t he Loans and adv ances to (5) (5) amount of €200 customers Term deposit s and renewal s Due to c ustomers (211) (211) Bank - 31.1 2.2025 Line item in the bal ance Cash flow hedgi ng reserve Cash flow hedgi ng reserve (before ta x) Cash flow hedgi ng sheet where the hedged (before tax) for act ive hedging for terminated h edging relationship s reserve (before ta x) item is included relationships Interest rate risk Loans with floating rate at t he Loans and adv ances to (5) (5) amount of €200 customers Term deposit s and renewal s Due to c ustomers (211) (211)
As at 31.12.2024 the following cashflow hedge relationships were in effect:
Group Bank Risk Category Duration 1 - 5 year s Interest rate risk Loans with float ing rate at the amo unt of €350 Nominal amount of the deri vative 35 0 350 Average fixe d interest r ate 0.02% 0.02%
The balance sheet and the income statement amount relating to open cash flows hedging relationships as at 31.12.2024 and the amortization
of the reserve in the corresponding period that was formed at the date of termination of the cashflow hedge for term deposits during the
previous period are analyzed as follows:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
313 | ANNUAL FINANCIAL REPORT
Group - 31.12.2024 Carrying Change in fair value of Amounts reclas sified from Change in fair value of Income statement Amount hedging instru ment cash flow hedging r eserve to Derivative hedged item us ed for line affected by th e Hedging Relati onship recognized in ca sh the income statem ent in 2024 Type calculating the hed ge terminated hedgi ng flow hedging re serve from terminated h edging Liabili ties effectiveness i n 2024 relationships in 2024 relationships Interest ra te risk Loans with floating rate at Interest 10 11 11 the amount o f € 350 Net int erest income Rate Swap Term deposit s and renewal s (2 1) Bank - 31.12.2024 Carrying Change in fair value of Amounts reclas sified from Change in fair value of Income statement Amount hedging instru ment cash flow hedging r eserve to Derivative hedged item us ed for line affected by th e Hedging Relati onship recognized in ca sh the income statem ent in 2024 Type calculating the hed ge terminated hedgi ng flow hedging re serve from terminated h edging Liabili ties effectiveness i n 2024 relationships in 2024 relationships Interest ra te risk Loans with floating rate at Interest 10 11 11 the amount o f € 350 Net int erest income Rate Swap Term deposit s and renewal s (2 1)
The amounts that have been recognized in the cashflow hedge reserve at 31.12.2024 are analyzed as follows:
31.12.2024 Line item in the bal ance Cash flow hedgi ng reserve Cash flow hedgi ng reserve (before ta x) Cash flow hedgi ng Group sheet where the hedged (before tax) for act ive hedging for terminated h edging relationship s reserve (before ta x) item is included relationships Interest rate risk Loans with floating rate at t he Loans and adv ances to (10) (10) amount of €350 customers Term deposit s and renewal s Due to c ustomers (2 32) (232) 31.12.2024 Line item in the bal ance Cash flow hedgi ng reserve Cash flow hedgi ng reserve (before ta x) Cash flow hedgi ng Bank sheet where the hedged (before tax) for act ive hedging for terminated h edging relationship s reserve (before ta x) item is included relationships Interest rate risk Loans with floating rate at t he Loans and adv ances to (10) (10) amount of €350 customers Term deposit s and renewal s Due to c ustomers (2 32) (232) c. Hedging of net i nvestment in foreign subsidiaries
The Group hedges part of the net investment in RON in the associate company Unicredit Romania S.A. through foreign exchange swap
derivatives. In addition, the Group hedges part of the net investment in GBP in the subsidiary Alpha Bank London through forward foreign
exchange derivative transactions that are renewed.
The hedging instruments as at 31.12.2025 and 31.12.2024 are summarized as follows:
Group 31.12.2025 31.12.2024 Nominal amount i n Currency Currency Nominal amount i n Euro Euro Investment in Alpha Bank London Duration < 1 yea r Duration < 1 yea r FX Swaps - EUR/GB P GBP 59 Exchange rate G BP/EUR 0.83 CCIRS - EUR/GBP GBP 77 Exchange rate G BP/EUR 0.87 Investment in sub sidiaries (RON) Duration < 1 yea r Fx Derivati ves RON 35 Exchange rate R ON/EUR 4.97 Investment in Subsidiaries (RON) 1-5 years Fx Derivati ves RON 10 Exchange rate R ON/EUR 4.97 Investment in Associates (RON) Duration < 1 yea r Fx Swaps and Cross Curr ency Inte rest Rate Swaps RON 303 Exchange rate R ON/EUR 4.97 Investment in Associates (RON) 1-5 years 1-5 years Fx Swaps and Cross Curr ency Inte rest Rate Swaps 26 RON 10 Exchange rate R ON/EUR 5.10 4.97
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
314 | ANNUAL FINANCIAL REPORT
The balance sheet and the income statement amounts relating to hedging of net investment in foreign subsidiaries and associates and the
effectiveness of the hedge are analyzed as follows:
Assets
Liabilities
Assets
Liabilities
Group - 31.1 2.2025 Line item in the Change in fair value of hedging Change in the fair value of the Change in the fair value of the balance sheet w here instrument for th e hedging instru ment recognized Hedging instru ment hedging instru ment recognized i n the hedge item is measurement of the hedge in the income state ment in the the reserve for t he year 2025 included effectiveness for the year 2025 year 2025 CCIRS - EUR/GBP 3 3 Derivat ives Fx swaps & CCIRS 1 5 5 Group - 31.1 2.2024 Line item in the Change in fair value of hedging Change in the fair value of the Change in the fair value of the balance sheet w here instrument for th e hedging instru ment recognized Hedging instru ment hedging instru ment recognized i n the hedge item is measurement of the hedge in the income state ment in the the reserve for t he year 2024 included effectiveness for the year 2024 year 2024 CCIRS - EUR/GBP (3) (3) Fx swaps & CCIRS 1 Derivat ives Fx swaps & CCIRS 2
The amounts related to hedged items as of 31.12.2025 and 31.12.2024 are analyzed as follows:
Group 31.12.2025 31.12.2024 Balance of foreign Change in fair Balance of foreign Foreign Foreign Change in fair value fo r the exchange differenc es value for the exchange differenc es Exchange Exchange measurement of the hedge reserve due to measurement of reserve due to differences differences effectiveness discontinued hed ging the hedge discontinued hed ging reserve reserve relationships effectiveness relationships Investment i n Alpha Bank London (3) (4) 3 (12) Investment i n subsidiarie s (RON) (1) 2 Investment i n Associates (R ON) (5) (7)
24.
Loans and advances to customers
The balance of “Advances to customers measured at fair value through profit or loss” mainly include the contingent considerations arising
from the completion of NPE portfolio sale transactions.
Increase in line “Advances to customers measured at amortized cost”, is primarily due to an increase in activity related to credit facilities, with
the provision of an early payment option to the supplier.
As at 31.12.2025 the gross balance of “Advances to customers measured at amortised cost” for the Group amounted to € 435 (31.12.2024: €
329) and the allowance for expected credit losses amounted to € 28 (31.12.2024: € 38).
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Loans measure d at amortise d cost 42,780 39,215 40,194 37,729 Leasing 203 198 2 3 Less: Allowanc e for expect ed credit losses (637) (601) (570) (570) Total 42,346 38,812 39,626 37,162 Advances to customers measure d at amortised c ost 407 291 367 246 Advances to customers measure d at fair val ue through profit or loss 568 595 345 357 Loans measure d at fair value through profi t or loss 162 127 162 116 Loans and advanc es to custo mers 43,483 39,825 40,500 37,881
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
315 | ANNUAL FINANCIAL REPORT
Loans measured at amortised cost
At Group level the acquisition of Astro Bank’s certain assets and liabilities, which was completed in 2025 contributed to an increase in loans
and advance to customers NBV of € 603.
Increase in the line “Senior Notes” compared to 31.12.2024 is driven by the securitisation of Gaia I and Gaia II transactions. On 6.6.2025 the
Bank completed the sale of the loan portfolios Gaia I and Gaia II by means of securitization transactions under Law 3156/2003 and the Greek
law on the guarantee program for securitizations of credit institutions (Law 4649/2019) as amended and in force as of 30.6.2023. More
specifically, the Bank transferred to the special purpose vehicles Gaia Securitisation Designated Activity Company and Gaia II Securitisation
Designated Activity Company loans with gross book value as at 6.6.2025 of € 465 Gaia I and € 568 Gaia II respectively that had been previously
classified as assets held for sale. As a result of the sale, the Bank recognized a loss of € 2, which was recognized in the line “Gains less losses
on derecognition of financial assets measured at amortized cost”. The Bank retained 100% of the Senior notes issued by the sp ecial purpose
vehicles as well as 5% of the mezzanine and junior notes, in accordance with the regulatory risk retention framework. The notes have been
also classified in Loans and Advances to customers in line “Senior Notes”. In “Loans portfolio measured at amortized cost” th e Group also
includes the senior notes of Galaxy and Cosmos transactions, which were completed during 2021. In addition, the Group holds a portfolio of
loans that have been securitized through special purpose entities controlled by the Group. As per the contractual terms and the structure of
the above transactions it is evident that the Group retains in all cases the risks and rewards arising from the securitized portfolios.
The Group assesses loan sales from the holding business model with the aim of collecting contractual flows and confirms that the sales made
do not affect this business model. It is mentioned that the Group possess loans that have been classified as “Assets Held for Sale”, as explained
in note 54.
The movement of allowance for expected credit losses on loans, that are measured at amortized cost, is presented below:
Allowance for expected credit losses
Group Bank Balance 1.1.2 024 842 793 Changes for the year 1.1. - 3 1.12.20 24 Impairment loss es for the y ear 297 278 Transfer o f allowance for e xpected credit l osses from / (to) Ass ets held for sale (397) (3 61) Change in prese nt value of t he impairment losses 8 7 Foreign excha nge difference s (2) Loans writ ten-off during the year (148) (147) Other move ments 1 Balance 31.12.2024 601 570 Changes for the year 1.1 - 31.12.2025 Impairment loss es for the y ear 258 255 Transfer o f allowance for e xpected credit l osses from / (to) Ass ets held for sale (99) (128) Change in prese nt value of t he impairment losses 5 3 Loans writ ten-off during the year (139) (139) Other move ments 11 9 Balance 31.12.2025 637 570
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Individual s Mortgages - Non-securitized 5,262 5,165 4,374 4,560 - Securitized 1,698 1,719 1,698 1,719 Consumer: - Non-securitized 905 768 789 704 - Securitized 390 435 390 435 Credit car ds: - Non-securitized 390 368 379 362 - Securitized 473 494 473 494 Other 6 5 Total loans to i ndividuals 9,124 8,954 8,103 8,274 Corporate: Corporate loans: - Non-securitized 26,418 23,172 25,791 23,197 - Securitized 520 580 519 580 Leasing: - Non-securitized 203 198 2 2 Factoring 937 831 Senior Not es 5,076 4,903 5,076 4,903 CLOs (note 2) 705 775 705 775 Total corporate loan s 33,859 30,459 32,093 29,458 Total 42,983 39,413 40,196 37,732 Less: Allowanc e for expect ed credit losses (637) (601) (570) (570) Total loans measur ed at amortise d cost 42,346 38,812 39,626 37,162
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
316 | ANNUAL FINANCIAL REPORT
“Impairment losses for the year” 2025 presented in the table above for the Group, differ from the amount presented in line “Impairment
losses/(gains) on loans” of note 12 mainly due to:
a. A loss of € 39 related to loan portfolios that have been classified as held for sale.
b. A gain of € 3 related to fair value adjustment of the contractual balance of loans which were impaired at their acquisition or
origination (POCI) is not included. This adjustment does not impact the accumulated impairments since it is included in the gross
carrying value of the loans.
Finance lease receivable is analyzed by duration as follows:
The net amount of finance lease receivables are analyzed as follows, based on their duration:
Loans measured at fair value through profit or loss
During 2025 the Group sold loans amounting € 0 (2024: € 313) which were held within the “hold to sell” business model.
25.
Investment securities
An analysis of investment securities is provided in the following tables per classification category, per type of security.
a. Investment securities measured at fair value through other comprehensive income
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Up to 1 year 48 34 1 1 From 1 year t o 5 years 136 139 1 2 Over 5 ye ars 40 73 224 246 2 3 Non accrue d finance lease i ncome (21) (48) Total 203 198 2 3
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Up to 1 year 41 28 1 1 From 1 year t o 5 years 126 124 1 2 Over 5 ye ars 36 46 Total 203 198 2 3
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Corporate: - Non-securitized 160 126 160 115 Galaxy and Cos mos mezzanine and ju nior n otes 1 1 1 1 Gaia mezzanine and junior n otes 1 1 Total corporate loan s 162 127 162 116 Total loans to custo mers measure d at fair val ue through profit or los s 162 127 162 116
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Investment Se curities measur ed at fair value t hrough other compre hensive inco me 1,157 1,009 1,083 935 Investment Se curities measur ed at fair value t hrough profit or loss 237 167 226 158 Investment Se curities measur ed at amortized co st 16,176 15,645 14,469 14,708 Total 17,570 16,821 15,778 15,802
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Greek G overnment: - Bonds 294 233 294 233 - Treasury bil ls 537 539 537 539 Other Go vernments: - Bonds 181 143 146 104 Other i ssuers: - Listed Bo nds 92 54 82 43 Equity sec urities: - Listed 25 17 17 13 - Non liste d 28 23 7 3 Total 1,157 1,009 1,083 935
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
317 | ANNUAL FINANCIAL REPORT
Investment portfolio equity securities measured at fair value through other comprehensive income
The Group has made the irrevocable election on initial recognition to measure at fair value through other comprehensive income equity
instruments that have the following characteristics:
a) Shares in companies of the financial sector (credit institutions and interbank companies and interbank companies),
b) Investments in private equity (shares of venture capital or private equity),
c) Equity shares received in exchange for debt forgiveness in the context of debt restructurings and
d) Shares held in the long term investment horizon.
The following table presents the equity shares of investment portfolio measured at fair value through other comprehensive income as of
31.12.2025 and as of 31.12.2024.
Fair Value Dividend income from 1.1 to Fair Value Dividend income from 1.1 to Group 31.12.2025 31.12.2025 31.12.2024 31.12.2024 Investments in financial indus try entities 10 1 6 1 Investments in private equit y 15 16 Equity shar es received in e xchange for debt forgiveness i n 3 1 the cont ext of debt restructur ings Long term equi ty holdings 25 1 17 1 Total 53 2 40 2 Fair Value Dividend income from 1.1 to Fair Value Dividend income from 1.1 to Bank 31.12.2025 31.12.2025 31.12.2024 31.12.2024 Investments in financial indus try entities 3 Long term equi ty holdings 18 1 15 1 Equity shar es received in e xchange for debt forgiveness i n 3 2 the cont ext of debt restructur ings Total 24 1 17 1
During 2025 the participation in the long term equity holdings “Akritas S.A” was derecognized at a Bank and Group level as it was sold with a
fair value of € 1 at the date of derecognition. The cumulative loss recognized in equity amounted to € 3.
b. Investment securities measured at amortized cost
Group 31.12.2025 31.12.2024 Before Amortized Before Impairment Impairment Amortized Cos t impairment Cost impairment Greek G overnment: - Bonds 7,721 (8) 7,713 7,997 (8) 7,989 - Treasury bil ls Other G overnments: - Bonds 4,934 (2) 4,932 4,354 (3) 4,351 Other i ssuers: - Listed 3,538 (7) 3,531 3,312 (8) 3,304 - Non-Listed 1 1 Total 16,193 (17) 16,176 15,66 4 (19) 15,645 Bank 31.12.2025 31.12.2024 Before Amortized Before Impairment Impairment Amortized Cos t impairment Cost impairment Greek G overnment: - Bonds 7,567 (8) 7,559 7,903 (8) 7,895 - Treasury bil ls Other G overnments: - Bonds 3,965 (2) 3,963 3,913 (3) 3,910 Other i ssuers: - Listed 2,953 (6) 2,947 2,911 (8) 2,903 - Non-Listed 1 1 Total 14,485 (16) 14,469 14,728 (19) 14,709
The Group and the Bank evaluates sales from the hold to collect business model aiming to collect the contratual cash flows and confirms that
the sales made do not affect this business model.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
318 | ANNUAL FINANCIAL REPORT
c. Investment securities measured at fair value through profit or loss
26.
Investments in subsidiaries, associates and joint ventures
Α. INVESTMENTS IN SUBSIDIARIES
The table below presents the movement in Investment in Subsidiaries for 2025 and 2024 at a Bank level:
Bank
2025
2024
Opening Balance 1.1.
2,632
2,439
New Subsidiaries
88
53
Additions due to Reverse Merger
16
(Returns) / Share Capital Increases / Stock option rights and stock awards
192
86
(Impairments)/ Reversal of impairments
161
52
Valuation of investments due to fair value hedging and other movements
*
(3)
2
Closing Balance 31.12.
3,086
2,632
During 2025 the Bank established the subsidiaries ABINVEST I S.M.S.A. and ABINVEST III S.M.S.A with an initial capital of € 74 and € 14,
respectively.
The line “Additions due to Reverse Merger” refers to Alpha Services and Holdings S.A. subsidary Alpha Life, which was transferred to Alpha
Bank at the Reverse Merger date with an amount of € 16.
The line “(Returns) / Share Capital Increases / Stock option rights and stock awards” refers to the:
- Return of Capital from Alpha Life of € 11, which corresponds to the portion that is classified as a subsidiary (49%)
- Share capital increase in ABINVEST I S.M.S.A of € 78
- Share capital increase in ABINVEST II S.M.S.A of € 75
- Share capital increase in ABINVEST I II S.M.S.A of € 30
- Share capital increase in Alpha Holdings S.A. € 20
The line “(Impairments)/ Reversal of impairments” for the subsidiaries is analysed in the tables below:
2025
Company Name
Impairment /
Reversal
Conditions
Impairment
/ (Reversal)
amount
Recoverable
amount
Determination of Recoverable
amount
Fair Value
Hierarchy
Level
Valuation
Methodology
Key Assumptions
Alpha Bank
London Ltd
Deterioration of
valuations in
the peer
banking sector
9
46
Fair Value
Level 3
Multiples
Method
Selection of companies to
estimate representative P/B
ratio of the sector.
Alpha Real Estate
Management and
Investment S.A
Dividend
collection
(5)
311
Adjusted Net
Asset Value
(NAV)
Adjusted NAV of Alpha
Holding’ s participation/
Selection of companies to
estimate representative P/B
ratio of the sector of each
subsidiary of Alpha Holding.
Alpha Group
Investment Ltd
Revaluations of
its real estate
assets
(21)
756
Adjusted Net
Asset Value
(NAV)
Valuation of the individual
assets considering the most
recent property valuation
reports.
Alpha Support
Operations
The company's
financial
performance.
2
42
Accounting
Net Asset
Value (NAV)
Recoverable amount of
intangible assets (software).
Alpha Holding S.A
Deterioration in
investment
valuations
6
287
Adjusted Net
Asset Value
(NAV)
Selection of companies to
estimate representative P/B
ratio of the sector of each
subsidiary of Alpha Holding.
Alpha
International
Holdings S.M.S.A.
Ιmprovement in
banking sector
investment
valuations
(151)
1.281
Adjusted Net
Asset Value
(NAV)
Selection of companies to
estimate representative P/B
ratio and Present value of the
future profits of its subsidiaries
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Other i ssuers: - Listed 10 10 10 10 - Non liste d 1 Equities se curities - Listed 129 67 130 67 - Non liste d 75 70 66 63 Other v ariable yield securiti es 22 20 20 18 Total 237 167 226 158
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
319 | ANNUAL FINANCIAL REPORT
2024
Company Name
Impairment /
Reversal Conditions
Impairment /
(Reversal)
amount
Recoverable
amount
Determination
of Recoverable
amount
Fair Value
Hierarchy
Level
Valuation
Methodology
Key Assumptions
Alpha Bank
London Ltd
Deterioration of
valuations in the
peer banking sector
5
58
Fair Value
Level 3
Multiples
Method
Selection of companies
to estimate
representative P/B ratio
of the sector
Alpha Real Estate
Management
and Investment
S.A
Improvement in
valuation of direct
investment in Alpha
Holding S.A
(11)
306
Adjusted Net
Asset Value
(NAV)
Selection of companies
to estimate
representative P/B ratio
for Alpha Holding S.A.'s
equity investments
Alpha Support
Operations
Impact of Unicorn
transaction
(1)
44
Accounting
Net Asset
Value (NAV)
Recoverable value of
intangible assets
(software)
Alpha Holding
S.A
Dividend collection &
improvement in
financial sector
investment
valuations
(11)
273
Adjusted Net
Asset Value
(NAV)
Selection of companies
to estimate
representative P/B ratio
for the company's
holdings
Alpha
International
Holdings S.M.S.A.
Completion of
Unicorn transaction
& improvement in
banking sector
investment
valuations
(71)
1,129
Adjusted Net
Asset Value
(NAV)
Valuation of holdings,
selection of companies
to estimate
representative P/B ratio
for the company's
holdings
The (Impairments)/Reversal of impairments of the subsidiaries have been estimated based on their fair values. The valuations are classified in
level 3 since the non-observable market prices were used for their measurement.
The recoverable amount of the subsidiaries was determined as fair value less costs to sell, applying the appropriate valuation methodology in
each case from the following, depending on the characteristics of the investment under review:
− Multiples Method: Applied to unlisted investments in sectors where sufficient observable market data from active market
companies with similar business activities are available, using the “average” or “median” P/B ratio derived from a representa tive
sample of companies in the sector
− Adjusted Net Asset Value (NAV): Applied to holding companies with investments or real estate assets, adjusting their accounting
figures to reflect the fair value of their properties/investments to estimate the fair value of their net assets
− Accounting Net Asset Value (NAV): Applied to investments (a) that measure their assets at fair value, or (b) for which no
representative data of their fair value is available beyond their accounting figure.
The key financial information of Bank’s investments in subsidiaries are as follows:
Balance 31.12.2025
1.1 – 31.12.2025
Name
Country
Assets
Equity
Liabilities
Turnover
Profit / Loss
before income
tax
Bank ownership
interest%
Banks
1. Alpha Bank London Ltd
Un.Kingdom
626
77
549
49
(3)
100.00
Leasing companies
1. Alpha Leasing Romania IFN S.A.
Romania
1
-
Insurance
1. Alphalife A.A.E.Z.
Greece
1,340
81
1,260
25
16
99.92
Real Estate and Hotel
1. APE Fixed Assets S.A.
Greece
42
41
1
72.20
2. ABINVEST I S.M.S.A.
Greece
182
153
29
2
2
100.00
3. ABINVEST IΙ S.M.S.A.
Greece
146
128
18
2
100.00
4. ABINVEST IIΙ S.M.S.A.
Greece
44
44
100.00
Special purpose and holding entities
1. Alpha Group Investments Ltd
Cyprus
677
675
2
4
3
100.00
2. Alpha Real Estate Management and Investments S.A.
Greece
312
311
1
11
6
100.00
3, Epihiro Plc
Un.Kingdom
4. Pisti 2010-1 Plc
Un.Kingdom
5. AGI-Cypre Ermis Ltd
Cyprus
4
4
100.00
6. Alpha International Holdings S S.M.S.A.
Greece
1,054
1,033
21
62
32
100.00
7. Alpha Holdings S.M.S.A.
Greece
525
521
4
1
8
51.00
8. Gemini Core Securitisation Designated Activity Company
Ireland
Other companies
1. Kafe Alpha S.A.
Greece
2. Alpha Supporting Services S.A.
Greece
44
42
2
9
(3)
100.00
3. Emporiki Management S.A.
Greece
3
3
100.00
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
320 | ANNUAL FINANCIAL REPORT
B. INVESTMENTS IN ASSOCIATE COMPANIES AND JOINT VENTURES
The table below presents the movement in Investments in Associates and Joint Ventures at a Group and Bank level:
Group Bank 2025 2024 2025 2024 Opening Balance 1.1. 571 100 129 76 New associ ates / Joint ventur es 414 Dividend s (16) (8) (Returns) / Shar e Capital Inc reases (27) 63 (27) 58 Impairments (5) (3) (5) Share of pr ofits/(losses) a nd other comprehensive income 45 2 Fair Value a djustment 12 FX Translation difference s (4) Closing Balance 3 1.12. 576 57 1 99 129
Group
Group’s share on equity Fr om 1 J anu ary to 31.12.2025 31.12.2024 a. Associates Bank Info rmation Systems S.A. 3 Nexi Gre ece Payments Instit utions S.A. 27 32 Alpha Invest ment Propert y Elaionas S.A 60 59 Cepal Holdings S.A. 9 38 Perigenis Com mercial Prope rty S.A. 14 15 Toorbee Trav el Services Li mited 1 Skyline Pr operties M.S.A. 86 83 Alpha Bank R omania S.A. 54 UniCredit Bank S.A. 360 275 Total (a) 559 55 7 b. Joint ventures APE Commerci al Propert y Α.Ε. 5 4 Alpha ΤΑΝΕΟ A.K.E.S. 4 4 Panarae Saturn LP 1 2 Alpha Invest ment Propert y Commercial Stor es S.A. 7 4 Total (b) 17 14 Total (a+b) 576 57 1
At Group level the movements for 2025, besides the share of profits mainly regards :
• Dividend receipt of € 16 (€ 14 from UniCredit Bank S.A., € 2 from Cepal).
• Return of share capital of € 27 (return of € 31 of Cepal S.A., increase of share capital of € 4 in Bank Information Systems S.A. (Tiresias
S.A.)
• Impairment of € 5, mainly related to an impairment of € 3 in Nexi Greece Payments Institutions S.A (note 14), and is reported within
the “Corporate Center/Elimination Center” segment for operating segment disclosure purposes (see Note 48).
• Fair Value Adjustment of € 12, from a gain relating to the valuation of equity instruments.
The companies over which the Group exercises significant influence or joint control are presented in detail in note 46. The table below
presents the book value of each associate and joint venture which the Group consolidates using the Equity method.
Other information for associates and joint ventures and significant restrictions
With the exception of Group’s participation in Olganos S.A. which is fully impaired, and the Group has ceased recognizing its participation,
there are no other cases where the Group has seized such recognition of losses.
With respect to any contingent liabilities of the Group related to its participation in associates or joint ventures or significant unrecognized
commitments of the Group that could lead to a future outflow of cash or other resources, the only case concerns the contractual texts of the
Skyline Properties M.S.A transaction, which stipulate that for a period of 3 years after the closing of the Skyline transaction, if Skyline
Properties M.S.A. has not completed the sale of the properties whose development strategy is "sale", then Skyline Properties M.S.A. will have
the right to sell to the Group the remaining properties of this strategy, which, however, may not cumulatively exceed € 15 in terms of prices
at which the initial recognition of these properties from the Group to Skyline Properties M.S.A took place. These sales will be made at prices
that will incorporate a surcharge of 20% compared to the prices at which the initial recognition of these properties from the Group to Skyline
Properties M.S.A took place.
There are no significant restrictions for the associates or joint ventures to transfer capital in the Group or to repay the loans that have been
granted by the Group apart from the restrictions imposed by the regulatory framework in which supervised associates operate in terms of
their capital adequacy and the restrictions that apply by Law 4548/2018 for Greek companies in connection with the minimum required share
capital and equity and the ability to distribute dividends.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
321 | ANNUAL FINANCIAL REPORT
Investments in significant associates and joint ventures
The Group assessed as significant the associates presented in the table below, by taking into account the activities that are considered to be
of strategic importance, as well as the carrying amount of the Group’s participation in the companies and of the loans and receivables that are
part of the Group’s net investment in the companies, if any. There is no joint venture of the Group that has been assessed as significant.
Significant Associ ate Operation Country UniCredit Bank S.A. Bank Romania Skyline R eal Estate S.M.S.A. Real est ate management Greece Cepal Holdings S.A. Management of claims from loan s and credits Greece A IP Elaionas S.A. Real est ate management Greece Nexi Gre ece Payments Instit utions S.A. Other mone tary intermedi ation services Greece
Associates of the above table are not listed in any market and there is no direct observation for their fair value. On 15.8.2025, the merger of
Alpha Bank Romania S.A. with UniCredit Bank S.A. (“UniCredit Romania”) was completed, forming a single banking entity in whic h Alpha
International Holdings S.A., a wholly-owned subsidiary of the Bank, holds a 9.9% stake. The merger lacked economic substance for the Group
and therefore had no financial impact on the consolidated financial statements
Below there is a summary of the condensed financial information of the above mentioned companies.
Nexi Cepal AIP Greece Skyline Unicredit Bank Condensed Stat ement of Total Comp rehensive Inco me 31.12.2025 Holdings Elaionas Payments Group S.A. S.A. S.A. Institutions S.A.. Interest and similar inco me 928 Fee and commissi on income 142 194 Other i ncome 226 3 15 101 Profit/(Losses) befo re income tax 37 2 (6) (11) 409 Profit/(Losses) for th e year 28 2 (11) (11) 341 Total comprehensi ve income after in come tax 28 2 (11) (11) 341 Amount attr ibuted to the participation of the Group to profits/(losses) of the associate 6 1 (1) (1) 34 For the rest associate companies not presented in the condensed statements, the aggregated amount of its share of profit afte r tax
consolidated to € 3 for 2025.
Nexi Greece AIP Elaionas Payments Skyline Condensed Bal ance Sheet 31.12.2025 Cepal Holdings S.A. Unicredit Bank S.A. S.A. Institutions Group S.A. ASSETS Cash and balanc es with ce ntral banks 48 1 10 5.364 Due from ban ks 1 Derivat ive financial ass ets 32 Loans and adv ances to cust omers 12.602 Investment s ecurities 3.107 Other ass ets 3 40 119 292 24 4 916 Assets Held for Sale 2 2 Total Assets 3 40 11 9 340 3 56 22.024 LIABILITIES Due to ban ks 2.284 Derivat ive financial liabi lities 28 Due to c ustomers 14.6 36 Debt sec urities in issue and o ther borrowed f unds 63 1.913 Liabilitie s for current inco me tax 16 Other liabi lities 247 1 75 55 568 Total Liabi lities 247 1 75 118 19.445 EQUITY 93 118 265 238 2.5 79 Total Liabi lities and Equity 340 119 340 356 22.024 Group par ticipation (%) 20.00% 50.00% 9.99% 35.00% 9.90% Equity shar eholding 19 59 27 820 25 5 Valuation adjustments at initi al recognitio n (10) 3 4 105 Impairments (3) Impact of cha nge in accounting po licy 1 Net investment 9 60 27 86 360
Within the reporting period, the Group received a dividend of € 14 from the associate company Unicredit Bank S.A. and € 2 from Cepal
Holdings S.A..
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
322 | ANNUAL FINANCIAL REPORT
AIP Nexi Greece Alpha Bank Cepal Holdings Skyline Unicredit Condensed Stat ement of Total Comp rehensive Inco me 31.12.2024 Elaionas Payments Romania S.A.Group Bank S.A.S.A.Institutions S.A.S.A.Interest and similar inco me 152 46 Fee and commissi on income 141 31 7 Other i ncome 203 2 5 Profit/(Losses) befo re income tax 28 (4)(8)--30(47) Profit/(Losses) for th e year 23 (4)(14)--26(41) Total comprehensi ve income after in come tax 23 (4)(14)--26(41) Amount attr ibuted to the participation of the Group to profits/(losses) of 5 (2) (1) 3 (4) the assoc iate AIP Nexi Greece Alpha Bank Cepal Skyline Unicredit Condensed Bal ance Sheet 31.12.2024 Elaionas Payments Romania Holdings S.A. Group Bank S.A. S.A. Institutions S.A. S.A. ASSETS Cash and balanc es with ce ntral banks 45 106 3,922 450 Due from ban ks 37 499 Derivat ive financial ass ets 33 Loans and adv ances to cust omers 7,712 3,129 Investment s ecurities 2,668 354 Other ass ets 352 11 6 325 242 217 87 Total Assets 352 116 370 348 14,590 4,520 LIABILITIES Due to ban ks 490 104 Derivat ive financial liabi lities 32 Due to c ustomers 10,618 3,575 Debt sec urities in issue and o ther borrowed f unds 1,327 307 Liabilitie s for current inco me tax 10 Other liabi lities 118 73 119 370 87 Total Liabi lities 118 - 73 119 12,848 4,073 EQUITY 234 116 297 229 1,743 446 Total Liabi lities and Equity 352 116 370 348 14,590 4,520 Group par ticipation (%) 20.00% 50.00% 9.99% 35.00% 9.90% 9.90% Equity shar eholding 47 58 30 80 173 44 Valuation adjustments at initi al recognitio n/impairments (9) 2 44 102 10 Net investment 38 58 32 84 275 54
Bank
At a Bank level during 2025 there was a return of capital of € 31 from the associate company Cepal S.A as well as share capital increase of € 4
on the associate company Bank Information Systems S.A. (Tiresias S.A.).
The following tables present information regarding, the line “(Impairments)/Reversal of impairments” of the associates at Bank level.
2025 Impairment/ Impairment Recoverable Determination of rec overable Fair value Valuation Company name Reversal /(Reversal) Key assumption s amount amount hierarchy level methodology conditions amount Nexi Gre ece Decrease in Net Accounting Valuation based on accounting Payments Asset Value 2 27 Fair Value Level 3 Net Asset net positi on as a good Institutions S.A. (NAV) Value (NAV) approximatio n of fair value. 2024 Impairment/ Determination Fair value Impairment/ Recoverable Valuation Company name (Reversal) of recoverable hierarchy Key assumption s Reversal conditi ons amount methodology amount amount l evel Valuation based on Accounting Cepal Holdings Increase i n Net Asset accounti ng net position (4) 40 Fair Value Level 3 Net Asset A.E Value (NAV) as a good appr oximation Value (NAV) of fair value Valuation based on Accounting Nexi Payments Decrease in Net accounti ng net position 2 29 Fair Value Level 3 Net Asset Hellas S.A. Asset Value (NAV) as a good appr oximation Value (NAV) of fair value Valuation based on Alpha Invest ment Accounting Decrease in Net accounti ng net position Property Eleona 7 50 Fair Value Level 3 Net Asset Asset Value (NAV) as a good appr oximation S.A Value (NAV) of fair value
The (Impairments)/Reversal of impairments of the associates have been estimated based on their fair values. The valuations are classified in
level 3 since the non-observable market prices were used for their measurement.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
323 | ANNUAL FINANCIAL REPORT
The recoverable amount of the associates was determined as fair value less costs to sell, applying the appropriate valuation methodology in
each case from the following, depending on the characteristics of the investment under review:
− Adjusted Net Asset Value (NAV): Applied to holding companies with investments or real estate assets, adjusting their accounting
figures to reflect the fair value of their properties/investments to estimate the fair value of their net assets
− Accounting Net Asset Value (NAV): Applied to investments (a) that measure their assets at fair value, or (b) for which no
representative data of their fair value is available beyond their accounting figure.
The key financial information of Bank’s investments in associates and joint ventures are as follows:
a. Associates
Balance 31.12.2025 1.1–31.12.202 5 Profit/Loss Bank ownership Company name Country Assets Equity Liabili ties Turnover before income interest% tax 1. AEDEP Thessal ias and Ster eas Ellados Greece 2 2 1 50.00 2. Bank Info rmation Syste ms S.A. Greece 23 (2) 25 18 (2) 23.77 3. Olganos S.A. Greece 7 3 4 (1) 30.69 4. Cepal Holdings S.A. Greece 340 247 93 226 37 20.00 5. Nexi Gree ce Payments Inst itutions S.A. Greece 340 75 265 144 (2) 9.99 6. Aurora SME I DA C Ireland 23 3 20 7 1 7. REOCO Solar S.A. Greece 26.46 8. AEP Ε leona S.A. Greece 119 1 118 2 50.00 9. Alpha Compass Desi gnated Activi ty Company Ireland 184 184 20 10. Alpha Blue Designated Act ivity Company Ireland 130 130 19
b. Joint Ventures
Balance 31.12.2025 1.1–31.12.202 5 Profit/Loss Bank ownership Company name Country Assets Equity Liabili ties Turnover before income interest% tax 1. APE Commercial Property S.A. Greece 6 6 72.20 2. APE Investment Property S.A. Greece 100 62 38 9 (2) 71.08 3. Alpha TANEO A.K.E.S. Greece 10 9 1 1 1 51.00 4. ISIDE SPV Srl Italy 98 98 8
27.
Investment property
Group Bank Land– Right of use on land Land– Right of use on land Total Total Buildings and buildings Buildings and buildings Balance 1.1.2024 298 3 301 62 3 65 Impact from cha nge in account ing policy 29 1 30 4 4 Balance 1.1.2024 as r estated 327 4 331 66 3 69 1.1-31.12.2024 Additions 24 1 25 1 1 Gain/(Losse s) from valuatio n (2) (2) (4) 3 (1) 2 Disposals/Wr ite-offs (28) (28) (1) (1) Reclassifi cation from/(to) "Asse ts held for s ale" (1) (1) 3 3 Balance 31.12.2024 a s restated 320 3 323 72 2 74 1.1-31.12.2025 Balance 1.1.2025 320 3 323 72 2 74 Additions 287 22 309 - Reclassifi cation from/(to) "Prope ry, plant and equ ipment" (7) (7) - Reclassifi cation from/(to) " Ot her Assets " (38) (38) (3) (3) Reclassifi cation from/(to) " Asset s held for s ale " (2) (2) - Disposals/Wr ite-offs (19) (19) - Gain/(Losse s) from valuatio n 9 (1) 8 2 (1) 1 Balance 31.12.2025 5 50 24 574 71 1 72
Following the Group’s decision to broaden its portfolio of investment properties at the Group level achieving higherlevels of the related
income from such investments the Group has revised its accounting policy for investment properties. The change of accounting policy has
been applied retrospectively, resulting in the restatement of comparative figures, and and has positively impacted the Group’s equity by Euro
28 million as of 31 December 2024, arisig from the fair value measurement of investment properties.
In line "Additions," € 309 relates to acquisitions of investment properties during 2025 (31.12.2024: €24), of which € 198 pertains to the
acquisition of new companies (note 56).
The fair value of the investment property is calculated in accordance with the methods mentioned in note 1.2.7 and are classified, in terms of
fair value hierarchy, in Level 3 since assumptions and inputs relating to properties of relevant characteristics are used for the determination of
fair value and therefore encompass a wide range of unobservable market inputs. The valuation is performed by and independent external
evaluators.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
324 | ANNUAL FINANCIAL REPORT
The capitalization rate used ranges between 7.5% and 12%.
The Group, as a lessor of buildings owned by third parties, recognizes rental income in the results of the period.
Future receipts from operating leases are as follows:
28.
Property plant and equipment
Group Bank Land and Right of use on Land and Right of use on Equipment Total Equipment Total building s fixed assets building s fixed assets Balance 1.1.2024 36 3 56 82 501 334 51 85 470 Acquisiti on Cost 560 493 176 1,229 668 446 176 1,2 90 Accumulated depreciation and impairment loss es (197) (437) (94) (728) (334) (395) (9 1) (820) 1.1-31.12.2024 Net book value 1.1.2024 363 56 82 501 334 51 85 470 Additions 16 9 18 43 16 8 15 39 Disposals/Wr ite-offs/Terminat ions/Reassessment s / (4) (1) 17 12 17 17 Destruc tions Reclassifi cation from/(to) "Ot her Assets” (1) (1) (1) (1) Reclassifi cation to "Assets he ld for sale" 21 21 19 19 Depreci ation charge for t he year (10) (14) (18) (42) (9) (13) (22) (44) Net Book value 31.12.2024 385 50 99 534 359 46 95 500 Balance 31.12.2024 Acquisiti on Cost 591 495 207 1,293 702 448 19 4 1,344 Accumulated depreciation and impairment loss es (206) (445) (108) (759) (343) (402) (99) (844) 1.1-31.12.2025 Net book value 1.1.2025 385 50 99 534 359 46 95 500 Additions 55 19 19 93 33 19 11 63 Disposals/Wr ite-offs/Terminat ions/Reassessment s/ 12 12 12 12 Destruc tions Reclassifi cation from/(to) "Ot her Assets” 1 1 - Reclassifi cation from/(to) "Invest ment Proper ty" 7 7 - Depreci ation charge for t he year (11) (13) (28) (52) (10) (12) (24) (46) Net Book value 31.12.2025 437 56 102 595 382 53 94 529 Balance 31.12.2025 Acquisiti on Cost 65 1 510 237 1,398 735 46 7 21 7 1.4 19 Accumulated depreciation and impairment loss es (214) (454) (135) (803) (353) (414) (123) (8 90)
Item «Disposals/Write-offs/Terminations/Reassessments» of Rights-of-use on fixed assets includes rent adjustments and contract time.
Collumn “Land and Buildings” as at 31.12.2025, includes Assets under construction of € 33 (31.12.2024: € 10).
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 - Up to 1 year 19 9 2 3 -From 1 year to 5 years 62 18 10 4 -Over 5 year s 100 5 3 1 Total 181 32 15 8
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
325 | ANNUAL FINANCIAL REPORT
29.
Goodwill and other intangible assets
Group Bank Software Goodwill Other intangible Total Software Other intangible Total Balance 1.1.2024 467 - - 467 450 - 450 Acquisiti on Cost 1,074 126 1,200 944 124 1,068 Accumulated depreciation and impairment loss es (607) (126) (733) (495) (124) (618) 1.1. - 31.12.2024 Net book value 1.1.2024 467 - - 467 450 - 450 Additions 109 109 93 93 Disposals/Wr ite-offs (2) (2) - Amortization charge for t he year (127) (127) (117) (1 1 7) Impairment loss es for the y ear (9) (9) (7) (7) Net book value 31.1 2.2024 4 38 - - 438 419 - 419 Balance 31.12.2024 Acquisiti on Cost 1,104 126 1,230 998 124 1,122 Accumulated depreciation and impairment loss es (666) (126) (792) (579) (124) (703) 1.1. - 31.12.2025 Net book value 1.1.2025 438 - - 438 419 - 419 Additions 107 83 6 196 100 100 Transfer 3 3 - Disposals/Wr ite-offs (3 7) (3 7) (33) (33) Amortization charge for t he year (80) (80) (76) (76) Impairment loss es for the y ear (4) (4) (1) (1) Net Book value 31.12.2025 427 83 6 516 409 - 409 Balance 31.12.2025 Acquisiti on Cost 1,088 83 132 1,303 1,010 124 1,134 Accumulated depreciation and impairment loss es (661) (126) (787) (601) (124) (725)
Goodwill recognition relates to the result of the acquisition of new subsidiaries. (note 56)
Software “Additions” line for the current year relates mainly to the purchase of license and software implementations of the Bank.
More specifically, an amount of € 16 (31.12.2024: € 12) is included, which is related to internally produced software applications.
The amortization charge for the year corresponding to the internally produced software applications amount to € 11 (31.12.2024: € 19).
Other intangible additions of the year ending 31.12.2025 of amount € 6 of the Group, relate to intangible assets of subsidiaries acquired
within the reporting period. (note 56)
Line “Disposals / Write-offs” for the period mainly related to write offs of Intangible assets with NBV of € 34, which
no benefits were expected from their use.
30.
Deferred tax assets and liabilities
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Assets 4,816 4,807 4,812 4,7 68 Liabilitie s (35) (18) Total 4,781 4,789 4,812 4,7 68
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
326 | ANNUAL FINANCIAL REPORT
Deferred tax assets and liabilities are analyzed as follows:
Companies
31.12.2025
31.12.2024
31.12.2025
1.1-31.12.202 5 Recognised in Group Balance Acquistion of Balance Income 1.1.2025 Equity Statement Debit diff erence of Law 4046/201 2 757 (4 5) 71 2 Debit diff erence of Law 4465/201 7 2,772 (50) 2,722 Write-offs, de preciation, i mpairment of plant, property and equi pment and leases an d valuation of 75 (37) (13) 25 Investment Pr operties Loan port folio 816 (49) 766 Valuation of loans due to he dging - 4 4 Employee def ined benefit and insurance funds 6 1 7 Valuation of derivatives fi nancial instruments / Valua tion cash flo w hedge reserve (6) (96) (7) (109) Valuation of liabilities t o credit institutio ns and other bo rrowed funds due to f air value hedge 10 (13) (3) Valuation/Impai rment of inv estments 147 (2) 14 5 Valuation/Impai rment of debt securities and ot her securities 122 1 11 6 23 9 Tax losses car ried forwar d 2 207 1 210 Other tempor ary differe nces 94 (6) (18) (2) 68 Currency t ranslation differ ences from financi al statements an d net investment he dging of foreign (6) (6) operati ons Total 4,789 25 (19) (14) 4,7 81 1.1-31.12.202 4 Recognised in Group Balance Balance Income 1.1.2024 Equity Statement Debit diff erence of Law 4046/201 2 802 (45) 757 Debit diff erence of Law 4465/201 7 2,942 (170) 2,772 Write-offs, de preciation, i mpairment of plant, property and equi pment and leases an d valuation of Inve stment 98 (23) 75 Properti es Loan port folio 717 99 816 Employee def ined benefit and insurance funds 5 1 6 Valuation of derivatives fi nancial instruments / Valua tion cash flo w hedge reserve 47 (44) (9) (6) Valuation of liabilities t o credit institutio ns and other bo rrowed funds due to f air value hedge (33) 43 10 Valuation/Impai rment of inv estments 143 4 147 Valuation/Impai rment of debt securities and ot her securities 150 (30) 2 122 Tax losses car ried forwar d 10 (8) 2 Other tempor ary differe nces 81 12 94 Currency t ranslation differ ences from financi al statements an d net investment he dging of foreign ope rations (17) 11 (6) Total 4,9 45 (16 1) 4 4,789 1.1 - 31.1 2.2025 Recognised in Bank Balance Balance Income 1.1.202 5 Equity Statement Debit diff erence of Law 4046/201 2 757 (45) 7 12 Debit diff erence of Law 4465/201 7 2,772 (50) 2,722 Write-offs, de preciation, i mpairment of plant, property and equi pment and leases an d valuation of 87 (35) 1 53 Investment Pr operties Loan port folio 703 (48) 655 Valuation of loans due to he dging - 4 4 Employee def ined benefit and insurance funds 7 7 Valuation of derivatives fi nancial instruments / Valua tion cash flo w hedge reserve - (96) 19 (77) Valuation of liabilities t o credit institutio ns and other bo rrowed funds due to f air value hedge 20 (13) (3) 4 Valuation/Impai rment of inv estments 282 (1) 28 1 Valuation/Impai rment of debt securities and ot her securities 69 110 179 Tax losses car ried-forward - 209 209 Other tempor ary differe nces 71 (7) (1) 63 Total 4,768 28 16 4,812
As at 31.12.2025, the Bank includes in line “Valuation of derivatives financial instruments/Valuation cash flow hedge reserve” recognised in
Equity € 27 and is related to the deferred tax asset related to the embedded derivative, with recall option at the day of the reverse merge.
The respective amount was recognised in line “Merger reserve”.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
327 | ANNUAL FINANCIAL REPORT
31.12.2024
1.1 - 31.1 2.2024 Recognised in Bank Balance Balance Income 1.1.2024 Equity Statement Debit diff erence of Law 4046/201 2 802 (45) 757 Debit diff erence of Law 4465/201 7 2,942 (170) 2,772 Write-offs, de preciation, i mpairment of plant, property and equi pment and leases an d valuation of 11 0 (2 3) 87 Investment Pr operties Loan port folio 604 99 703 Employee def ined benefit and insurance funds 7 7 Valuation of derivatives fi nancial instruments / Valua tion cash flo w hedge reserve 53 (44) (9) - Valuation of liabilities t o credit institutio ns and other bo rrowed funds due to f air value hedge (23) 43 20 Valuation/Impai rment of inv estments 278 4 282 Valuation/Impai rment of debt securities and ot her securities 97 (32) 4 69 Other tempor ary differe nces 69 2 71 Total 4,9 39 (16 6) (5) 4,7 68
As of 31.12.2025, the amount of deferred tax assets which are in the scope of Law 4465/2017 and include the amount of the debit difference
of Law 4046/2012 (PSI), amount to € 2.26 bil. (31.12.2024: € 2.42 bil.).
As at 31.12.2025, the Group had not recognized deferred tax asset of €494 in relation to tax losses carried forward. The amount includes € 403
of deferred tax assets not recognized arising from tax losses carried forward from previous periods of €1,389 relating to Alpha Services and
Holdings, mainly due to the sale of 51% of the mezzanine and junior notes of Galaxy securitization, which are not expected to be offset with
future tax profits.
Following the reverse merger, the tax losses of Alpha Services and Holdings from previous years carried forward for a total a mount of €2,233,
were transferred to the Absorbing entity (Alpha Bank) under the same terms and conditions, and with the same five-year utilization period that
would have applied to the Absorbed entity had the transaction not taken place, in accordance with paragraph 22 of Article 16 of Law 2515/1997,
as amended by paragraph 1 of Article 221 of Law 5193/2025. Out of these tax losses, an amount € 844 could be utilized for offsetting taxable
profits of the Bank over the time horizon permitted by the relevant law and consequently deferred tax assets of €245 were rec ognized on
25.6.2025.
Deferred tax assets that have not been recognized as at 31.12.2025 deriving from relevant tax losses are presented in the following table by
year of maturity.
Expiration year for setting off tax los ses Deferred tax ass ets 2026 2027 2028 2029 2030 Total Group 251 199 8 23 13 494 Bank 210 189 2 2 4 03
Moreover, the Group as at 31.12.2025 has not recognized deferred tax assets on temporary differences of amount € 2. The year for the
reversal of the above temporary differences cannot be reliably determined.
31.
Other assets
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Tax advances and withholdi ng taxes 190 215 187 186 Deposit a nd Investment Guar antee Fund 37 37 37 37 Property obtained from auct ions and other inventories 376 238 183 190 Prepaid expe nses 37 25 28 22 Accrued i ncome 59 44 61 39 Other 27 6 2 49 163 174 Total 97 5 80 8 659 648 Group Line “Tax advances and withholding taxes” is presented in the table above net of provisions of € 2 as of 31.12.2025 (31.12.2024: € 21).
Group Line “Property obtained from auctions and other inventories” includes assets obtained from auctions. As at 31.12.2025 t he amount
stood at € 376 (31.12.2024: 249), increased mainly due to the consolidation of the acquired Astro Bank’s subsidiaries.
As at 31.12.2025 the Group valued “Property obtained from auctions and other inventories” which have been classified as Other Assets, at
the lower between their carrying amount and fair value less costs to sell. For cases where the net realisable value of the properties was less
that their carrying value, impairment loss of € 2 (31.12.2024: € 3) has been recognised. The impairment amount was recognized in
“Impairment losses on fixed assets and equity investments” in the Consolidated Income Statement.
The recoverable amount of land and buildings that were impaired during the year amounted to € 31 (31.12.2024: € 4).
“Accrued income” includes a contract asset of € 13 (31.12.2024: € 10) which relates to the performance bonus from the achievement of
distribution targets for insurance products based on a relevant agreement. More specifically, this amount represents income recognised
based on the achievement of targets up to 31.12.2025.
The Group’s right to the total consideration will become unconditional 10 years following the date of the signing of the agre ement, therefore
the consideration amount is variable and subject to periodical reestimation in accordance with the provisions of IFRS 15.
However, considering that in essence there is no uncertainty with regards to the achievement of the target, it is estimated the consideration
will not change .
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
328 | ANNUAL FINANCIAL REPORT
The increase in the balance of the contract asset during 2025 is mainly due to the recognition of commission income from insurance
brokerage fees amounting to € 3 related to achievement of targets set s.
Moreover, taking into account the credit rating of the counterparty and the payment history, no impairment loss has been recognised related
to the contract asset.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
329 | ANNUAL FINANCIAL REPORT
LIABILITIES
32.
Due to Banks
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Deposits: - Current acco unts 184 312 52 52 - Term deposits: Central Ban ks 2,301 2,602 2,301 2,602 Other credi t institutions 118 150 150 181 Cash collat eral for derivativ e margin account and repurchase agre ements 325 348 330 348 Securities so ld under agreement to repurchase (Repos) 3,304 2,770 4,780 3,262 Borrowing f unds 303 350 245 298 Deposits on demand: - Other cre dit institutions 1 1 1 Total 6,536 6,533 7,858 6,744
Interbank repo transactions increased compared to 31.12.2024 with the use of sovereign and corporate bonds as collateral, in line with the
Group’s liquidity strategy.
33.
Due to customers
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Deposits: - Current acco unt 25,87 8 22,403 24,030 21,961 - Saving accounts 14,13 5 13,496 13,672 13,398 - Term deposits 14,83 5 14,862 11,670 12,728 Fair value hedge adjustment s of deposits in portfolio hedge of i nterest rate risk 24 78 24 77 Deposits on demand 38 31 54,910 50,870 49,396 48,164 Cheques payab le 174 162 164 157 Total 55,08 4 51,032 49,560 48,321
For interest rate risk management purposes, the Bank has entered through derivative contracts for fair value hedge accounting for a portfolio
of savings account with nominal value of € 8.2 bil. As at 31.12.2025 the valuation of deposits at fair value in terms of the hedged risk
amounted to € 24.
At Group level the acquisition of Astro Bank’s certain assets and liabilities, which was completed in 2025 contributed to an increase in deposits
and customer accounts of € 2 bil.
With the resolution 85/1/19.11.2025 the Resolution Measures Committee of the Bank of Greece resolved on the finalisation of the difference
between the value of liabilities and assets that were transferred to the Bank after the liquidation of the credit institution “Cooperative Bank of
West Macedonia L.L.C.” in 2013.
Under the said resolution the Bank received from Hellenic Deposits and Investment Guarantee Fund an amount of € 4 with the purpose of
allocating it to the depositors of the “Cooperative Bank of West Macedonia L.L.C.”, whose deposits were transferred to Alpha Bank.
34.
Debt securities in issue and other borrowed funds
i. Covered Bonds
The following table presents detailed information for the covered Bonds issues:
Nominal Value Issuer Currency Interest Rate Maturity 31.12.2025 31.12.2024 Alpha Bank S.A. € 3m Εuribor+0.50%, minimum 0% 23.1.2028 1,000 1,000 Alpha Bank S.A. € 3m Εuribor+0.50%, minimum 0% 23.1.2028 1,000 1,000 Alpha Bank S.A. € 3m Εuribor+0.50%, minimum 0% 23.1.2028 400 400 Total 2,400 2,400 On 31.12.2025 all of the above c overe d bonds are held by the Gr oup.
ii. Senior debt
The Bank issued on 30.10.2025 a senior preferred bond with a nominal value of €500, maturing on 30.10.2031, with a call option on 30.10.2030
and an initial fixed annual coupon of 3.125%. The coupon is reset to a new interest rate that applies from the call date until maturity, determined
based on the annual swap rate plus a margin of 0.92%.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
330 | ANNUAL FINANCIAL REPORT
The movement of the key characteristics of the portfolio of senior bond loans for 2025 is presented in the table below.
Group Bank Balance 1.1.2025 1,99 6 2,012 Changes for the year 1.1-31.12.2025 New issues 496 496 Maturit ies/Repayments (108) (108) Accrued i nterest 114 115 Balance 31.12.2025 2,498 2,515
Detailed information on common bond issues is presented in the table below. The following issues have been made by the Bank and are
denominated in Euro currency.
rd
Group Bank rd Nominal Value H eld by 3 Nominal Value H eld by the Nominal Value H eld by 3 Interest Rate Maturity Group parties parties 31.12.2025 31.12.2024 31.12.2025 31.12.2024 31.12.2025 31.12.2024 2.50% 23.3.2028 2 500 498 500 500 7.50% 16.6.2027 2 2 448 448 450 450 6.75% 13.2.2029 5 5 65 65 70 70 6.875% 27.6.2029 5 5 495 495 500 500 6.50% 22.11.2029 1 1 49 49 50 50 5.00% 12.5.2030 1 1 399 399 400 400 3.125% 30.10.2031 2 498 500 Totals 16 16 2,454 1,954 2,470 1,970
iii. Liabilities from the securitization of loans and receivables
Liabilities arising from the securitization of consumer, loans and credit cards are not included in “Debt securities in issue and other borrowed
funds”, as the corresponding securities of a nominal amount equal to € 467 (31.12.2024: € 467), are held by the Group.
Detailed information for the above liabilities are presented in the following table:
Nominal Value Issuer Currency Interest Rate Maturity 31.12.2025 31.12.2024 Pisti 2010-1 Plc L DN - Class A Euro 2.50% 24.2.2026 294 294 Pisti 2010-1 Plc L DN - Class B Euro 1m Euribor, minimu m 0% 24.2.2026 173 173 Total 467 467
iv. Liabilities from the securitization of non - performing loans
The Bank has carried out a securitization transaction of an NPE portfolio managed by Cepal, the amount of which may vary on a continuous
basis depending on whether specific eligibility criteria are met. In particular, the loans were transferred to the special purpose company Gemini
Core Securitisation Designated Activity Company based in Ireland, which issued a bond that was purchased entirely by the Bank. The bond is
euro denominated, has a nominal value of € 3,785 as at 31.12.2025 (31.12.2024: € 4,841), it bears an interest rate of 3m Euribor+0.4%, minimum
0% and it matures at 27.6.2050. As the bond is held by the Bank, the liability from the said securitization is not included in the account “Debt
securities in issue and other borrowed funds”.
v. Subordinated debt (Lower Tier II, Upper Tier II)
Group Bank Balance 1.1.2025 1,124 1,155 Changes for the year 1.1 - 31.12.2025 New issues 496 496 Repurchase s (8) Maturit ies/Repayments (554) (1,598) Reverse Merger 1,017 Hedging adjustments 6 5 Financial (gains)/losses 14 14 Interest expense 59 60 Balance 31.12.2025 1,137 1,149
On 13.2.2025, the Group proceeded with the full redemption of the subordinated bond with maturity date 13.2.2030 and nominal value of €
131. On 27.6.2025, the Bank proceeded with the reverse merger. In this context, the Lower Tier II subordinated notes which had been issued by
Alpha Bank S.A. on 19.4.2021 during the hive-down were cancelled due to the merger and the subordinated notes that were included in the
liabilities of Alpha Services and Holdings were transferred to Alpha Bank S.A.
On 16.7.2025, Alpha Bank invited holders of its outstanding € 500 dated subordinated fixed rate reset Tier 2 Notes due 11.6.2031 to tender their
Notes for cash at a price of 101.75 %.
As at 24.7.2025, € 362 in aggregate principal amount of the Notes were validly tendered, while € 138 in aggregate principal amount of the Notes
remain outstanding. The loss in recognised in the statement of profit and loss for the period from the derecognition of the tendered amount
equals € 13 (note 7).
On 23.7.2025 Alpha Bank issued a new subordinated bond with a nominal value of € 500 maturing on 23.7.2036, callable in 6 years and with a
fixed annual coupon of 4.308%, which is adjusted to a new coupon applicable from the call date until maturity, determined on the then prevailing
swap rate plus a margin of 1.93%.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
331 | ANNUAL FINANCIAL REPORT
Group Bank rd parties Nominal value H eld by 3 rd Nominal value H eld by the Group Nominal value H eld by 3 parties Interest Rate Maturity 31.12.2025 31.12.2024 31.12.2025 31.12.2024 31.12.2025 31.12.2024 4.25% 13.2.2030 131 131 5.50% 11.6.2031 10 138 490 138 500 6.00% 13.9.2034 11 11 489 489 500 500 4.3 08% 23.7.2036 8 492 500 Total 19 21 1,119 1,110 1,138 1,131
vi. Credit Linked Debt
As part of the €1.2 bil Credit Linked Note Issuance Programme, the Bank issued on 17.12.2025 a synthetic securitization bond with a nominal
value of € 81, maturing on 20.12.2039, with a call option on 17.3.2030 and a coupon based on 3m Euribor.
The movement of the key characteristics of the synthetic securitization bond portfolio for 2025 is presented in the table below.
Group Bank Balance 1.1.2025 88 88 Changes for the p eriod 1.1-31.12.20 25 New Issues 81 81 Maturit ies/Repayments (2) (2) Accrued i nterest 2 2 Balance 31.12.2025 169 169
Detailed information on credit linked notes issuances is presented in the following table: Group Bank Issuer Currency Interest Rate Maturity Nominal Value 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Alpha Bank S.A. € 3m Εuribor 30.6.2039 88 88 88 88 Alpha Bank S.A. € 3m Εuribor 20.12.2039 81 81 Total 169 88 169 88 Group Bank 2025 2024 2025 2024 Total of debt securi ties in issue and other borrow ed funds as at 3 1.12. 3,804 3,208 3,833 3,256
The following table presents the changes of debt securities and other borrowed funds by separately disclosing the cash and non-cash items:
Group Cash Flows Non Cash Flows Desecuritizations Cash flows fro m financing activiti es 1.1.202 5 New issues Foreign exchange Change of Fair Accrued interest Other 31.12.2025 Maturities differences Value Repayments Senior de bt securities (ii) 1,996 388 114 2,498 Subordinat ed debt (v) 1,124 (66) 59 6 14 1,137 Credit l inked debt (vi) 88 79 2 169 Group Cash Flows Non Cash Flows Desecuritizations Cash flows fro m financing activiti es 1.1.202 4 New issues Foreign exchange Change of Fair Accrued interest Other 31.12.2024 Maturities differences Value Repayments Senior de bt securities (ii) 1,964 (125) 133 23 1 1,996 Subordinat ed debt (v) 956 68 58 32 10 1,124 Credit l inked debt (vi) - 88 88
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
332 | ANNUAL FINANCIAL REPORT
Bank Cash Flows Non Cash Flows Desecuritizations Cash flows fro m financing activiti es 1.1.2025 New issues Foreign exchange Change of Fair Accrued interest Other 31.12.2025 Maturities differences Value Repayments Senior de bt securities (ii) 2,012 388 115 2,515 Subordinat ed debt (v) 1,155 (86) 60 5 15 1,149 Credit l inked debt (vi) 88 79 2 169 Bank Cash Flows Non Cash Flows Cash flows fro m financing 1.1.202 4 Desecuritizations N ew issues Accrued Foreign exchange activities Change of Fair Val ue Other 31.12.2024 Maturities Repa yments interest differences Senior de bt securities (ii) 1,980 (126) 134 23 1 2,012 Subordinat ed debt (v) 972 65 60 33 25 1,155 Credit l inked debt (vi) - 88 88
35.
Liabilities for current income tax
Current Income Tax Liabilities as at 31.12.2025 for the Group amount to € 11 (31.12.2024: € 69) mainly regards the provision calculated for
the OECD Pillar II model rules at Group level of € 4.
36.
Employee defined benefit obligations
The total amounts recognized, in the financial statements for defined benefit obligations are presented in the tables below:
Group Bank Balance Sheet - Liabi lities Balance Sheet - Liabi lities 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Employee's ind emnity prov ision due to retirement in accordance with Law 2112/19 20 19 17 17 15 Plans for D iners (pension and health care) 6 6 6 7 Total Liabi lities 25 23 23 22 Group Bank Income Statement Expense / (Inco me) From 1 Januar y to 31.12.2025 31.12.20 24 31.12.2025 31.12.2024 Employee's ind emnity prov ision due to retirement in accordance with Law 2112/19 20 3 3 3 3 Total Liabi lities 3 3 3 3
Balance Sheet and Income Statement amounts are analyzed per fund and type of benefit as follows:
a. Employee indemnity due to retirement in accordance with Law2112/1920
The contracts of the regular employees of Alpha Bank S.A. are indefinite term employee contracts and when terminated, the provisions of
Law 2112/1920 and Law3198/1955 apply, as amended by Law 4093/2012, which provide a lump sum benefit payment.
The amounts recognized in the income statement are as follows:
Group Bank From 1 Janu ary to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Current se rvice cost 2 2 2 2 (Gain)/Loss from Settlement / Cur tailment / Terminati on 1 1 1 1 Total (included i n staff costs) 3 3 3 3
The movement in the present value of defined benefit obligation is as follows:
Group Bank 2025 2024 2025 2024 Opening Balance 1.1 17 17 15 17 Current se rvice cost 3 2 2 2 Benefits pa id (2) (3) (1) (3) (Gain)/Loss from Settlement / Curtailment / Terminat ion 1 1 1 1 Reclassifi cation to volunt ary separation scheme p rovision (2) Closing Balance 3 1.12 19 17 17 15
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
333 | ANNUAL FINANCIAL REPORT
The movement in the present value of defined benefit obligation is as follows:
Group Bank 2025 2024 2025 2024 Opening Balance 1.1 17 17 15 17 Benefits pa id (2) (3) (1) (3) Loss/(Gain) recognized in Inco me Statement 4 3 3 3 Reclassifi cation to volunt ary separation scheme p rovision (2) Closing Balance 3 1.12 19 17 17 15
b. Supplementary Pension Fund and Healthcare of Diners
The Bank guarantees from 30.9.2014, date of acquisition of Diners Club Greece S.A., the Supplementary Pension Fund and Health Care Plan of
the Company, which is managed by an independent insurance company.
The contribution to Diners' supplementary pension scheme is not expected to be significant in 2026.
The amounts included in the balance sheet of the Group and Bank are analyzed as follows:
31.12.2025 31.12.2024 Present val ue of defined o bligation 7 7 Fair value of plan assets (1) (1) Liabili ty 6 6
The movement in the present value of defined benefit obligation is as follows:
202 5 2024 Opening Balance 8 8 Actuarial (gain)/loss-demographi c assumptions (1) Closing Balance 7 8 The movement in the fair value of assets for the plan is analyzed as follow s:
202 5 2024 Opening Balance 1 1 Benefits pa id Closing Balance 1 1
The amounts recognized directly in Equity during the year are analyzed as follows:
31.12.2025 31.12.2024 Change in liab ility due t o financial and demographic assumptions - gains/(loss) 1 Total actuarial gain/(loss) reco gnized in equi ty 1 -
The movement in the obligation/(asset) is as follows:
202 5 2024 Opening Balance 7 7 (Gain)/lo ss recognized in Equi ty (1) (1) Closing Balance 6 6
The results of the abovementioned valuations are based on the assumptions of the actuarial studies. The principal actuarial assumptions used
for the abovementioned defined benefit plans are as follows:
31.12.2025 31.12.2024 Discount rate 3.54% - 4.10% 3.14%-3.44% Inflatio n rate 2.00% 2.00% Future sal ary growth 2.50% 2.25% Future pens ion growth 0.00% 0.00%
The discount rate was based on the iBoxx Euro Corporate AA+ adjusted to the characteristics of the programs.
The average duration per program is depicted in the table below:
31.12.2025 31.12.2024 Bank emplo yee's indemni ty provision due to retirement in ac cordance with Law 2112/1920 6.5 6.9 Plans for D iners (pension and health care) 13.4 13.9
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
334 | ANNUAL FINANCIAL REPORT
The table below presents the sensitivity analysis of the financial assumptions with regards to the obligation of the above programs:
% change Percentage vari ation in li ability (%) Increase i n discount rate b y 0.5% (3.7) Decrease in discount rate by 0.5% 4.0 Increase i n future salary gro wth rate by 0.5% 1.9 Decrease in future salary growth rate by 0.5% (1.9)
37.
Other Liabilities
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Liabilitie s to third parties 29 27 24 26 Suppliers 93 79 72 51 Broker age services 47 31 Deferre d income 25 23 21 23 Accrued e xpenses 1 31 140 108 105 Liabilitie s to merchants for the use of credi t cards 233 207 253 225 Lease liab ilities 128 124 112 118 Other t axes 29 28 24 23 Other 285 235 168 189 Total 1,000 89 4 782 760 There are no property leases which include a variable lease te rm while variable leases have been included in the expenses rel ating to other
types of leases.
The following table includes the movement in lease liabilities, with distinctive presentation of cash flows, a presented in the Cash flows
Statement from financing activities and the non cash flow movements. At Group level the acquisition of Astro Bank’s certain assets and
liabilities, which was completed in 2025 contributed to an increase in € 9 in lease liabilities which are included “new leases” in the table
below.
Non-cash flows Transfer t o Held for Group 1.1.2025 Cash flows 31.12.2025 New leases Other c hanges Sale Lease liab ilities 12 4 (20) 28 (4) 128 Non-cash flows Transfer t o Held for Group 1.1.2024 Cash flows 31.12.2024 New leases Other c hanges Sale Lease liab ilities 110 (18) 16 9 7 124 Non-cash flows Transfer t o Held for Bank 1.1.202 5 Cash flows 31.12.2025 New leases Other c hanges Sale Lease liab ilities 118 (17) 14 (3) 112 Non-cash flows Transfer t o Held for Bank 1.1.202 4 Cash flows 31.12.2024 New leases Other c hanges Sale Lease liab ilities 112 (15) 15 6 118
Line “Other” for the Group includes an amount of € 32 which represents the fair value of the deferred considerations resultin g from to the
acquisition of subsidiaries that took place within 2025.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
335 | ANNUAL FINANCIAL REPORT
38.
Provisions
Separation Scheme
provisions
Separation Scheme
provisions
Provisions to cov er credit risk Provisions for Voluntary Other Group (from undrawn loan commitments Letters of Total pending legal case s Guarantee and Letters of Credit) Balance 1.1.2024 29 30 18 42 119 Changes for the year 1.1-31.12.2024 Provisions/(Reversals) (5) 55 60 110 Provisions used (9) (1) (32) (26) (68) Balance 31.12.2024 20 24 41 76 161 Changes for the year 1.1-31.12.2025 Provisions/(Reversals) 8 1 2 20 31 Provisions used (7) 1 (17) (32) (55) Transfer fr om Other Liabilitie s 3 3 Balance 31.12.2025 21 26 26 67 140 Provisions to cov er credit risk Provisions for Voluntary Other Bank (from undrawn loan commitments Letters of Total pending legal case s Guarantee and Letters of Credit) Balance 1.1.2024 19 30 17 35 101 Changes for the year 1.1-31.12.2024 Provisions/(Reversals) 1 (8) 53 29 75 Provisions used (3) (31) (23) (57) Balance 31.12.2024 17 22 39 41 119 Changes for the year 1.1-31.12.2025 Provisions/(Reversals) 8 1 27 36 Provisions used (6) (17) (26) (49) Balance 31.12.2025 19 22 23 42 106 V olunt ary Separation Scheme
Within 2024, the Executive Committee approved a new VSS program with an estimated total cost of € 58. Within 2025 provisions utilised
under the VSS program amount to € 17, while the remaining amount relates to the provision of those beneficiaries who opted for the
Sabbatical program.
Other provisions
Line "Provisions/(Reversals)" for the period ended 31.12.2025 includes:
a. an additional provision of € 25 related to the extension of the 'Marietta Giannakou' programme that was booked by the Bank
b. a reversal of € 7 related to provisions in the context of sale transactions.
Line ‘’Provisions used’’ for the period ended 31.12.2025 is mainly related to an amount paid against the provision of the "Marietta
Giannakou" 2024 program.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
336 | ANNUAL FINANCIAL REPORT
EQUITY
39.
Share Capital
Group Bank Number of ordi nary Carrying Number of ordi nary Carrying registered shar es amount registered shar es amount Balance 31.12.2024 2,352,977,294 682 51,979,992,461 4,678 Shares fro m Share Capital Inc rease through stoc k options exerc ise 834,784 137,322 Cancelatio n of treasury sha res (38,550,720) (11) Shares fro m Share Capital Inc rease due to reverse mer ge 2,315,124,036 671 Cancelatio n of own shares due to reverse merge (51,979,992,461) (4,678) Balance 31.12.2025 2,315,261,358 671 2,315,261,358 671
As of 31.12.2024, the share capital of the Bank (Absorbing Company) amounted to € 4,678 divided into 51,979,992,461 common, r egistered,
voting shares of nominal value € 0.09 each.
The share capital of the Alpha Services and Holdings S.A. (Absorbed Company) on the same date amounted to € 682 and was divid ed into
2,352,977,294 common, registered, voting shares of nominal value of € 0.29 each.
In the context of Stock Options Plan through which stock options rights could be granted to key management and the employees of the
Company and the Group, 697,462 stock option rights vested and exercised from the Beneficiaries in January 2025, in accordance with
Performance Incentive Program for the year 2020.
From the above rights, 215,836 were exercised at an issue price of € 0.29 and the remaining 481,626 rights were exercised at an issue price of
€ 0.30. As a result of the above 697,462 ordinary, registered, voting shares of nominal value of € 0.29 each were issued, and share capital
increased by € 0.2 mn. Furthermore, the share premium increased by € 0.5 mn due to exercise of above stock options.
The Bank’s Extraordinary Shareholder General Meeting (“EGM”) dated 12.6.2025 as well as the Extraordinary General Meeting of the
Shareholders of the Absorbed Company dated 23.6.2025 approved the Reverse Merger which was completed on 27.6.2025. As a resul t, the
share capital of the Absorbed Entity was contributed to the Absorbing Entity in accordance with par. 5 of article 16 of Law 2 515/1997.
The shares of the Absorbing Entity that were 100% owned by the Absorbed Entity, namely 51,979,992,461 common, registered, voting shares
of nominal value € 0.09 each, representing the entire share capital of € 4,678 of the Absorbing Entity, were transferred, as a r esult of the
Merger and by way of universal succession, to the Absorbing Entity itself, and became own shares of the Absorbing Entity in accordance with
article 49 par. 4 point (b) of Law 4548/2018 and were cancelled upon the completion of the Merger.
In addition, upon the completion of the Merger the 38,550,720 treasury shares of the Absorbed Entity acquired under the Share Buyback
Program approved and amended by the Ordinary General Meetings of Company’s Shareholders dated 27.7.2023 and 24.7.2024 acco rdingly,
were cancelled, while the share capital of the Absorbing Entity was reduced by a corresponding amount (i.e. € 11).
In September 2025 137,322 option rights vested and exercised from the beneficiaries, in accordance with Performance Incentive Program for
the years of 2021. As a result of the above, 137,322 ordinary, registered, voting shares with nominal value of Euro 0.29 were issued.
Subsequently, the Bank’s share capital as of 31.12.2025 amounts to € 671 divided into 2,315,261,358 ordinary, registered shares with voting
rights with a nominal value of €0.29 each. (note Reverse merger)
Treasury shares
A share buyback program was approved and amended by the Ordinary General Shareholders Meetings on 27.7.2023 and 24.7.2024 of Alpha
Services and Holdings S.A. accordingly, for the acquisition of own shares to serve any and all purposes permitted by applicable laws and the
regulatory framework, including the free distribution of treasury shares to Members of Management and Personnel of the Company and its
Affiliates, within the meaning of article 32 of Law 4308/2014 (the “Share Buyback Program”).
More specifically, in the context of the dividend distribution program for the year 2023 the Alpha Services and Holdings S.A. during the 1st
quarter of 2025 repurchased 5,649,854 treasury shares amounting € 10 and thus completed the program by repurchasing in total 38,550,720
treasury shares for a total cost of € 61. The said 38,550,720 treasury shares were cancelled on 27.6.2025, following the reso lutions of the
Extraordinary General Shareholders’ Meeting of Alpha Services and Holdings S.A. on 23.6.2025.
During the Annual General Shareholders’ Meeting of Alpha Services and Holdings S.A. on 21.5.2025 the above mentioned Share Bu yback
Program was terminated and a new one was established noting that the new Share Buyback Program would also be adopted and respectively
implemented by the Bank , as the surviving entity of the Reverse Merger. Following the above, the Extraordinary General Shareholder
Meeting of the Bank on 12.6.2025, decided the establishment of a Share Buyback Program, as per the terms and conditions of the Share
Buyback Program approved by Alpha Services and Holdings S.A. , for the acquisition of own shares in accordance with article 49 of L.
4548/20218, that will serve any and all purposes permitted by applicable laws and the regulatory framework, including the fre e distribution
of treasury shares to Members of the Management and the Personnel of the Bank and its Affiliates, within the meaning of article 32 of Law
4308/2014, as well as, the acquisition and the consequent cancellation of own shares in the context of the dividend distribution policy
towards the shareholders.
In addition, the subsidiary company Alpha Finance S.A. performs transactions with the shares of the Bank in the context of market making. As
at 31.12.2025 the carrying amount of the treasury shares held by the subsidiary was € 5.
The transactions of treasury shares of the Group and the Bank are described below:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
337 | ANNUAL FINANCIAL REPORT
Alpha Bank S.A. Alpha Services and H oldings S.A. Alpha Finance S.A. (b) Total (a) Total Group (a)+(b) Dividend distributi on Share awards Dividend distributi on Share awards Market making No. of Carrying No. of Carrying No. of Carrying No. of Carrying No. of Carrying No. of Carrying No. of Carrying shares amount shares amount shares amount shares amount shares amount shares amount shares amount Balance 1.1.2024 - - - - - - 5,855,794 9 5,855,794 9 1,385,675 2 7,241,469 11 Changes for the p eriod 1.1-31.12.20 24 Purchases 32,900,866 51 32,900,866 51 41,632,447 66 74,533,313 117 Sales - - (38,906,960) (61) (38,906,960) (61) Share awards (3,690,333) (6) (3,690,333) (6) (3,690,333) (6) Balance 31.12.2024 - - - - 32,900,866 51 2,165,461 3 35,066,327 54 4,111,162 7 39,177,489 61 Changes for the p eriod 1.1-31.12.20 25 Purchases 26,260,464 93 3,501,556 11 5,649,854 10 1,123,533 3 36,535,407 117 65,782,307 173 102,317,714 290 Sales - - (68,733,129) (175) (68,733,129) (175) Share awards (992,440) (3) (3,288,994) (6) (4,281,434) (9) (4,281,434) (9) Cancelatio n (38,550,720) (61) (38,550,720) (61) (38,550,720) (61) Balance 31.12.2025 26,260,464 93 2,509,116 8 - - - - 28,769,580 101 1,160,340 5 29,929,920 106
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
338 | ANNUAL FINANCIAL REPORT
40.
Share premium
Group Bank 2025 202 4 2025 202 4 Opening Balance 1.1 4,784 4,783 1,125 1,125 Changes for the year 1.1-31.12 Increase i n share premium thr ough the stock options rights exe rcise 1 Due to Re verse Merger (not e “Reverse Merger”) 1,125 4,784 Balance 31.12 5,909 4,784 5,909 1,125
41.
Merger reserve
Differences arising from the elimination of Alpha Services and Holdings' investment in the Bank with Alpha Bank’s share capital and other
elements of its equity & elimination of other intra-group assets and liabilities were recognized in a special equity reserve (Merger reserve). As
at 31.12.2025 the balance of the Merger Reserve was € 1,125 for the Group, and € 1,577 for the Bank. On 14.10.2025, the supervisory
authorities approved the offsetting of the merger reserve with other equity components. Such an offset is subject to the approval of the
Annual General Assembly meeting expected to take place in 2026.
42.
Other Equity Instruments
Group Bank 2025 202 4 2025 202 4 Opening Balance 1.1 700 400 700 400 Changes for the year 1.1-31.12 AT1 Issuance 300 300 Balance 31.12 700 700 700 700
On 1 February 2023, the Absorbed Company issued additional Tier 1 instruments ("AT1 Notes") amounting to € 400 in order to strengthen its
regulatory capital position. The bonds are indefinite, with an adjustment clause, a maturity of 5.5 years and a yield of 11.875%. Additionally,
on 3 September 2024, the Company issued additional Tier 1 instruments (AT1 Notes) amounting to € 300. The bonds are perpetual, with an
adjustment clause, a maturity of 6 years and a yield of 7.5%.
“AT1 securities” are structured to qualify as Additional Tier 1 instruments in accordance with the applicable capital rules at the relevant issue
date. "AT 1 securities" are redeemable in their entirety, at the choice of the issuer, in case of specific changes in the tax or regulatory
treatment of the securities. Interest on the securities is due and payable only at the sole discretion of the Company, which may at any time
and for any reason cancel (in whole or in part) any interest payment that would otherwise be payable on any interest payment date.
Based on the above characteristics, the instrument is recognized as an equity item while interest repayments will be recognized as a dividend
deducting equity. During 2025, the Group made a coupon payment for the AT1 Notes, amounting to € 70.
43.
Reserves
Reserves are analyzed as follows:
a. Statutory reserve
Group Bank 2025 202 4 2025 202 4 Opening Balance 1.1 97 103 61 26 Changes for the year 1.1-31.12 Appropriat ion of reserve s 56 36 32 35 Sale of sub sidiary (5) (42) Due to R everse Merger (not e “Reverse Merger”) 11 Balance 31.12 148 97 104 61
According to article 158 of Law 4548/2018, (for which a corresponding paragraph exists in article 26 of the Banks’ Articles of association) at
least one-twentieth (1/20) is deducted annually from the annual net profit for the formation of the statutory reserve. This requirement ceases
to be mandatory once the reserve reaches the one - third (1/3) of the share capital. Based on the provisions of the aforementioned article this
reserve can be utilized exclusively before any dividend distribution in order to offset prior year accumulates losses.
For the remaining companies of the Group the statutory reserve is formed according to the local regulations.
b. Reserve of investment securities measured at fair value through other comprehensive income
Group Bank 2025 2024 2025 2024 Opening Balance 1.1 (3) (3) (2) (2) Changes for the year 1.1-31.12 Valuation of debt securitie s measured at fai r value through othe r comprehensi ve income, after income tax 4 4 (1) 2 Reclassifi cation to income s tatement of re serve of debt secur ities measured at f air value through o ther 4 (4) (1) (2) comprehensi ve income, afte r income tax Balance 31.12 5 (3) (4) (2)
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
339 | ANNUAL FINANCIAL REPORT
The movement for the year of the reserve for investment securities measured at fair value through other comprehensive income, that relate
to the valuation of the investment securities and the transfer of the related reserve to Income Statement, amounts (before income tax) to a
debit amount of €2 and a debit amount of €2 respectively (1.1-31.12.2024: credit amount of €3 and debit amount of € 3, respectively).
c. Cash flow hedge reserve recognised directly in Equity
Group Bank 2025 2024 2025 2024 Opening Balance 1.1 (172) (194) (172) (194) Changes for the year 1.1-31.12 New hedging aft er income t ax 4 7 4 7 Amortization of hedging rel ationships expir ed after income tax 15 15 15 15 Balance 31.12 (1 53) (172) (153) (172)
d. Exchange differences on translating and hedging the net investment in foreign operations
Group Bank 2025 202 4 2025 202 4 Opening Balance 1.1 (18) (21) - - Changes for the year 1.1 - 31.12 Change of Forei gn Exchange diffe rences on tr anslating and hedging t he net invest ment in foreign oper ations 2 3 Balance 31.12 (16) (18) - -
e. Valuation Reserve for stock options rights to employees
Group Bank 2025 202 4 2025 202 4 Opening Balance 1.1 1 1 - 1 Changes for the year 1.1 - 31.12 Exercise o f rights (1) (1) Reserve valuation for stoc k options right to e mployees 1 Balance 31.12 1 1 - -
Details for the stock options exercised during 2025 are included in note 10.
f. Valuation reserve for share award rights to employees
Group Bank 2025 202 4 2025 202 4 Opening Balance 1.1 2 3 3 3 Changes for the year 1.1 - 31.12 Exercise o f rights (7) (6) (9) (5) Reserve valuation for stoc k award right to employees 11 5 11 5 Balance 31.12 6 2 5 3
g. Other and not taxable reserves
Group Bank 2025 202 4 2025 202 4 Opening Balance 1.1 - - 21 21 Changes for the year 1.1 - 31.12 Intragroup and other non-taxable dividends 10 Due to Re verse Merger (refer to note “Rever se Merger”) (760) Balance 31.12 - - 79 1 21
h. Associates Other Comprehensive Income Reserve
Group Bank 2025 202 4 2025 202 4 Opening Balance 1.1 - - Changes for the year 1.1 - 31.12 Changes in the share of othe r comprehensiv e income of asso ciates and joint vent ures 2 Balance 31.12 2 - Group Bank 2025 2024 2025 2024 Total reserves (a+b+c+d+e+f+g+h) (7) (93) 743 (89)
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
340 | ANNUAL FINANCIAL REPORT
i. Reserves related to Assets held for sale
Group Bank 2025 202 4 2025 2024 Opening Balance 1.1 (14) (64) - - Changes for the year 1.1 - 31.12 Change of Forei gn Exchange diffe rences on tr anslating and hedging t he net invest ment in foreign oper ations 45 Reserve of portfolio hel d for sale 8 Valuation of shares classifie d as held for sale (3) Balance 31.12 (14) (14) - -
It is noted that the amount of € 45 in 2024 refers to the recycling of Other Comprehensive Income reserves to the statement of profit and loss due
to the sale of Alpha Bank Romania.
44.
Retained Earnings
Retained Earnings for the Group stood at € 2,777 as at 31.12.2025 (31.12.2024: € 2,203). The increase was mainly due to the profits for the
year 2025 of € 943 which was partially offset by:
• the interim dividend distribution of € 111 (0.0460 € per share) that took place in December 2025,
• the payment of AT1 dividends amounting to € 70,
• the distribution of cash dividends of € 70 (0.0303 € per share) and the appropriation of statutory reserves of € 56 for the year 2024
as per the resolution of the Ordinary Shareholders Meeting held at 21.5.2025 and finally
• the cancellation of the treasury shares by the amount exceeding their nominal value of € 50.
On 26.2.2026, the BoD of Alpha Bank, decided to propose to the forthcoming General Assembly, subject to the permission of ECB , the
distribution of both cash and through share buyback, for an amount equal to 55% of annual consolidated profits for 2025. This amount
includes the interim dividend of € 111 already paid in 2025.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
341 | ANNUAL FINANCIAL REPORT
ADDITIONAL INFORMATION
45.
Contingent liabilities and commitments
a. Legal issues
There are certain legal claims against the Group and the Bank, deriving from the ordinary course of business. In the context of managing the
operational risk events and based on the applied accounting policies, the Group and the Bank has established internal controls and processes
to monitor all legal claims and similar actions by third parties to assess the probability of a negative outcome and the potential loss. For cases
where there is a significant probability of a negative outcome, and the result may be reliably estimated, the Group and the Bank recognizes a
provision that is included in the Balance Sheet under “Provisions”. As of 31.12.2025 the amount of the provision at a Group level stood at €20
(31.12.2024: €20), while at a Bank level stood at € 19 (31.12.2024: € 17).
For those cases, that according to their progress and the assessment of the legal department as at 31.12.2025, a negative outcome is not
probable or the possible loss cannot be estimated reliably due to the complexity of the cases and their duration, the Group has not established
a provision. As of 31.12.2025 the legal claims against the Group for the above cases amount to €426 (31.12.2024: €423) and €32 (31.12.2024:
€34), respectively, while the legal claims against the Bank amount to €418 (31.12.2024: € 172) and €13 (31.12.2024: €21), respectively.
According to the legal department’s estimation, the ultimate settlement of the claims and lawsuits is not expected to have a material effect on
the financial position or the operations of the Group and the Bank.
b. Tax issues
According to art.78 of Law 5104/2024 from the year 2011, the statutory auditors and auditing firms that conduct mandatory audits of societe
anonymes are required to issue an annual tax compliance report regarding the application of the tax provisions in certain tax areas. Based on
art.56 of Law 4410/3.8.2016 tax compliance reports are optional for the years from 1.1.2016 and thereon. Nevertheless, the intention of the
Bank and the companies included in its Group is to continue receiving such tax compliance report.
On 27.6.2025, the merger by absorption of Alpha Services and Holdings S.A. by Alpha Bank S.A. was completed, following the approval of the
Extraordinary General Meeting of the shareholders of Alpha Services and Holdings S.A. on 23.6.2025.
Alpha Services and Holdings S.A. (“Absorbed Company”) has been audited by the tax authorities for the years up to and includi ng 2010 as well
as for the year 2014, while tax audits for fiscal years 2020 and 2021 are currently ongoing. Years 2011 to 2018 are considered as closed, in
accordance with the Ministerial Decision 1208/20.12.2017 of the Independent Public Revenue Authority. For the years from 2011 up to an
including 2024 the Company has received tax compliance report, according to the article 82 of L aw 2238/1994 and the article 78 of Law
5104/2024, with no qualification. Tax audit in connection with the tax compliance report of 2025 is in progress.
Alpha Bank S.A. (“Absorbing Company”) emerged from the hive-down of the banking sector and started its operation on 16.4.2021 and the
first fiscal year was from 1.7.2020 to 31.12.2021. Alpha Bank S.A. has received a tax compliance report for its first tax year from 1.7.2020 to
31.12.2021 and for tax years 2022,2023 and 2024, according to the article 78 of Law 5104/2024, with no qualification. Tax audit in connection
with the tax compliance report of 2025 is in progress.
The Bank’s branch in Luxembourg started its operation in June 2020 and has not been tax audited since its operation.
Based on Ministerial Decision 1006/5.1.2016 there is no exemption from tax audit by the tax authorities to those entities that have been tax
audited by the independent statutory auditor and they have received an unqualified tax compliance report. Therefore, the tax authorities
may reaudit the tax books. Additional taxes, interest on late submission and penalties may be imposed by tax authorities, as a result of tax
audits for unaudited tax years, the amount of which cannot be accurately determined.
Information regarding the unaudited tax years of the Group subsidiaries is provided in Note 46.
In December 2022, the European Council adopted the EU Directive 2022/2523 for a global minimum tax that is expected to be used by
individual jurisdictions. The goal of the framework is to reduce the shifting of profit from one jurisdiction to another, in order to reduce global
tax obligations in corporate structures. In March 2022, the OECD released detailed technical guidance on Pillar Two of the rules. As at the date
of approval of these interim financial statements, most of the jurisdictions where the Group operates have already incorporated these
changes into their domestic legislation with the exception of Serbia which has not enacted legislation to incorporate these rules of Pillar II into
its national law yet. As far as Greece is concerned, Law 5100/2024 published in the Official Gazette on 5 April 2024, incorporated the EU
Council Directive into Greek legislation and it closely follows the provisions of the EU Pillar Two Directive. The law includes detailed provisions
on safe harbors, including a Transitional Country-by-Country reporting (CbC) Safe Harbor, a Transitional Undertaxed Profits Rule Safe Harbor,
as well as a permanent Qualifying Domestic Minimum Top-Up Tax Safe Harbor.
The Group falls within the scope of the Pillar II rules and, for the period ended 31 December 2025, performed an assessment of the potential
impact arising from the imposition of top-up tax. Based on this assessment, a top-up tax liability was identified in the jurisdictions of Greece
and Romania. Income tax expense in the Statement of Profit or Loss includes an amount of € 5 (31.12 2024: € 0), relating to the respective
top-up tax charge.
c. Off balance sheet commitments
The Group and the Bank, as part of its normal course of business, enters into contractual commitments, with its customers. Due to its nature,
these commitments are monitored in off balance sheet accounts and relate to letters of credit, letters of guarantee and liabilities from
undrawn loan commitments as well as guarantees given for bonds issued and other guarantees to subsidiary companies.
Letters of credit are used to facilitate trading activities and relate to the financing of contractual agreements for the transfer of goods locally
or abroad, through direct payment to the third party on behalf of the Group’s customers. Letters of credit, as well as letters of guarantee, are
commitments under specific terms and are issued by the Group for the purpose of ensuring that its customers will fulfill the terms of their
contractual obligations.
In addition, contingent liabilities for the Group arise from undrawn loan commitments that can be utilized only if certain requirements are
fulfilled by counterparties.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
342 | ANNUAL FINANCIAL REPORT
The outstanding balances are as follows:
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Letter s of credit 289 128 285 89 Letter s of guarantee and other guarantees 6,419 5,608 6,340 5,697 Undrawn loan c ommitments 5,170 4,554 4,913 4,527 Undrawn commitment s for due from financ ial institutions 46 48 The Group measures the expected credi t losses for all the undrawn loan commitments and letters of credit/letters of guarantee € 26
(31.12.2024: € 24), which are presented in “Provisions”.
d. Pledged asset
Group Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Comment Cash and Reserve deposits relating t o a) deposits that the Bank of Greec e requires from all f inancial balances instit utions established i n Greece to maintain i n BoG, corresp onding to 1% of t heir total 573 505 493 470 with Central customer d eposit as also to b) deposits of foreign banking sub sidiaries which are maintaine d Banks in accor dance with the re quirements set by t he respective Centr al Banks in thei r countries. 201 203 201 203 Guarantee s provided, mainly, on behalf of the Greek Government. 476 548 476 548 Placements pr ovided as guar antee for deri vative and other repu rchase agreements (repos). Placements pr ovided for L etter of Credit or Guarantee Letters that the Bank iss ues for 210 232 210 232 Due from facilitati ng customer import s. financial Placements pr ovided to the Resolution Fund as ir revocable pay ment commitment as part of the institutions 30 30 30 30 2016 up to 2023 cont ributi on. This commitment must be fully cove red by collater al exclusively in cash, as de cided by the Single Resolution Boar d. 23 23 Placements t o cover credit risk for issues at foreign subsidi aries 65 57 65 57 Placements us ed as coll ateral for the issuance of bonds held by the Group. 3,708 4,723 3,708 4,723 Loans pledge d to central banks for liquidit y purposes. Corporate loans, finance leas e receivables and credit cards sec uritizes for the iss uance of Special 489 515 489 515 Purpose Enti eties’ corpor ate bond held by t he Bank. Mortgage loan s used as co llateral for Covere d Bond Issuan ce Program II. The n ominal value of Loans and the afor ementioned bond s amounted to € 2,400 (31.12.2024: €2,400) out o f which the Ban k advances to 2,502 2,619 2,502 2,619 owns € 53 (31.12.2024: € 190) and has bee n pledged to Central Banks for liqui dity purposes and customers € 2,3 47 (31.12.2 024: €2,210) has bee n pledged as c ollateral in r epo transactions. 85 330 612 575 CLOs pledged as collateral in repo transactions Galaxy seni or bonds clas sified as loans at amort ised cost ple dged as collateral in repo 743 352 743 352 transact ions. 3 3 Greek Tre asury Bills have been pledged as coll ateral in repo tran sactions. Bonds iss ued by other gover nments pledged as c ollateral to t he Central Banks f or liquidity 834 474 834 474 purposes. Greek G overnment Bonds have been pledged as c ollateral to t he European Central B ank for 96 95 liquidity p urposes. 95 38 94 38 Greek G overnment Bonds pledged as a collateral in repo transactio ns (note 21) Investments Greek Tre asury Bills ple dged as collateral i n the context of derivative transacti ons with the 260 253 260 253 securities Greek St ate. 442 130 1,146 117 Other G overnment Bonds have been pledged as c ollateral in re po transactions. Greek G overnment Bonds have been pledged as c ollateral in t he context of deriv ative 22 3 22 3 transact ions with customers. Other c orporate bonds hav e been pledged as col lateral ic Cr edit Linked Note Issu ance 118 121 118 121 Programme. 309 247 672 658 Other c orporate bond s pledged as collateral in re po transactions. Total 11,261 11,380 12,797 12,011
Additionally,
a. In the context of derivative transactions with customers the Group and the Bank have also received Greek and other sovereign
Bonds of nominal value of € 12 (31.12.2024: € 4) and fair value of € 12 (31.12.2024: € 4) as collateral.
b. In the context of reverse repo transactions the Group has received bonds with a nominal value of € 1,763 (31.12.2024 € 994) and a
fair value of € 1,634 (31.12.2024: € 981) as collateral which are not included in its assets, while the Bank has received bonds with a
nominal value of € 1,892 (31.12.2024 € 1,189) and a fair value of € 1,761 (31.12.2024: € 1,164).
The above are not recognised on the Consolidated Statement of Balance Sheet.
e. Other information
In December 2024, following announcements by the Prime Minister and the Ministry of National Economy and Finance, systemic banks have
committed to invest € 100 for the establishment of the Fund for the Acquisition and Leasing of Real Estate. This Fund is specifically designed
to address the needs of vulnerable debtors who are facing bankruptcy or enforcement actions. Under the terms of the Fund, the debtor's
primary residence will be acquired following a formal transfer request. Subsequently, the property will be leased back to the debtor. The
leaseback period will extend to a maximum of 12 years, during which time the debtor will have the opportunity to exercise the right to
repurchase the property either during the lease or at its expiration.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
343 | ANNUAL FINANCIAL REPORT
46.
Group Consolidated Companies
The consolidated financial statements, apart from the parent company Alpha Bank S.A., include the following entities:
a. Subsidiaries
Group’s own ership Name Country interest % Audited y ear by tax au thorities up a nd includ ing: 31.12.2025 31.12.2024 Banks 1 Alpha Bank Lond on Ltd Un. Kingdom 100.00 100.00 2023 - volunt ary settlem ent of tax obl igatio n 2 Alpha Bank C yprus Ltd Cyprus 100.00 100.00 2017 - tax audi t in progre ss for the year s 2018-2021 Financing co mpanies *1 Alpha Leasing S.A.Greece 100.00 100.00 2020 – Withi n 2025, the tax audit f or the years 2 019-2020 wa s complete d 2 Alpha Leasing Ro mania IFN S.A. Romania 100.00 Company wa s sold within the year *3 ABC Factors S.A.Greece 100.00 100.00 2009 - The years up to and includin g 2019 are con sidered as au dited in accordance with the cir cular POL. 12 08/2017 4 Alpha Erev na Agoras S.M.S.A. Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2024 5 FlexFin S.A. Gre ec e 100.00 Tax unaudited since acqui sition in 2025 Investment B anking *1 Alpha Fina nce A.E.P.E.Y. Greece 100.00 100.00 2018 - The years up to and includin g 2019 are con sidered as au dited in accordance with the cir cular POL. 12 08/2017 The company ha s been audi ted by the tax autho rities up to and including 2009 in accor dance wi th Law 3 888/2010 whi ch relat es t o voluntary *2 Alpha Venture s S.A.Greece 100.00 100.00 settlement for the tax una udited year s. The year s up to and in cluding 2019 a re considere d as audite d in accordan ce wit h the circular POL. 1208/2017 The company ha s been audi ted by the tax autho rities up to and including 2009 in accor dance wi th Law 3 888/2010 whi ch relat es t o voluntary *3 Alpha S.A. Ve ntures Capital Manageme nt - AKES Greece 100.00 100.00 settlement for the tax una udited year s. The year s up to and in cluding 2019 a re considere d as audi ted in accorda nce with the circular POL. 1208/2017 4 Emporiki Vent ures Capita l Develo ped Markets Ltd Cyprus 100.00 100.00 2017 - Tax a udit is in progress for the year 2018-2019 5 Emporiki Vent ures Capita l Emergi ng Markets Ltd Cyprus 100.00 100.00 2017 - Tax a udit is in progress for the year 2018-2019 6 AXIA Venture s Group Lt d Cyp rus 100.00 2023 – The company wa s acquired wi thin 2025 Asset Manag ement The company ha s been audi ted by the tax autho rities up to and including 2009 in accor dance wi th Law 3 888/2010 whi ch relat es t o voluntary *1 Alpha Asset Management A.E.D.A.Κ.Greece 100.00 100.00 settlement for the tax una udited year s. The year s up to and in cluding 2019 a re considere d as audite d in accordan ce wit h the circular POL. 1208/2017 2 ABL Independent Financial Advisers Ltd Un. Kingdom 100.00 100.00 2023 - volunt ary settlem ent of tax obl igatio n Insurance 1 Alpha Insuran ce Brokers S.R.L. Romania 100.00 Company wa s sold within the year The company ha s been audi ted by the tax autho rities up to and including 2009 in accor dance wi th Law 3 888/2010 whi ch relat es t o voluntary *2 Alphali fe A.A.E.Z.Greece 100.00 100.00 settlement for the tax una udited year s. The year s up to and in cluding 2019 a re considere d as audite d in accordan ce wit h the circular POL. 1208/2017 3 Astrobank i nsurance age ncy Ltd Cyp rus 100.00 2019 - Tax u naudited sin ce acquisi tion in 2025 Real Estate an d Hotel *1 Alpha Re al Estate Servi ces S.A.Greece 89.28 93.17 2009 - The years up to and includin g 2019 are con sidered as au dited in accordance with the cir cular POL. 12 08/2017 *2 Alpha Re al Estate Mana gement and Inv estments S.A.Greece 100.00 100.00 2009 - The years up to and includin g 2019 are consi dered as audi ted in accor dance wi th the circul ar POL. 1208/20 17 3 Alpha Re al Estate Bulgari a E.O.O.D. Bulgaria 93.17 Company wa s liquidate d within the year
*
These companies received tax certificate for the years up to and including 2024 without any qualification.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
344 | ANNUAL FINANCIAL REPORT
Group’s own ership Name Country interest % Audited y ear by tax au thorities up a nd includ ing: 31.12.2025 31.12.2024 4 Alpha Re al Estate Servi ces S.R.L. Romania 89.28 93.17 Tax unaudited since comme ncement of its ope ration in 1998 Tax unaudited since comme ncement of its ope ration in 2012. The years up to and incl uding 2019 are considered a s audited in accordance wi th the **5 Alpha Inve stment Property A ttikis S.A Greece 100.00 100.00 circular PO L. 1208/201 7 ***6 Stockfort Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2010 - Tax audi t is in prog ress for the year 2020 ***7 Romfelt R eal Estate S.A.Romania 99.99 99.99 Tax unaudited since comme ncement of its acquisi tion in 201 5 8 AGI-RRE Posei don S.R.L. Romania 100.00 Company wa s liquidate d within the year 9 Alpha Re al Estate Servi ces LLC Cyprus 89.28 93.17 2017 - Comm encement of o peration 2010 - Tax audi t is in prog ress for the years 2018 a nd 2019 The company ha s been audi ted by the tax autho rities up to and including 2009 in accor dance wi th Law 3 888/2010 whi ch relat es t o voluntary *10 APE Fixed As sets S.A. Greece 72.20 72.20 settlement for the tax una udited year s. The year s up to and in cluding 2019 a re considere d as audite d in accordan ce wit h the circular POL. 1208/2017 ***11 Asmita Garden s S.R.L. Romania 100.00 100.00 Tax unaudited since comme ncement of its acquisi tion in 201 5 12 Cubic Center De velopment S.A. Romania 100.00 100.00 2020 - Comm encement of o peration 2010 13 AGI-SRE Partici pations 1 D.O.O. Serbia 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2016 Tax unaudited since comme ncement of its ope ration in 2017, the years up to and i ncluding 2019 are considered as audit ed in accordance wi th the **14 AIP Athens Commercial Assets I M.S.A. Greece 100.00 100.00 circular PO L. 1208/201 7 15 AGI-Cypre Property 2 Ltd Cyprus 100.00 Company wa s liquidate d within the year 16 AGI-Cypre Property 5 Ltd Cyprus 100.00 Company wa s liquidate d within the year 17 AGI-Cypre Property 7 Ltd Cyprus 100.00 Company wa s liquidate d within the year 18 AGI-Cypre Property 8 Ltd Cyprus 100.00 Company wa s liquidate d within the year 19 AGI-Cypre Property 15 Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2018 - Tax audi t is in prog ress for the year 2020 20 AGI-Cypre Property 17 Ltd Cyprus 100.00 100.00 2019 -Comme ncement of operation 2018 - Tax audi t is in progre ss for the year 2020 ***21 ABC RE P2 Lt d Cyprus 100.00 100.00 Commenceme nt of operat ion 2018 - Ta x audit i s in progress fo r the year 201 8-2019 22 ABC RE P3 Lt d Cyprus 100.00 100.00 2019 - Comm encement of o peration 2018 - Tax audi t is in prog ress for the year 2020 23 ABC RE L2 Lt d Cyprus 100.00 Company wa s sold within the year 24 AGI-Cypre Property 21 Ltd Cyprus 100.00 100.00 Commenceme nt of operat ion 2018 - Ta x audit i s in progress fo r the years 2018-2019 25 AGI-Cypre Property 24 Ltd Cyprus 100.00 Company wa s liquidate d within the year ***26 ABC RE L3 Lt d Cyprus 100.00 100.00 2019 - Comm encement of o peration 2018 - Tax audi t is in prog ress for the year 2020 ***27 ABC RE P&F Limassol Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2018 - Tax audi t is in prog ress for the year 2020 28 AGI-Cypre Property 25 Ltd Cyprus 100.00 100.00 2019 - Tax u naudited sin ce commen cement of its operati on in 2019 - Tax au dit is in pro gress for the yea r 2020 29 ABC RE RES Lar naca Ltd Cyprus 100.00 Company wa s liquidate d within the year 30 AGI Cypre Property 27 Ltd Cyprus 100.00 Company wa s liquidate d within the year 31 ABC RE L5 Lt d Cyprus 100.00 100.00 2019 - Tax u naudited sin ce commen cement of its operati on in 2019 - Tax au dit is in pro gress for the yea r 2020 32 AGI-Cypre Property 30 Ltd Cyprus 100.00 100.00 2019 - Tax u naudited sin ce commen cement of its operati on in 2019 - Tax au dit is in pro gress for the yea r 2020 **33 AIP Industrial Assets Athe ns S.M.S.A.Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 34 AGI-Cypre Property 33 Ltd Cyprus 100.00 Company wa s liquidate d within the year 35 AGI-Cypre Property 34 Ltd Cyprus 100.00 100.00 2019 - Tax u naudited sin ce commen cement of its operati on in 2019 - Tax au dit is in pro gress for the yea r 2020 36 Alpha Group R eal Estate Ltd Cyprus 100.00 100.00 2019 - Tax u naudited sin ce commen cement o f its operatio n in 2019- Tax a udit is in progre ss for the year 2020 37 ABC RE P&F Pafos Ltd Cyprus 100.00 Company wa s liquidate d within the year 38 ABC RE P&F Nicosia Ltd Cyprus 100.00 Company wa s liquidate d within the year 39 ABC RE RES Ni cosia Ltd Cyprus 100.00 Company wa s liquidate d within the year
*
These companies received tax certificate for the years up to and including 2024 without any qualification.
**
These companies received tax certificate for the years up to and including 2023 without any qualification.
***
These companies are under liquidation.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
345 | ANNUAL FINANCIAL REPORT
Group’s own ership Name Country interest % Audited y ear by tax au thorities up a nd includ ing: 31.12.2025 31.12.2024 **40 AIP Residential Assets Rog S.M.S.A.Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 **41 AIP Attica Re sidential A ssets I S.M.S.A.Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 **42 AIP Thessaloni ki Reside ntial Assets S.M.S.A.Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 *43 AIP Cretan Re sidential A ssets S.M.S.A. Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 **44 AIP Aegean Re sidential A ssets S.M.S.A Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 **45 AIP Ionian Resi dential A ssets S.M.S.A.Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 **46 AIP Attica Re sidential A ssets III S.M.S.A.Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 **47 AIP Attica Re sidential A ssets II S.M.S.A.Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 **48 AIP Land II S.M.S.A Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2019 49 AGI-Cypre Property 37 Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2019 - Tax audi t is in prog ress for the year 2020 50 AGI-Cypre Property 38 Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2019 - Tax audi t is in prog ress for the year 2020 ***51 Krigeo Holdi ngs Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2019 - Tax audi t is in prog ress for the year 2020 52 AGI-Cypre Property 40 Ltd Cyprus 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2020 53 ABC RE RES A mmochostos Ltd Cyprus 100.00 Company wa s liquidate d within the year 54 AGI-Cypre Property 47 Lim ited Cyprus 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2020 55 AGI-Cypre Property 48 Lim ited Cyprus 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2020 56 Alpha Credi t Property 1 Limited Cyprus 100.00 Company wa s liquidate d within the year 57 Acarta Constr uct SRL Romania 100.00 100.00 2013 58 AGI-Cypre Property 52 Lim ited Cyprus 100.00 Company wa s liquidate d within the year 59 S.C. Carmel Re sidential Srl Romania 100.00 Company wa s liquidate d within the year 60 AGI-Cypre Property 56 Lim ited Cyprus 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2022 **61 AIP Commerci al Assets ΙΙ S.M.S.A Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2022 62 AIP Attica Re tail Asset s IV S.M.S.A. Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2022 63 AIP Commerci al Assets II I S.M.S.A. Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2023 64 Abinvest II S.M.S.A. Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2024 65 Abinvest I S.M.S.A. Gre ec e 100.00 Tax unaudited since comme ncement of its ope ration in 2025 66 Abinvest III S.M.S.A. Gre ec e 100.00 Tax unaudited since comme ncement of its ope ration in 2025 67 AEP Oikistikon Akinito n Attikis V S.M.S.A. Gre ec e 100.00 Tax unaudited since comme ncement of its ope ration in 2025 68 AEP Perife reias II S.M.S.A. Gre ec e 100.00 Tax unaudited since comme ncement of its ope ration in 2025 69 Greco Delta S.M.S.A. ** Gre ec e 100.00 Tax unaudited since its acq uisition i n 2025 70 HIGR S.M.S.A. Gre ec e 100.00 Tax unaudited since its acq uisition i n 2025 71 Brawnido Ltd Cyp rus 100.00 2021 – The company wa s acquired wi thin 2025 72 Pandingmor Lt d Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 73 A.P.M. Contro l Company Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 74 A.P.M. First sun Compan y Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 75 Azulito Ve ntures Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 76 Bushtron Holdi ng Ltd Cyp rus 100.00 2020 - The company wa s acquired wi thin 2025 77 Catouna Ltd Cyp rus 100.00 2021 - The company wa s acquired wi thin 2025 78 Conaria Holdi ngs Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025
*
These companies received tax certificate for the years up to and including 2024 without any qualification.
**
These companies received tax certificate for the years up to and including 2023 without any qualification.
***
These companies are under liquidation.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
346 | ANNUAL FINANCIAL REPORT
Group’s own ership Name Country interest % Audited y ear by tax au thorities up a nd includ ing: 31.12.2025 31.12.2024 79 Dacibel Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 80 Firstplatinum Company Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 81 Gianteto Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 82 Kantadia Ventu res Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 83 Macerio Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 84 Martisio Ltd Cyp rus 100.00 2022 - The company wa s acquired wi thin 2025 85 Openstar Interna tional co mpany Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 86 Jiboka Ltd Cyp rus 100.00 2022 - The company wa s acquired wi thin 2025 87 Sabatia Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 88 Scaevola Ventu res Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 89 Serianio Ltd Cyp rus 100.00 2022 - The company wa s acquired wi thin 2025 90 Todero Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 91 Tomentos Holdi ngs Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 92 Viegiot Inve stments Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 93 Yurania Investme nts Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 94 KPMG M LS SERVICES Ltd Cyp rus 100.00 Tax unaudited since its acq uisition i n 2025 - o n 27.1.2 02 6 i t wa s ren am ed t o A v oni Lt d 95 Iolaos Ktimati ki S.M.S.A. Gre ec e 100.00 Tax unaudited since its acq uisition i n 2025 **96 Alkanor Μ.Α.Ε.Gre ec e 100.00 Tax unaudited since its acq uisition i n 2025 Special pur pose and ho lding entit ies 1 Alpha Group Inv estments Ltd Cyprus 100.00 100.00 2017 - Comm encement of o peration 2006 - Tax audi t is in prog ress for the years 2018 -201 9 2 Ionian Equity Participati ons Ltd Cyprus 100.00 100.00 2017 - Comm encement of o peration 2006 - Tax audi t is in prog ress for the years 2018 -201 9 ***3 AGI-BRE Parti cipations 1 Lt d Cyprus 100.00 100.00 2019 - Comm encement of o peration 2009 - Tax audi t is in prog ress for the year 2020 4 AGI-RRE Parti cipations 1 Lt d Cyprus 100.00 100.00 2019 - Comm encement of o peration 2009 - Tax audi t is in prog ress for the year 2020 5 Nigrinus Limi ted Cyprus 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2022 6 Epihiro Plc Un. Kingdom Company wa s liquidate d within the year 7 Irida Plc Un. Kingdom Company wa s liquidate d within the year 8 Pisti 2010-1 Plc Un. Kingdom 202 3 - volunt ary settleme nt of tax obl igation 9 AGI-RRE Posei don Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2012 - Tax audi t is in prog ress for the year 2020 ***10 AGI-RRE Hera Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2012 - Tax audi t is in prog ress for the year 2020 Tax unaudited since comme ncement of its ope ration in 2001, the years up to and includi ng 2019 are co nsidered a s audit ed in accordan ce with the **11 Alpha Hol dings S.Μ.S.A.Greece 100.00 100.00 circular PO L. 1208/201 7 ***12 AGI-BRE Parti cipations 2 Lt d Cyprus 100.00 100.00 2019 - Comm encement of o peration 2011 - Tax audi t is in prog ress for the year 2020 ***13 AGI-BRE Parti cipations 3 Lt d Cyprus 100.00 100.00 2017 - Comm encement of o peration 2011 - Tax audi t is in prog ress for the year 2018- 2019 ***14 AGI-BRE Parti cipations 4 Lt d Cyprus 100.00 100.00 2019 - Comm encement of o peration 2010 - Tax audi t is in prog ress for the year 2020 ***15 AGI-RRE Ares Ltd Cyprus 100.00 100.00 2020 - Comm encement of o peration 2010 - Tax audi t is in prog ress for the year 2021 16 AGI-RRE Artem is Ltd Cyprus 100.00 100.00 2017 - Comm encement of o peration 2012 - Tax audi t is in prog ress for the year 2018- 2019 ***17 AGI-BRE Parti cipations 5 Lt d Cyprus 100.00 100.00 2019 - Comm encement of o peration 2012 - Tax audi t is in prog ress for the year 2020 18 AGI-RRE Cle opatra Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2013 - Tax audi t is in prog ress for the year 2020 ***19 AGI-RRE Herme s Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2013 - Tax audi t is in prog ress for the year 2020 20 AGI-RRE Ar sinoe Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2013 - Tax audi t is in prog ress for the year 2020
**
These companies received tax certificate for the years up to and including 2022 without any qualification.
***
These companies are under liquidation.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
347 | ANNUAL FINANCIAL REPORT
Group’s own ership Name Country interest % Audited y ear by tax au thorities up a nd includ ing: 31.12.2025 31.12.2024 ***21 AGI-SRE Ariadni Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2013 - Tax audi t is in prog ress for the year 2020 22 Zerelda Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2012 - Tax audi t is in prog ress for the year 2020 23 AGI-Cypre Evagoras Ltd Cyprus 100.00 Company wa s liquidate d within the year ***24 AGI-Cypre Tersefanou Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2014 - Tax audi t is in prog ress for the year 2020 25 AGI-Cypre Ermis Ltd Cyprus 100.00 100.00 2016 - Comm encement of o peration 2014 - Tax audi t is in prog ress for the years 2017-20 21 26 AGI-SRE Partici pations 1 Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2016 - Tax audi t is in prog ress for the years 2020 27 Alpha Credi t Acquisition Com pany Ltd Cyprus 100.00 100.00 2021 - Comm encement of o peration 2019 **28 Alpha Interna tional Hol dings Μ.S.A.Greece 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2020 29 Sapava Li mi te d Cyp rus 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2020 30 Gemini Core Securitisati on Designate d Activ ity Company Ireland Tax unaudited since comme ncement of its ope ration in 2021 31 A.G. Star Gisam a Investme nts LTD Cyprus 100.00 100.00 Tax unaudited since comme ncement of its ope ration in 2024 32 FlexFin Ltd Cyp rus 100.00 Tax unaudited since comme ncement of its acquisi tion in 202 5 33 Dremikol Ltd Cyp rus 100.00 2021 - The company wa s acquired wi thin the fi scal year 34 Alpha Hol ding Luxembour g S.A. Luxembourg 100.00 Tax unaudited since comme ncement of its ope ration in 2025 35 KPMG INVES TMENTS Ltd Cyp rus 100.00 Tax unaudited since its acq uisition i n 2025 - o n 27.1.2 02 6 i t wa s ren am ed t o L ore l li Ltd Other com panies 1 Alpha Bank Lond on Nominee s Ltd Un. Kingdom 100.00 100.00 The company i s not subje ct to a tax audi t 2 Alpha Trustee s Ltd Cyprus 100.00 100.00 2019 - Comm encement of o peration 2002 - Tax audi t is in prog ress for the year 2020 3 Kafe Alpha S.A. Greece 100.00 Company wa s liquidate d within the year The company ha s been audi ted by the tax autho rities up to and including 2009 in accor dance wi th Law 3 888/2010 whi ch relat es t o voluntary **4 Alpha Supporti ng Service s S.A.Greece 100.00 100.00 settlement for the tax una udited year s. The year s up to and in cluding 2019 are considered a s audited i n accordan ce with the circular PO L. 1208/2017 5 Real Car Renta l S.A. Greece 100.00 Company wa s liquidate d within the year The company ha s been audi ted by the tax autho rities up to and including 2009 in accor dance wi th Law 3 888/2010 whi ch relat es t o voluntary **6 Emporiki Ma nagement S.A.Greece 100.00 100.00 settlement for the tax una udited year s. The year s up to and in cluding 2019 a re considere d as audite d in accordan ce wit h the circular POL. 1208/2017 Tax unaudited since comme ncement of its ope ration in 2015, the years up to and includi ng 2019 are co nsidered a s audit ed in accordan ce with the **7 Alpha Bank De bt Notifi cation Services S.A.Greece 100.00 100.00 circular PO L.1208/2017 8 Meribas Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025 9 Carbinor Consul tants Ltd Cyp rus 100.00 2019 - The company wa s acquired wi thin 2025
**
These companies received tax certificate for the years up to and including 2022 without any qualification.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
348 | ANNUAL FINANCIAL REPORT
b. Joint ventures
Group’s own ership intere st % Name Country 31.12.2025 31.12.2024 1 APE Commerci al Propert y S.A. Greece 72.20 72.20 2 APE Investm ent Propert y S.A. Greece 71.08 71.08 3 Alpha TANE O AKES Greece 51.00 51.00 4 Rosequeens Properties Ltd Cyrprus 33.33 33.33 5 Panarae Saturn LP Jersey 61.58 61.58 6 Alpha Inve stment Property Commer cial Stores S.A. Greece 70.00 70.00 7 Iside spv Srl Italy 8 Avramar S.A. Greece
c. Associates
Group’s own ership intere st % Name Country 31.12.2025 31.12.2024 1 Α EDEP Thes salias and Sterea s Ellados Greece 50.00 50.00 2 ALC Novel le Investme nts Ltd Cyrprus 33.33 3 Banking Info rmation S ystems S.A. Greece 23.77 23.77 4 Propindex AE DA Greece 34.87 35.58 5 Olganos S.A. Greece 30.69 30.69 6 Alpha Inve stment Property Elaiona S.A Greece 50.00 50.00 7 Zero Energ y Buildings Energy Service s S.A. Greece 43.87 43.87 8 Perigenis Commercial Assets S.A. Greece 32.00 32.00 9 Cepal Holdi ngs S.A. Greece 20.00 20.00 10 Aurora SME I DA C Ireland 11 Alpha Compas s DAC Ireland 12 Nexi Greece Payments In stitutions S.A. Greece 9.99 9.99 13 Alpha Bl ue Finance Designate d Activ ity Compan y Ireland 14 Toorbee Travel Services Limited Hong Kong 12.45 12.45 15 Reoco Solar S.A. Greece 26.46 26.46 16 Unicredit B ank S.A. Romania 9.90 9.90 17 Alpha Bank R omania S.A. Romania 9.90 18 Skyline Prope rties M.S.A. Greece 35.00 35.00
The Group has joint control over Avramar S.A and Iside spv S.R.L. and significant influence over Aurora SME I DAC, Alpha Compass DAC and Alpha Blue Finance Designated Activity Company, which are classified
as Joint ventures and Associates respectively. However, since the Group does not hold equity instruments issued by the above entities, accounting with the equity method is not applicable.
With respect to Avramar SA, it is noted that as a result of the acceleration of payments of credit facilities provided to the company, the lenders of Avramar S.A. have jointly taken possession of the voting rights
of the company and its subsidiaries from 16.7.2025.
On 15.8.2025, the merger of Alpha Bank Romania S.A. with UniCredit Bank S.A. (“UniCredit Romania”) was completed, forming a single banking entity in which Alpha International Holdings S.A., a wholly-owned
subsidiary of the Bank, holds a 9.9% stake. The merger lacked economic substance for the Group and therefore had no impact on the consolidated financial statements (note 55).
On 17.11.2025 Associate company A.L.C. Novelle Investments Ltd was liquidated and at the date of the liquidation no cash was held.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
349 | ANNUAL FINANCIAL REPORT
Group subsidiaries with non-controlling interest
The table as below provides information in relation with the Group subsidiaries with non controlling interest:
Non-controlli ng interests % Non-controlli ng interests % Name Country 31.12.2025 31.12.2024 31.12.2025 31.12.2024 1. APE Fixed Asset s S.A. Greece 27.8 27.8 11 11 2. Alpha Real Est ate Services S.A. Greece 10.72 6.83 8 5 3. Alpha Real Est ate Bulgari a E.O.O.D. Bulgaria - 6.83 4. Romfelt R eal Estate S.A. Romania 0.01 0.01 5. Alpha Real Est ate Services Sr l Romania 10.72 6.83 6. Alpha Real Est ate Services LL C Cyprus 10.72 6.83 Total 19 16
The percentage of voting rights held by third parties in subsidiaries does not differ with their participation in their share capital.
With respect to the above mentioned subsidiaries, significant non-controlling interests as at 31.12.2025 exist in Alpha Real Estate Services S.A.
and in APE Fixed Assets S.A.
A condensed set of financial information of Alpha Real Estate Services S.A. and APE Fixed Assets S.A. where Intra-group balances and
transactions have not been eliminated is presented below.
Condensed Statement of Total Comprehensive Income
Alpha Real Estate Services S.A. APE Fixed Asset s S.A. From 1 January to From 1 January to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Total inco me 21 23 Total expens es (14) (1 5) Profit/(loss) for th e year after inco me tax 7 8 - - Total comprehensi ve income for the year, after income t ax 7 8 - -
Condensed Balance Sheet
Alpha Real Estate Services S.A. APE Fixed Asset s S.A. 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Total non-curr ent assets 6 6 42 39 Total curr ent assets 71 70 Total shor t-term liabilities 7 9 Total long-term l iabilities 1 Total Equity 68 67 41 39
Condensed Cash flow statement
Alpha Real Estate Services S.A. APE Fixed Asset s S.A. From 1 January to From 1 January to 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Total inf lows/(outflows) from operating activit ies 2 18 Total inf lows/(outflows) from investing activit ies 8 17 Total inf lows/(outflows) from financing activit ies (7) (34) Total infl ows/(outflows) for the year 2 1 - - Cash and cash equi valents at th e beginni ng of the year 3 2 - - Cash and cash equi valents at th e end of the year 5 3 - -
The company Alpha Real Estate Services S.A. announced on 19.6.2025 the distribution of a dividend of a total amount of € 7. T he payment
was completed within the month of July 2025 (31.12.2024: € 4). The amount distributed to minority within the period was € 1.
Significant Restrictions
The Group’s significant restrictions regarding the use of assets or the settlement of liabilities, are those imposed by the r egulatory framework
in which its subsidiaries operate and concerns mainly those that are subject to supervision for their capital adequacy. In particular, the
regulatory authorities request, where appropriate and depending on the nature of the company, the compliance with specific thresholds, for
example maintaining minimum capital adequacy ratios, holding a predetermined level of highly liquid assets, minimizing their exposure to
other Group companies and complying with specified ratios. The total assets and liabilities of the subsidiaries operating in the banking,
insurance and other mainly financial sectors with significant restrict ions amount to €10,407 (31.12.2024: €75,459) and €9,227 (31.12.2024
€66,338) respectively.
In addition, all Greek subsidiaries are subject to the restrictions imposed by the regulatory framework (Codified Law 4548/20 18 or any other
specific legislation depending on the nature of their operations) regarding the minimum threshold of the share capital and net assets as well
as the ability to distribute dividends and to transfer equity shares.
There are no options of protection rights held by third parties in the share capital of subsidiaries that could otherwise limit the Group’s ability
to utilize those assets or settle the Group’s liabilities.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
350 | ANNUAL FINANCIAL REPORT
Consolidated structured entities
The Group as at 31.12.2025 consolidates the structured entities Pisti 2010-1 Plc and Gemini Core Securitisation Dac that serve securitization
transactions of loan portfolios originated by the Group. The Pisti securitization was established for liquidity purposes through the issuance of
notes, while the securitization of Gemini Core Securitisation Dac was established to serve the management of non performing loans. The
Group exercises control over these structured entities as it has authority over their activities and significant exposure to their returns. The
nominal value of notes issued per structured entity, all of which are held by the Group, is presented in note 34.
With regards to the Pisti transaction, depending on the eligibility criteria applicable to the securitized portfolio, the Group repurchases
securitized loans on a case-by-case basis, without however having a relevant contractual obligation. In addition, the Group securitizes new
loans in order to meet specific quantitative criteria related to the amount of the notes issued. The Group’s intention is to continue the above
practice. The Group has no contractual obligation to grant additional financing to Pisti 2010-1 Plc.
With regards to the Gemini non-performing loans securitization transaction, repurchases and new securitizations are carried out to ensure
that the eligibility criteria are met. Repurchases and new securitizations are not settled in cash but adjust the value of the bond issued by the
special purpose entity. The Group has no contractual obligation to provide additional financing to the above entity, but has undertaken the
commitment to issue letters of guarantee for Gemini Core Securitisation Dac up to a total limit of € 70 as at 31.12.2025, in exchange for the
collection of a commission. In case of forfeiture of any guarantee the amount paid becomes immediately due and, along with the commission,
is repaid through the deposit accounts the structured entity holds with the Bank in the context of the securitization transaction.
Changes of ownership interest in subsidiaries which did not result in loss of control
With in 2025, the Group ownership interest in subsidiaries Alpha Real Estate Services S.A., Alpha Real Estate Services S.R.L. and Alpha Real
Estate Services LLC decreased to 89.28% from 93.17%. The decrease in the percentage resulted in a decrease of € 3 to the equity attributable
to the shareholders of the Bank.
Loss of control in subsidiary due to sale or liquidation
In 2025, the following subsidiaries of the Group were liquidated:
Company AGI RRE Poseido n Srl Alpha Credit Property 1 Li mited AGI-Cypre Prope rty 2 Ltd AGI-Cypre Prope rty 52 Ltd Agi-Cypre Prope rty 5 Ltd Carmel Reside ntial Srl AGI-Cypre Prope rty 24 Ltd AGI-CYPRE Proper ty 7 Ltd ABC Re Res Larnaca Ltd Irida Plc AGI-Cypre Prope rty 27 Ltd Epihiro Plc ABC RE P&F Nico sia Ltd AGI-CYPRE Proper ty 33 Ltd ABC RE P&F Paf os Limited Real Car R ental S.A. ABC RE Res Ni cosia Limit ed AGI-CYPRE EVAGOR AS LTD ABC RE Res Ammoc hostos Lt d AGI-CYPRE PRO PERTY 8 LTD KAFE ALPHA S.A ALPHA REAL ES TATE BULGARIA E.O.O.D
• On 30.6.2025, the sale of the Group’s subsidiary ABC RE L2 Ltd was completed with no material impact on the consolidated Statement of
Profit and Loss. ABC RE L2 LIMITED 30.6.2025 Investment p roperty 3 Total Assets 3 Equity (3) Total Liabi lities and Equity (3)
• On 16.7.2025, the sale of Alpha Leasing Romania IFN S.A. and its subsidiary Alpha Insurance Brokers S.R.L. was completed, the group
recognised a loss of € 5 in the line “Discontinued operations” of the consolidated Statement of Profit and Loss.
Alpha Leasing Ro mania S.A. Alpha Insurance B rokers S.R.L. 16.7.2025 16.7.2025 Loans and adv ances to cust omers 26 Other ass ets 1 Total Assets 27 - Due to ban ks (20) Other liabi lities (1) Equity (6) Total Liabi lities and Equity (27) -
Exposure to non-consolidated structured entities
a. Mutual funds under Group Management
The Group, through its subsidiary Alpha Asset Management AEDAK, manages 68 (31.12.2024: 66) mutual funds which meet the definition of
structured entities and at each reporting date, it assesses whether it controls any of these according with the provisions of IFRS 10.
The Group, acting as the manager of the mutual funds has the ability to direct the activities which significantly affect the level of their return
by selecting the investments made by the funds within the framework of permitted investments as described in the regulation of each fund.
As a result, the Group has power over the mutual funds under management but within a clearly defined decision making framework.
Moreover the Group is exposed to variable returns through its involvement in the mutual funds as it receives fees for the purchase,
redemption and management of the funds under normal market levels for similar services. The Group also holds direct investments in some
of the funds under management, the level of which is assessed to be determined whether it leads to a significant variability in its returns
compared to the variability of the respective total rate of return of the mutual fund. Due to these factors, the Group assessed that, for all
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
351 | ANNUAL FINANCIAL REPORT
mutual funds under management, it exercises, for the benefit of unit holders, the decision making rights assigned to it acting as an agent
without controlling the mutual funds.
The following table presents the total assets of the mutual funds under management but not controlled by the Group by category of
investment. During the year 2025, the commission income from the management fees of these Mutual Funds amounted to €69 (31.12.2024:
€ 52).
Total Assets 31.12.2025 31.12.2024 Category of M utual Funds Bond Funds 2,714 2,740 Money Mar ket Funds 25 35 Equity Funds 1,293 927 Balanced Funds 1,751 1,272 Total 5,783 4,974
The direct investment of the Group in the above mutual funds was classified, in the portfolio of investment securities measured at fair value
through profit or loss. The carrying amount of the investment in mutual funds as at 31.12.2025 amounts to €696 (31.12.2024: €556). The
change in the fair value of the aforementioned mutual funds during the year 2025 resulted in a gain of €44 (year 2024: gain of €33). It is
noted that there is no contractual obligation for the Group to provide financial support to any of the mutual funds under management nor
does it guarantee their rate of return.
b. Securitisation non-consolidated structured entities
The Group holds 100% of the senior notes and 5% of the mezzanine and junior notes that were issued in the context of non-performing loan
securitisation transactions by the structured entities Orion X Securitisation DAC, Galaxy II Funding DAC, Galaxy IV Funding DAC, Cosmos
Securitisation DAC, Gaia Securitisation DAC and Gaia II Securitisation DAC. The Group does not exercise control over the activities of the above
entities. The following table presents the carrying amount of notes that the Group holds and the related results.
Profit or Loss 31.12.2 025 Carrying Am ount Gain Less Loss es on 31.12.2025 Interest Income Impairment Loss es Financial Transacti ons Loans and Advance s to Custo mers measured at Amo rtised Cost Notes i ssued by special pur pose entities 5,074 40 Loans and Advance s to Custo mers measured at fair valu e through profit or loss Notes i ssued by special pur pose entities 2 2 Profit or Loss 31.12.2 024 Carrying Am ount Gain Less Loss es on 31.12.2024 Interest Income Impairment Loss es Financial Transacti ons Loans and Advance s to Custo mers measured at Amo rtised Cost Notes i ssued by special pur pose entities 4,902 27 4 Loans and Advance s to Custo mers measured at fair valu e through profit or loss Notes i ssued by special pur pose entities 1 1
The aforementioned special purpose entities maintain cash deposits with the Group amounting to € 214 as at 31.12.2025 (31.12.2024: € 222).
The total nominal value of notes issued from the above entities as at 31.12.2025 amounts to € 14.4 bil. (31.12.2024: € 13.6 bil.).
The Group has granted loans with a carrying amount of € 89 (31.12.2024: € 99) to the special purpose entities Orion X Securit isation DAC,
Galaxy II Funding DAC, Galaxy IV Funding DAC, Cosmos Securitisation DAC, Gaia Securitisation DAC and Gaia II Securitisation DAC for the
purpose of financing their reserves. The net income recognized by the Group from the above loans in 2025 amounted to € 1 (2024: € 1).
In connection with the Group’s commitments resulting from these securitisation transactions, it should be noted that the tran sferred
securitized portfolios included letters of guarantee. In case of forfeiture of any of them, the payment to the third party (to whom the letter of
guarantee is addressed) is made from special deposit accounts, with reserved balances, held by the aforementioned special purpose entities
with the Group.
Moreover, the Group has committed to issue letters of guarantee for the above securitiz ation companies up to the total amount of € 565,
through a relevant loan facility limit, for which a commission is received. In case of forfeiture of any guarantee, the amount paid becomes
immediately due and the capital amount is repaid through the securitization current accounts, while the amount of interest and other
commissions is repaid through the reserves of the securitisation company and in case these are not sufficient, it takes a high order priority of
payment and is repaid on the coupon payment dates of the bonds.
It is noted that the Group has committed to provide financing, on behalf of the aforementioned securitization entities, to the special purpose
entities set up for the acquisition of properties or shareholdings (REOCOs), through the signing of bond loan agreements. In the event that a
relevant loan is required to be granted under these contracts, this is transferred directly to the securitization company that holds the
securitized portfolio, with an advance payment of the transfer consideration, from a relevant reserve that is held by the securitization
company. In the event that the consideration is not paid in advance, the Group is not obliged to proceed with the loan disbursement and
therefore the Group’s exposure to credit risk from the above transaction is zero. It is noted that the legal transfer of said claims has already
taken place at the time of the securitization in the form of a transfer of future claims under the specific bond loans. The above companies
have deposits with the Group of € 40 as at 31.12.2025 (31.12.2024: € 31).
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352 | ANNUAL FINANCIAL REPORT
The aforementioned carrying amounts of bonds and loans, together with the commitments of the Group to provide loans and guarantees,
constitute the maximum possible exposure of the Group to the special purpose entities, established in the context of the Galaxy, Cosmos and
Gaia transactions.
The Group, in the context of loan portfolios’ synthetic securitisation transactions, has entered into financial guarantee contracts with special
purpose entities for the acquisition of credit protection for a part of the credit risk losses of securitized loan portfolios. The special purpose
entities have issued bonds that were covered by third parties not affiliated with the Group, and the proceeds from their issuance are
collateral for the Group’s compensation in case of forfeiture of the guarantee.
The Group has significant influence over these entities since, although their activities are predetermined, it reserves the right to make
decisions on specific core activities that mainly relate with the management of the collateral and its investment in eligible securities according
to predetermined criteria. Since there is no Group exposure to the equity instruments of the above entities, the equity method is not
applicable. The Group pays a commission to the special purpose entities for the provision of the guarantee and has also undertaken to cover
their expenses. As at 31.12.2025, synthetic securitization transactions through Alpha Compass DAC and Alpha Blue Finance DAC were in force,
while the transaction established through Aurora SME I DAC was terminated during the last quarter of 2025. The related expens es recognized
in 2025 amounted to € 34 (2024: € 45). The nominal value of the bonds issued by these entities amounted to € 174 (31.12.2024: € 376).
The Group participates, jointly with another lender, in the financing of the special purpose entity Iside Spv Srl, which was established for the
purpose of financing a real estate investment company in the context of the Italian Securitization Law. Based on this law, the financing
provided to the special purpose entity is collateralized with mortgages of the ultimate debtor, while the repayment of the financing reflects
the repayment schedule of the loan granted by the special purpose entity to the ultimate debtor. As the company’s main activity is related to
its issued bonds, for which decisions are taken jointly with the other lender, the Group has joint control over the special purpose entity. The
amount of said financing as of 31.12.2025 € 26 (31.12.2024: € 49), while the net results recognized in the Group accounts from said financing
amount to a gain € 2 (2024: € 4).
c. Other Special structured entities
In addition, the Group has investments in special purpose entities through its participation in venture capital mutual funds which it does not
manage as well as in companies subject to the issuance of securities secured by its assets (asset-backed securities). The following table
analyzes the said participations of the Group. As an indication of the size of the non-consolidated structured entities the total assets of the
funds based on most recent available balance sheet and the total nominal value of asset-backed securities are given.
Carrying Amount Total Assets / No minal Value 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Structured Entit y category Investment securiti es measured at f air value through O CI Venture c apital mutual fun ds 14 13 615 467 Asset- backed securities 92 124 Investment securiti es at fair val ue through profi t or loss Asset- backed securities 10 10 29 29 Investments in a ssociates and joint v entures Venture c apital mutual fun ds 2 1 2 3
The Group is committed to participating in additional investments in the aforementioned mutual funds up to a total amount of €14
(31.12.2024: €13). This commitment, together with the carrying value of the investment, represents the Group's maximum exposure to these
investments.
From its shares in asset-backed securities, the Group recognized interest income of € 2 for the 2025 financial year (31.12.2024: €1) and no
gains or losses (31.12.2024: € 0) were recognized in the Statement of profit or loss.
The Group has no contractual obligation to provide financial support to the entities that issued these securities. The maximum potential
exposure of the Group to losses from asset-backed securities is consistent with their carrying value.
47.
Disclosures Law 4261/5.5.2014
Article 81 of Law 4261/5.5.2014 transposed into Greek legislation the Article 89 of Directive 2013/36/EU of the European Parliament and of
the Council of 26 June 2013, according to which, it is enacted for first time the obligation to disclose information on a consolidated basis by
Member State and third country in which the Group has a head office as follows: company name or company names, nature of operations,
geographic location, turnover, results before tax, income tax, public subsidies received and the number of full time employees.
The quantitative information required is set out below by geographical area. Note 46 presents in detail the subsidiaries included in each
geographical area as well as the nature of the activity of each company.
Greece United Kingdo m Cyprus Romania Bulgaria Turnover 5,090 49 180 10 - Profit B efore Taxes 1,195 (3) 30 8 - Income tax Expens e 29 1 (4) (1) - Number of e mployees 6,136 97 772 12 1
It is noted that neither the Company nor the Group companies have received amounts related to public subsidies.
Article 82 of Law 4261/5.5.2014 transposed into Greek Law article 90 of Directive 2013/36/EU of the European Parliament and of the Council
of 26 June 2013, which establishes for the first time the requirement to disclose total return on assets. The total return on the assets of the
Group for the year 2025 amounts to 1.26%.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
353 | ANNUAL FINANCIAL REPORT
48.
Segment Reporting
a. Operating Segments
The Executive Committee is the chief operating decision maker and monitors internal reporting on the Group operating segments’
performance based on which segments’ results against targets are evaluated and allocation of resources is decided.
1.1 – 31.12.2025 Non Corporate Wealth International Retail Wholesale Performing Center/Elimination Group Management Activities Assets Center Net int erest income 577 744 15 124 25 113 1,598 Net fee and commission inc ome 138 15 5 159 22 2 47 6 Other i ncome 15 53 9 15 (27) 28 93 Net inc ome from investment property management 17 17 Total income 730 952 183 161 - 158 2,184 Of which i ncome between o perating segment 9 89 15 (9) (104) - Total expenses (391) (186) (68) (98) (48) (59) (850) Impairment loss es and prov isions to cover cr edit risk and (74) (45) 3 (280) (1) (397) other r elated expenses Impairment loss es on other f inancial instrume nts (2) (2) Impairment loss es on fixe d assets and equity investments (12) (15) (1) (6) (17) (51) Gains/(Loss es) on disposal of fixed assets and e quity (1) (1) 2 7 7 investment s Provisions and transfor mation costs (20) (24) (2) 5 18 (7) (30) Share of pr ofit/(loss) of asso ciates and joint v entures 40 3 43 Profit/(loss) befo re income tax 233 681 112 110 (314) 82 904 Income tax 15 Net profit/(loss) fro m continuing operations for th e year 919 after income tax Net pro fit/(loss) for the year after income tax fr om 29 (5) 24 disconti nued operations Net profit/(loss) for t he year 943 Assets 31.12.2025 12,630 34,778 286 7,624 2,041 20,099 77,458 Liabilitie s 31.12.2025 36,652 10,687 2,349 6,824 393 11,729 68,634 Capital expe nditure 103 37 5 12 8 332 497 Depreci ation and Amortizati on (74) (30) (10) (7) (7) (3) (131) Investments in associates and joint ventures 360 216 576
Profit before income tax of the operating segment named “Corporate Center/Elimination Center” of a total amount of € 83.9 include
expenses from eliminations between operating segments amounting in total of € 1.5.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
354 | ANNUAL FINANCIAL REPORT
1.1 – 31.12.202 4 Non Corporate Wealth International Retail Wholesale Performing Center/Eliminati on Group Management Activities Assets Center Net int erest income 621 737 15 131 27 114 1,645 Net fee and commission inc ome 150 132 114 19 5 420 Other i ncome 17 39 7 5 81 149 Net inc ome from investment property management (3) (3) Total income 788 908 136 155 32 192 2,211 Of which i ncome between o perating segment 20 93 12 (4) (121) Total expenses (411) (181) (57) (79) (54) (70) (852) Impairment loss es and prov isions to cover cr edit risk and (23) (43) (2) (384) (452) other r elated expenses Impairment loss es on other f inancial instrume nts (1) (1) Impairment loss es on fixe d assets and equity investments (3) (10) (13) Gains/(Loss es) on disposal of fixed assets and e quity 25 2 27 investment s Provisions and transfor mation costs (47) (17) (5) (5) (3) (22) (99) Share of pr ofit/(loss) of asso ciates and joint v entures (3) (3) Profit/(loss) befo re income tax 307 667 74 69 (387) 88 818 Income tax (221) Net profit/(loss) fro m continuing operations for th e year 307 667 74 69 (387) 88 597 after income tax Net pro fit/(loss) for the year after income tax fr om 24 33 57 disconti nued operations Net profit/(loss) for t he year 654 Assets 31.12.2024 12,9 73 31,665 159 4,828 2,436 20,041 72,102 Liabilitie s 31.12.2024 35,700 10,786 2,025 4,161 405 10,808 63,8 85 Capital expe nditure 83 25 4 7 24 9 152 Depreci ation and Amortizati on (102) (41) (10) (6) (9) (6) (174) Investments in associates and joint ventures 329 242 571
Profit before income tax of the operating segment named “Corporate Center/Elimination Center” of a total amount of € 86 include income
from eliminations between operating segments amounting in total of € 0.3.
i. Retail
All Individuals (retail banking customers), self-employed professionals, small and very small companies operating in Greece. This operating
segment offers all types of deposit products (saving accounts, current accounts, term deposits etc.), debit and credit cards, credit facilities
(mortgages, consumer, business loans, leasing products, factoring services, letters of guarantee/letters of credit etc.). In addition, it includes
insurance and bancassurance products.
ii. Wholesale
All medium-sized and large companies including shipping corporations and enterprises which cooperate with the Wholesale Banking and
Investment Banking Divisions. This operating segment offers working capital facilities, corporate loans, leasing products, factoring services,
letters of guarantee/letters of credit etc. It also offers investment banking services including corporate finance. It also includes the execution
of trading activities in the interbank market (FX, bonds, derivatives, money market, etc.).
iii. Wealth Management
Wealth management services offered to all client segments through the Private Banking units, the subsidiaries Alpha Finance and Alpha Asset
Management A.E.D.A.K. as well as revenues from the sale and management of mutual funds.
iv. International
All products and services offered through the international network in Cyprus, Romania and United Kingdom.
v. Non-performing assets
This operating segment includes the management of non-performing assets in Group, as well as any company established to manage these
assets and related real estate. In addition, participations and shares from loan recoveries are included.
vi. Corporate Center
Includes activities under the management of the Chief Investment Officer related to the Group’s liquidity, funding, capital, structural interest
rate and foreign exchange risks, as well as investments in non-commercial assets (incl. securities at amortised cost and investment property).
This segment also includes other Group operations not allocated to specific operating segments, as well as intersegment eliminations.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
355 | ANNUAL FINANCIAL REPORT
b. Geographical segments
The breakdown by geographical segment is defined by the country of the business operations of the Group company.
1.1 - 31.1 2.2025 Greece Other countries Group Net int erest income 1,476 122 1,598 Net fee and commission inc ome 45 4 22 47 6 Other i ncome 83 10 93 Net inc ome from investment property management 11 6 17 Total income 2,024 160 2,184 Total expenses (748) (102) (850) Impairment loss es and prov isions to cover cr edit risk and relat ed expenses (380) (17) (397) Impairment loss es on other f inancial instrume nts (2) (2) Impairment loss es on fixe d assets and equity investments (51) (51) Gains/(Loss es) on disposal of fixed assets and e quity investments 8 (1) 7 Provisions and transfor mation costs (38) 8 (30) Share of pr ofit/(loss) of asso ciates and joint v entures 3 40 43 Profit/(loss) befo re income tax 816 88 904 Income tax 15 Net profit/(loss) fro m continuing operations for th e year after i ncome tax 919 Net pro fit/(loss) for the year after income tax fr om disconti nued operations 29 (5) 24 Net profit/(loss) for t he year 943 Non curr ent assets 31.12.2025 1,470 215 1,685 1.1 - 31.1 2.2024 Greece Other countries Group Net int erest income 1,513 132 1,645 Net fee and commission inc ome 401 19 420 Other i ncome 144 5 149 Net inc ome from investment property management (3) (3) Total income 2,055 156 2,211 Total expenses (771) (81) (852) Impairment loss es and prov isions to cover cr edit risk and relat ed expenses (427) (25) (452) Impairment loss es on other f inancial instrume nts (1) (1) Impairment loss es on fixe d assets and equity investments (13) (13) Gains/(Loss es) on disposal of fixed assets and e quity investments 27 27 Provisions and transfor mation costs (93) (6) (99) Share of pr ofit/(loss) of asso ciates and joint v entures (3) (3) Profit/(loss) befo re income tax 773 44 818 Income tax (221) Net profit/(loss) fro m continuing operations for th e year after i ncome tax 597 Net pro fit/(loss) for the year after income tax fr om disconti nued operations 24 33 57 Net profit/(loss) for t he year 654 Non curr ent assets 31.12.2024 1,256 38 1,294
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
356 | ANNUAL FINANCIAL REPORT
49.
Risk Management
The Group and the Bank have designed and implement a framework for managing the risks it faces, taking into account the best banking
practices and regulatory requirements. In accordance with common European legislation and the current system of common banking rules,
principles and standards, this system is constantly evolving to ensure that the Group's corporate governance is effective.
1. RISK MANAGEMENT FRAMEWORK
1.1 Risk Management Governance
The Board of Directors (BoD) supervises the overall operations of the Risk Management Function. The BoD has established a Board Risk
Management Committee (RMC), which convenes, on a monthly basis and reports to the Board of Directors. The Committee recommends to
the Board of Directors the risk undertaking and capital management strategy, checks its implementation and evaluates its adequacy and
effectiveness.
The risk management framework and its effectiveness are reassessed on a regular basis, in order to ensure compliance with best practices as
well as the supervisory and regulatory requirements.
For a more comprehensive and effective identification and monitoring of all types of risks, Management Committees have been established
(Assets and Liabilities Management Committee, Non - Financial Risks and Internal Control Committee, Credit Risk Committee,
Group
Sustainability Committee and Reputational Risk Committee).
1.2 Risk management Unit
The Group Chief Risk Officer supervises the Group’s and Bank’s Risk Management Function. Under the responsibility of the Risk Management
Function regular and ad hoc reports are submitted to the Management Committees, the Risk Management Committee and the Group’s
Board of Directors. These reports cover the management of all types of risks. As far as credit risk is concerned the reporting covers the
following areas:
• The risk profile of portfolios by rating grade.
• The transition among rating grades (migration matrix).
• The estimation of the relevant risk parameters by rating grade, group of clients, etc.
• The trends of basic rating criteria.
• The changes in the rating process, the criteria or in each specific parameter.
• The concentration risk (by risk type, sector, country, collateral, portfolio etc.).
• The evolution of Loan exposures, +90 days past due loans, Non-Performing exposures and the monitoring of KPIs on a Group basis.
• The Cost of Risk.
• The IFRS 9 Staging transition of exposures per asset class.
• The maximum risk appetite (credit risk appetite) per country, sector, currency, Business Unit, limit breaches and mitigation plans.
1.3 Organizational Structure
The following Risk Management Business Areas operate under the supervision of the Group Chief Risk Officer in the Group, that have the
responsibility for the immediate implementation of risk management framework in accordance with the guidelines of the Risk Management
Committee.
• Chief Risk Control Officer
- Credit Risk and Enterprise Risk Modelling
- Credit Control
- Climate, ESG and Enterprise Risk Management
- Non-Financial Risks Control
- Market Risk Control
• Chief Credit Officer
- Wholesale Credit
- Retail Credit
• Risk Models and Data Validation
49.1
Credit Risk
For credit risk management purposes, lending facilities are separated into Wholesale and Retail as described below.
1. WHOLESALE BANKING CREDIT FACILITIES
Wholesale Banking credit facilities are provided to companies with a turnover > € 10 million or with a credit limit > € 1 mil lion.
1.1 Credit Assessment Process
The Group and the Bank, following best international practices and taking into account the prevailing institutional framework set by
legislation, regulations, ministerial decrees/decisions etc., has designed a robust credit risk framework, where the main principles, guidelines,
procedures followed and the responsibilities of involved Business Areas and Relationship Managers are clearly defined, based on the four
eyes principle.
In this context, all credit proposals are prepared by the Product Business Areas, are reviewed by the competent Credit Business Areas and are
assessed by the competent Credit Committee based on the total credit exposure, the obligor’s credit risk rating, the provided collaterals and
the Environmental, Social and Governance Risk (ESG) rating at obligor, transaction and overall level.
The limits of the Wholesale Banking Credit Committees are determined in accordance with the Total Credit Risk, which is defined as the
aggregate of all credit facilities to a single company or group of related companies including any financing provided to their owners which can
be approved by the Group.
Credit Committees decide on:
•
Approval of the terms of new loans, renegotiations or restructuring of existing credit facilities.
•
Approval of the loan pricing, considering the overall profitability of a client’s relationship based on the Risk Adjusted Ret urn on Risk
Adjusted Capital - RARORAC (historical RARORAC – RARORAC based on the outcome of the proposed suggestion).
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•
Credit Limit Expiration/Renewal date (depending on the customer’s credit risk zone) and any deviations from the rule.
•
Amendment on the collateral structure.
•
Decision for actions in case of activation of early warning triggers.
•
Financial Difficulty assessment.
•
Unlikeliness to Pay (UTP) assessment.
•
Credit Rating grading.
•
Environmental, Social and Governance (ESG) risk rating at obligor, transaction, and overall level.
1.2 Credit Risk Measurement and Internal Ratings
The assessment of the borrowers’ creditworthiness and their scaling into credit risk categories is performed through rating s ystems.
The objective of the credit risk rating systems, for Wholesale Banking Customers, is the estimation of the probability that the borrowers will
not meet their contractual obligations to the Group and the estimation of the Expected Credit Loss.
The rating of the Group’s and Bank’s borrowers with the use of credit risk rating systems constitutes a basic tool for:
•
The decision-making process of Credit Committees for the approval/ renewal of credit limits and the implementation of the
appropriate pricing policy (interest rate spreads etc.).
•
The estimation of the future behavior of borrowers which belong to a group with similar characteristics.
•
The timely identification of potential troubled credit facilities and the prompt plan of the required actions for the minimization of
the expected loss for the Group and the Bank.
•
The assessment of the Group’s loan portfolio quality and the credit risk undertaken.
The rating systems employed by the Bank and the Group entities are the Alpha Bank Rating System (ABRS) and Moody’s Credit Len s which
incorporate different credit rating models (including Slotting scorecards).
All current and potential clients of the Group are assessed based on the appropriate credit risk rating model and within the predefined time
frames.
For the estimation of the probability of default of the borrowers of the Group and the Bank, the credit risk rating models evaluate a number
of parameters, which can be grouped as follows:
•
Financial analysis: borrower’s Financial Ability (liquidity ratios, debt to income, etc.)
•
Borrower’s position in the market environment in which operates compared to its competitors in the sector it belongs.
•
Transactional behavior of the borrower both to the Group and third parties (debt in arrears, adverse transaction records, etc).
•
Borrower’s qualitative characteristics (integrity and succession plan of the management, management skills etc.).
The credit rating models which are currently employed by the Group are differentiated according to:
•
The turnover of the companies.
•
The level of the total credit risk of the companies.
•
The credit facility’s specific characteristics.
•
The available information for the borrower’s assessment. Specifically, for the financial analysis the differentiation relates to the type
of the local accounting standards applied, the accounting framework applied (financial services, insurance services etc.) and
whether the financial statements are prepared in accordance with the International Financial Reporting Standards.
For each of the credit rating models, different parameters may be used, each of which contributes in a specific manner the relevant
assessment.
1.3 Borrowers Rating Scale
Borrowers are rated in the following rating scales: ΑΑ, Α+, Α, A-, ΒΒ+, ΒΒ, ΒΒ-, B+, Β, Β-, CC+, CC, CC-, C, D, D0, D1, D2
For special purpose finance (Structured Finance and Shipping Financing) special models have been designed (slotting) with the following
categorization scale:
Strong (Category 1), Good (Category 2), Satisfactory (Category 3), Weak (Category 4), Default (D, D0, D1, D2).
The mapping of the above Ratings to Credit Risk Zones follows:
Credit Risk Zones Rating Scale Specialized Lendi ng Categorization ΑΑ Α+ Low Α Strong (Category 1) Α- ΒΒ+ ΒΒ Medium ΒΒ- Good (Category 2) Β+ Β Acceptabl e Satisfact ory (Category 3) Β- CC+ Moderate Risk – Watch List - CC CC- High Weak (Category 4) C Default stat us: With object ive trigger ev ents of inability t o pay their obligati ons D In arrears D0 Default Denouncement of Loan Agree ment D1 Issuance of a Payment Orde r D2 There is no one to one mapping between credit risk r ating models and special purpose finance models (slotting) and especially as it regards
Watch List rating category, as presented above.
2. RETAIL BANKING CREDIT FACILITIES
Retail banking involves the lending facilities offered by the Group and the Bank and fall under one of the following categories:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
358 | ANNUAL FINANCIAL REPORT
•
Housing loans/Mortgages
•
Consumer Loans and Credit Cards
•
Small businesses (SB): Entrepreneurs with credit limit up to Euro 1 million and Personal Companies and Legal entities with turnover
up to Euro 10 million and credit limit up to Euro 1 million.
2.1 Credit Assessment Process
The Group has developed and implements a credit policy framework (taking into account the legislative and supervisory /regulatory
framework) on which the Group’s Retail Banking lending procedures are based on. Additionally, it has developed and put into e ffect a system
of key principles, processes and internal operating rules that are govern its lending activities and ensure the smooth and safe management of
the risk undertaken.
The main principles and rules that are applicable for the operations of Retail Banking lending are the following:
•
Sound lending management.
•
Prudent customer selection based on specific credit criteria.
•
Correlation of risks and returns and development of a pricing policy, loans’ coverage with collaterals taking into account th e credit
risk.
•
Monitoring and management of the Total Credit Risk, which refers to the aggregate amount of all revolving limits of the obligor, the
balances of one-off lending facilities and specifically for small businesses the total balance of the approved lending facilities
provided to the companies’ stakeholders. Additionally, lending facilities for which the customer is guarantor or co-debtor are also
considered.
Individuals: The credit approval process for individuals (persons with income from salaries, pensions or other sources of income not relat ed
with business activities) is performed based on the classification of borrowers into risk groups, which represent a specific level of undertaken
risk. The level of risk undertaken by the Group and the Bank is adjusted, when deemed necessary, according to its credit policy.
Small Businesses: The creditworthiness of Small Businesses fall under the responsibility of the Retail Banking is heavily related to the
creditworthiness of the company’s stakeholders/managers of the company and vice versa. Therefore, the assessment of the appli cations in
this category is based on two dimensions:
•
The assessment of the creditworthiness of company’s stakeholders or business managers and the guarantors.
•
The assessment of the creditworthiness of the company.
2.2 Internal models
The fundamental parameter in measuring the credit risk of Retail Banking is the credit risk models developed and utilized throughout the
credit risk cycle, both for the Bank and the Group companies. The abovementioned models segment the population into homogeneous risk
groups (pools) and are categorized into:
•
Behavior Models, which assess the client’s behavior and predict the probability of default within the following months.
•
Application Credit Scoring Models. These models assess application data, mainly demographic and predict the probability of default
within the following months.
These models and the estimations for the probability of default that derive from them play a significant role in risk management and decision-
making process throughout the Group’s operations. The areas that these models are used are the following:
•
Decision-making process for granting /renewal of credit limit.
•
Impairment assessment.
•
Forecasting the future behavior of clients that belong in pool with similar characteristics.
•
The timely identification of potential troubled credit facilities and the prompt plan of required actions for the minimization of the
expected loss for the Group and the Bank.
•
The assessment of the Group’s loan portfolio quality and the credit risk undertaken.
The parameters considered vary, according to the model’s type and product category that it assesses. Indicatively, some facto rs are:
•
Personal / demographic data, like the customer’s age, profession, marital status, or current address.
•
Loan characteristics, like the product applied for, loan term in the portfolio, the purpose of financing.
•
Behavioral data of loan during a recent period, like payments during the most recent period, maximum delinquency, outstanding
loan balance versus loan limit and the transaction type.
•
Qualitative data, like the activity sector and the company type.
Models are validated and updated on an annual basis and are subject to constant quality control, to ensure their predictive ability at any point
in time.
Furthermore, on a regular basis the Group and the Bank conducts exercises simulating crisis situations (Stress Tests), which explore the
potential impact on the financial results of the Group due to unfavorable developments both in obligors’ transactional behavior, as well as in
the broader financial economic environment.
For presentation purposes of the table “Loans by credit quality and IFRS 9 Stage” for Retail Banking Loans the classification in “Strong”,
“Satisfactory” and “Watchlist” categories, is generally based on the twelve-month Probability of Default, weighted by the three IFRS9 macro
scenarios, as well as the Staging criteria and EBA status. Specifically, for Alpha Bank Greece, the range of probabilities that determines this
classification, was derived from an analysis aiming at optimizing the discriminatory power between categories.
Therefore, ranges might differ per portfolio and per subsidiary. For the Bank, the range of probability of default which defines the
classification of a loan is presented in the table below:
Range of probability of default Rating Classification Mortgages Consumer Credit cards Small Businesses Strong up to 5% up to 5% up to 3% up to 5% Satisfactory from 5% up to 13% from 5% up to 13% from 3% up to 13% from 5% up to 13% Watchlist over 13% over 13% over 13% over 13%
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
359 | ANNUAL FINANCIAL REPORT
CREDIT CONTROL
According to risk management and control framework, there are three “lines of defense” with distinctive roles and responsibil ities, with
Business and Operations Units being the first “line of defense”, Risk Management Units the second “line of defense” and the Internal Audit
Unit the third “line of defense”.
In the context of the operation of the second “line of defense” and within the single context of operations set out for the s ectors of Retail
Banking, Wholesale Banking and Wealth Management, the Group carries out credit controls in order to optimize Credit Risk management, to
confirm the quality of the loan portfolio and ensure that the first “line of defense” operates within the framework set out f or effective Credit
Risk management.
The operation of the second “line of defense” is independent and aims, a mong else, to:
•
Design and develop procedures and controls for credit risk management.
•
Monitor the adequacy and effectiveness of existing credit risk management procedures.
•
Highlight critical issues that occur and possible deviations from the Group’s Manuals and Policies.
•
Provide guidelines and instructions concerning the credit risk management and control procedures.
•
Provide information to Units of interest about the findings of the controls and possible recommendations made. At the same time,
depending on the scope of the controls, a summary of the findings and recommendations is sent to the Units of the Group that
participate in the procedure and to the General Management (to the competent Chief).
In order to further strengthen and improve the credit risk management framework the following actions have been implemented:
•
Provision of a risk opinion on credit requests under the competence of the Wholesale Banking I and II Credit Committees as regards
concentration risk issues and adherence to Credit Risk Policies.
•
Provision of a risk opinion on Retail Banking forbearance requests with multiple forbearance measures falling under the perimeter
defined in the Management Arrears Act.
•
Quality control assessment as regards the real estate made available as loan collaterals as well as the owned by the Bank and Group
Companies, and provision of a risk opinion to the competent Committees.
Risk Models and Data Validation
The Group and the Bank, recognizing the inherent risk in credit risk models due to their complexity and their high degree of dependence on
parameters estimated from other models, has established a Model Risk Management Framework which includes the principles of the Model
Development Policy and the Model Validation Framework. In particular, the independent Business Area Risk Models and Data Validation, on
the basis of specific procedures, shall validate all models used for the purposes of calculating expected credit loss.
The role of Risk Models and Data Validation Business Area, in the context of the Model Risk Management Framework (MRM Framework),
includes responsibilities related to the monitoring of the performance of the models developed by the competent Business Area (Credit Risk
and Enterprise Risk Modelling). The primary task of the Risk Models and Data Validation Business Area is the independent validation of the
reliability of the models, their appropriateness, as well as the compliance with the regulatory guidelines. Risk Models and Data Validation
Business Area responsibility is to develop procedures for the evaluation of models’ performance, on a periodic basis.
The frequency and the extent of the validation process is determined from the significance of the models, that takes into account among
other criteria, the size and the complexity of the portfolio. The associated level of inherent model risk is determined from the methodology
for the grading of significance of the models (Model Tiering) which subsequently determines the frequency, the extent and the intensity of
the validation.
In addition, the Risk Models and Data Validation Business Area audits, as a second “line of defense”, the effectiveness of th e design of the
data governance framework in accordance with supervisory guidelines and procedures. It performs assessments of the operational
effectiveness of the risk data collection processes as well as monitoring the accurate and timely implementation of reports, through regular or
ad hoc controls. Furthermore, it defines indicators for monitoring and performance of data quality by developing an action plan for their
resolution, in cooperation with the relevant Business Areas.
CREDIT RISK MITIGATION
Collaterals
Collaterals are received in order to mitigate credit risk that may arise from the obligor’s inability to fulfill his contractual obligations, either at
the loan origination date, or during the loan life, either by consensus or after forced executions, auctions, etc.
Collaterals include all kind of assets and rights which are made available to the Group either by their debtors or by third parties, in order to be
used as complementary repayment sources of respective receivable. In any case, the necessary legal audit of the collaterals provided is
carried out, in order to ensure their validity, as well as the possibility of being liquidated or to come into the possession of the Group.
Collaterals are classified into two broad categories: a) Intangible and b) Tangible collaterals.
a) The main type of intangible collateral used in lending is the Guarantee. A guarantee constitutes the legal relationship between the
guarantor and the lender (Bank), through which the guarantor assumes the responsibility that the debt will be paid. The guarantor can be an
individual or a legal entity and the guarantee can be provided for future or conditional debt. It is noted that the intangible collaterals include
the guarantees of the Greek State which in case that are integral part of the loan, are taken into account in the calculation of expected credit
losses, compared to other intangible collaterals that are not taken into account in the calculation of expected loss.
b) Tangible collaterals are distinguished between mortgages and prenotation on mortgages which are registered on real estate properties and
pledges over movable assets (e.g., commodities, checks, bills of exchange) or on claims and rights. For better assurance of the credit facilities
granted, mortgaged and, where applicable, pledged collaterals assets are covered by an insurance contract, with assignment of the relevant
insurance contract to the Bank.
Mortgages are registered on real estate properties which can be liquidated and more specifically on: Residential Real Estate, Commercial Real
Estate, Industrial Buildings, Land, Mines, Ships or aircraft and engines, whether or not movable, Machinery or other facilities (if they are either
essential components of immovable property or any annexes thereto).
According to the Group’s Credit Policy, the existence and the valuation of collaterals are closely monitored. During the valuation, in addition
to the characteristics of the property, the property’s exposure to climate risks is taken into account, such as risk of fire, flood or drought, as
well as any burdensome characteristics that may affect its value. The property valuations are performed on an annual basis for all real estate
types, except for those cases where something different is foreseen contractually, in cases of known changes on the property or in the
business course, or in case there are urban planning changes or any other considerable factors. In addition to the review of collateral values,
the Group also validates such collateral values on an annual basis.
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360 | ANNUAL FINANCIAL REPORT
The initial valuations of a real estate property, provided as collateral, are carried out through an on-site visit of the appraiser and internal
inspection. The revaluations of real estate properties, which collateralize performing exposures, are mainly carried out through:
•
The Bank of Greece’s residential property price index for exposures up to Euro 3 million, for residential properties.
•
Authorized appraisers, after their visit to the residential property used as collateral or via desktop valuation, if the amount of
exposure exceeds Euro 3 million.
•
The Bank of Greece’s commercial property price index (for the perimeter of the collaterals available) or the CRE price index that has
been developed by Alpha Real Estate Services for other categories of commercial properties, used as collateral, on performing
exposures of amount up to Euro 1 million.
•
Authorized appraisers, after their visit to the commercial property used as collateral or via desktop appraisal, if the exposure
exceeds Euro 1 million.
The revaluations for properties used as collateral for non-performing exposures, are mainly carried out through:
•
The Bank of Greece’s residential property price index, for residential properties linked to at least one non-performing exposure but
the total amount of linked exposures does not exceed Euro 300 thousand.
•
The Bank of Greece’s commercial property price index (for the perimeter of the collaterals available) or the CRE price index that has
been developed by Alpha Real Estate Services for other categories of commercial property, used as collateral, linked to at least one
non-performing exposure but the total amount of linked exposures does not exceed Euro 300 thousand.
•
Authorized appraisers of Alpha Real Estate Services after their visit to the property used as collateral, if the borrower is cooperative,
or by desktop valuation if the borrower is not cooperative and provided that either the property is collateral linked to at least one
non-performing exposure and the total amount of linked exposures exceeds of Euro 300 thousand or in the cases where the indices
are not appropriate for the type of the property under revaluation.
Mortgaged properties must be secured throughout the duration of the loan, at the expense of the debtor and with insurance policy terms
approved by the Group, against fire, earthquake and flood risks.
The Group in the context of the credit control process, performs on a regular basis and through proper sampling, audits over the procedures
of implementation of the Group Loan Collateral Policy as well as back-testing for the verification of property valuations. Audits relate to
valuations based either on indices or on individual valuations, in order to confirm that the proper depiction of property val ues in Group’s
systems in accordance with the values indicated in the relevant approvals of the competent Committees.
Pledge is the property right on movable assets, rights, claims and securities that gives the pledged lender the privilege to be satisfied with
priority by the sale or liquidation thereof. Pledges can be registered on movable assets, securities, rights or claims that have not been
excluded or disallowed from transactions and can be liquidated including raw materials, products or commodities, machinery (movable), bill
of lading, bill of exchange, cheques, securities, deposit and any type of claim that can be pledged. The frequency of the valuation varies
according to the right or asset on which the pledge may be registered, up to a maximum of one year.
Acceptable Value
During the approval process, the Group calculates the value of the collaterals received based on the potential proceeds that could arise from
liquidation. This estimation is referred to as the acceptable value of the assets provided as collaterals for loans and for its determination the
quality of the assets as well as their market value are considered. In this way, the rates for acceptable values are determined for each type of
collateral, which are expressed as a percentage of their market value, nominal or weighted value, depending on the type of the collateral.
CREDIT RISK EARLY WARNING SYSTEM
In the context of optimal management of lending and the timely identification of non-performing loans, the Group has developed and
implements a Credit Risk Early Warning System, which is defined as the aggregation of actions, processes and reports required to ensure the
early identification of events, at borrower (corporate and individuals) and portfolio level, which may deviate from the Bank's Credit Risk
Appetite or may lead to an increase in exposures with overdue debts or an increase in exposures with significant increase in credit risk.
The Group’s Credit Risk Early Warning System consists of the following stages:
•
Identification of early warning triggers
•
Actions (timely and appropriate action taken)
•
Monitoring the effectiveness of the procedure
•
Quality control of the procedure’s implementation
The perimeter to which the Credit Risk Early Warning System is implemented at account level encompasses all performing exposures, as well
as exposures up to 10 days-past-due for Retail Banking (beyond 11 days-past-due assignments for management) and up to 30 days past due
for the Wholesale Banking portfolio which have not been forborne (PLs).
Additionally, to the early identification and management of borrowers or loan portfolio segments with signals of deterioration, the Group also
monitors through the Early Warning System the loan portfolio, regardless of days past due, to ensure that the evolution and performance of
the lending portfolio are in accordance with the Bank’s and Group’s Credit Risk Appetite.
The Group has also incorporated events related to the deterioration of the prospects of the borrower's sector of activity, natural disasters and
Operating Risk, which relates to the normal business activity of the borrower.
CLIMATE-RELATED, ENVIRONMENTAL - SOCIAL AND GOVERNANCE (ESG) RISKS
The Group, acknowledging the relevance and potential impact of the risks stemming from climate and environmental related factors, and
especially climate change, and as part of its plan and in alignment with the respective external guidelines, has elaborated further on the ESG
incorporation into the risk identification and materiality assessment processes and in the overall risk management framework, and is
committed to monitoring, assessing, and managing these risks going forward. Leveraging on the work already performed in previous years the
Bank has proceeded with targeted enhancements during 2025 in accordance Group’s ESG plan commitments. More specifically, the following
activities have been performed following the EBA final guidelines:
i. The Bank designed and implemented a dedicated internal report including ESG metrics for loans and advances, which is presented on a
quarterly basis to the Group Sustainability Committee and the RMC (Risk Management Committee), and through the RMC, to the Board
members.
ii. ESG-related considerations have been integrated into the Group's Remuneration Policy, aligning executive compensation with
environmental and sustainability goals. Active participation of the risk management function in the target setting and remuneration
process to ensure fulfillment of the supervisory expectations with regards to the implementation of sound remuneration practices which
do not encourage excessive risk taking or lack of controls. In detail, the risk management function review and opine on:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
361 | ANNUAL FINANCIAL REPORT
•
The Business Unit Balanced scorecards to verify the effective coverage of the most important strategic priorities of the Group, as
well as the sufficient inclusion of risk & control aspects at the Business Unit level.
•
The Senior Executives and KFHs’ APD individual scorecards to ensure that there are included quantitative risk related KRIs, a s well as
targets based on RAF which promote further alignment with the Risk Appetite Framework of the organization.
•
The Material Risk Takers’ identification process by reviewing and assessing both the criteria applied in the context of the process as
well as the business areas identified to be included in the “Material Risk Takers” list and the Material Risk takes list per se.
•
How the remuneration policy and specifically the variable remuneration structure is affected by and related with the risk profile, risk
culture and risk appetite of the Bank, as well as supports the HR function with regards to the Policy and the incentive system for risk
related components by validating and assessing specific aspects of the policy.
iii. The second risk culture measurement Survey completed successfully, the results will be presented within Q1 2026.
iv. The Bank updated the perimeter of the Reputational Risk questionnaire aligning with new criteria described by the Omnibus Regulation.
Additionally, the Bank updated the method of sending the questionnaire with an online link in order to facilitate obligors and automate
the process of assessment.
v. The Bank delivered several internal ESG trainings to the 1
st
Line of Defense (LoD) Wholesale Relationship Managers regarding the
Physical Risk assessment and the ESG Overall Assessment of obligors including ESG Obligor Assessment, Transaction Assessment and
Reputational Risk Assessment.
vi. The Bank has centralized data related to the CPRS sector (Climate Policy Relevant Sectors) and Physical Risk assessment on obligor and
real estate level, ensuring both credit assessment and reporting needs are efficiently met.
vii. The Bank completed the process of integrating ESG considerations in the due diligence process of Debt Securities.
viii. Ιn the context of the Internal Capital Adequacy Assessment Process (ICAAP Report), enhancements in the Bank's Climate and
Environmental Stress Test Framework were undertaken during 2025 to
•
extend the applicable perimeter of obligors analysed at counterparty level,
•
provide additional breakdown of sectoral inputs to models further aligning them with the ESG Risk Materiality assessment
•
adoption of newly published Network of Central Banks and Supervisors for Greening the Financial System NGFS short-term
scenarios and
•
the introduction of long-term Nature scenarios.
The Bank aligned with International best practices, has developed climate risk-specific methodologies to estimate the impact of:
•
transition on credit risk across different time horizons (short, medium and long term) by making use of leading global
macroeconomic and sectoral models. Additional characteristics such as buildings’ energy efficiency, geographic and counterpar ty
level characteristics are also incorporated in the estimation to further account for heterogeneity of impacts inherent in climate risks.
These are examined as stand-alone climate scenarios and used under both the Economic and Normative perspective. Where
applicable these scenarios are also applied on operational risk and business & strategic risks considering the relevant risk materiality
assessment that has been performed.
•
physical risk (chronic and acute risks – specifically flood and wildfire) on credit risk across different time horizons (short, medium
and long term) by making use of leading global macroeconomic and sectoral models, as well natural catastrophe models for Greece.
Additional characteristics such as geographic and counterparty level characteristics are also incorporated in the estimation to
further account for heterogeneity of impacts inherent in climate risks. These are examined as stand-alone climate scenarios and
used under both the Economic and Normative perspective. Where applicable these scenarios are also applied on operational risk
and business & strategic risks considering the relevant risk materiality assessment that has been performed.
ix. The Bank, for the first time, developed its Geopolitical Risk Materiality Assessment. European Central Bank treats geopolitical risk as a
cross-cutting risk being transmitted to the bank’s traditional risks through three transmission channels, the Financial Market’s channel,
the Real Economy channel and the Safety and Security channel. Therefore, the Bank assessed the materiality of the geopolitical risk
across its traditional risk more specifically credit risk, liquidity risk, market risk, business and strategic risk, and non-financial risk,
following both a sector-based analysis and a country-based analysis, as well as detecting potential vulnerabilities and dependencies.
The assessment showed the following results from a sector-based analysis:
•
Credit risk: material due to high concentration in geopolitical vulnerable sectors of the NFC exposures.
•
Liquidity risk: material from the Greek NFC Deposits perspective.
•
Market risk: Non-material from the corporate bonds portfolio analysis which constitutes a small share of the Bank’s total portfolio.
•
Business & strategic risk: Material from a profitability perspective according to a sector-based analysis of Gross Interest, Fees and
Commissions.
From a country-based analysis, there was no evidence of material impact across the Bank’s traditional risks due to the fact that the Bank’s
portfolio is mostly allocated in low or medium risk jurisdictions, as of 31.12.2025.
Regarding non-financial risk, a holistic assessment was conducted across all subcategories of the respective risk. The analysis showed that
geopolitical risk is material from an ICT and third-party risk assessment, as well as from a reputational and compliance risk perspective.
Thus, in alignment with the respective guidelines, the Bank incorporated geopolitical risk into its risk inventory and, moving forward, will
enhance its methodologies annually, while closely monitoring the external environment given that this type of risk is multifaceted and difficult
to predict in accuracy and across all time horizons.
x. The Bank earned a B rating from Carbon Disclosure Project (CDP) reflecting a two-grade improvement as a result of our ongoing efforts
to enhance environmental management and increase transparency and further integrate climate-related consideration into our business
strategy.
xi. The Bank has updated its annual Climate and ESG Materiality assessment with enhancements in alignment with the Bank’s appeti te for a
constant enhancement. More specifically the Bank proceeded with the inclusion of the following additional perimeters and changes:
•
The Bank complemented its ESG risk materiality assessment already performed in the context of Credit risk with an obligor-level
materiality assessment focusing on the top 20 obligors of the NFC Loan portfolio, in terms of total GHG emissions.
•
The Bank proceeded with the inclusion of certain additional perimeters in this year’s exercise. In particular, the Bank proceeded in
performing the analysis of off-balance sheet exposures (Credit Risk), the assessment of real estate investment properties (Business
& Strategic Risk) and the assessment of physical risk of repossessed real estate.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
362 | ANNUAL FINANCIAL REPORT
•
An additional element of identifying sectors sensitive to climate transition has been introduced in Bank’s current methodology.
More specifically, the Bank complemented its ESG risk materiality assessment already performed in the context of Credit risk with
an obligor-level materiality assessment focusing on the top 20 obligors of the NFC Loan portfolio, in terms of total GHG emissions.
•
Regarding the physical risk assessment, new risks have been also assessed (i.e., ocean acidification). The disaggregation of some
risks that were previously assessed under one category was conducted and are now assessed into distinct categories thus facilitating
the result aggregation of the examined physical risks into the four climate-related hazards classes (Temperature-, Wind-, Water-,
Soil- related).
•
The Bank transitioned from the UNEP FI tool to the ENCORE tool to identify the key sectors with negative impacts across the nature-
related topics.
•
As in the previous year’s impact analysis, the Bank assessed the likely negative impacts for sectors that significantly affect each
nature-related topic. The assessment was based on literature review across different time horizons. It is also considered existing and
future legislation, regulations, market pressures, technological advancements and innovation, as well as reputational risks. These
factors were combined to produce a likelihood score. In this year’s impact analysis, the assessment was further im proved by
calculating sector-level impact scores for each nature-related topic, providing a more detailed evaluation of risks within the defined
scope.
•
Greenwashing risk is assessed under the Social- & Governance-related risks, rather than under Climate- & Nature-related risks
considering the nature of greenwashing risk and its treatment within the Bank.
•
The Bank has explicitly referred to the likelihood of occurrence and potential magnitude dimensions to fully address the
requirements in accordance with CSRD.
Since the previous submission, updates to the methodologies have led to changes in the materiality assessment of nature-related risks for
non-financial and reputational risk. Specifically, non-financial risk is no longer assessed as material over the medium- and long-term horizons,
while reputational risk is now considered material only over the long-term horizon (and no longer over the medium term).
Τhe outcome of the materiality assessment for each risk category is outlined as follows:
a. Climate related risks:
•
Credit risk:
o
Transition risk : considered to be materially affected, both in the Non-Financial Corporate (NFC) portfolio and the Retail
portfolio secured by Real Estate in the medium and long-term horizons.
o
Physical risk : It is, also, considered to be materially affected in the medium and long-term horizons, leveraging on the
vulnerability assessment outcome per sector and region.
•
Non- financial risk: seems to be materially affected by transition and physical risks in the medium and long-term horizons as
examined in terms of the Bank’s Own used Real Estate Properties.
o
Regarding Legal/Litigation risk, and specifically Greenwashing Risk seems also be materially affected by C&E risks in
medium and long-term horizons.
•
Market/Liquidity risk: currently assessed as immaterial to both transition and physical risks across time horizons.
•
Reputational risk: materially affected by C&E risks in the medium and long-term time horizons.
•
Business & Strategic risk:
o
Transition risk: considered to be materially affected by transition risk over the medium- and long-term horizons. The
assessment examines the Gross Interest and Fees & Commissions Income of the Bank’s performing portfolio within the
ESG Sensitive Perimeter, following the same approach as credit risk.
o
Physical risk: considered to be materially affected by physical risks over the medium and long-term horizons.
b. Nature related risks:
•
Credit risk: materially affected by nature-related risks (and more specifically by biodiversity) over long-term horizon.
•
Non-financial risk: materially affected by nature-related factors in the medium- and long-term horizons.
•
Market/ Liquidity risk: immaterially affected by nature-related risks across time horizons.
•
Reputational risk: materially affected by nature-related factors in the medium and long-term horizon.
•
Business & Strategic risk: materially affected by nature-related risks (and more specifically by biodiversity) over long-term horizon.
c. Social related risks:
•
Credit risk: no material risks arise from the downstream portfolio due to the processes and controls applied by the institution,
despite the fact that certain part of the NFC portfolio impacts social factors.
•
Non-financial risk: considered material in the short-medium and long-term. Specifically, the social topics considered as material are
(a) for own workforce: the training & skills development, and (b) for consumers and end users: privacy, access to (quality)
information and responsible marketing practices.
•
Greenwashing risk: Although Greenwashing risk is considered a significant aspect of Governance risks, the Bank has also identified
and takes into account interdependencies between social risks and Greenwashing risk.
d. Governance risks:
•
Corruption and Bribery governance topic is considered material in the short, medium- - and long-term.
•
Greenwashing risk: Overall, greenwashing risk is considered material in the medium- and long-term.
To address the C&ESG risks, in 2025 the Bank has deployed a comprehensive strategic plan by carrying out the following key actions:
•
Identified, assessed, and prioritized the ESG issues related to its activities that may impact the Group’s operations and/or its
Stakeholders. Under this scope, a Double Materiality Analysis (DMA) was performed by leveraging the UNEP FI Principles for
Responsible Banking (PRB) Tool, the RSCA inherent risk assessment and outcome from the Compliance Risk Assessments to identif y
the material Impacts, Risks and Opportunities (IROs) and connect these with the relevant European Sustainability Reporting
Standards (ESRS) topics, subtopics or sub-subtopics under Corporate Sustainability Reporting Directive (CSRD).
•
Enhanced the regular monitoring of RAF indicators in order to cover all material C&E risks (transition & physical for credit risk in
NFCs and Collaterals, operational losses due to physical risk, social and governance risks, reputational risk due to ESG
considerations, business & strategic risk through the monitoring of income reliance from sectors sensitive to transition risk). The
RAF indicators were updated in Tier III in 2025 adding thresholds.
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•
Developed, in 2025, science-based financed emissions targets for material carbon-intensive sectors covering both lending and
investment portfolios. The targets cover the power generation, oil & gas, cement and iron & steel sectors, are aligned with the Net
Zero Banking Alliance recommendations and use the International Energy Agency Net Zero Emissions by 2050 (IEA NZE) scenario a s
the benchmark pathway. Going forward, the Bank will continue to progressively align its lending and investment portfolios wi th
net-zero pathways adding sectoral decarbonization targets, and to expand its sustainable finance solutions to support its custome rs’
transition through meaningful and effective engagement. In this respect, focus is put on the implementation and ongoing
refinement of its climate Transition Plan.
In order to assess the impact of climate risk on the calculation of Expected Credit Loss (ECL), information on the location of collateral as well
as information on EPCs is being collected. The information will be incorporated into the respective data systems and methodological
approaches will be developed in order to adapt the models for calculating the ECL.
More specifically, the following are in progress:
•
Data collections regarding ESG related information of the obligor through the use of the inter-banking ESG platform were ongoing
on 2025.
•
The Bank is considering in designing new interbanking ESG Obligor questionnaires targeting SPVs (Special Purpose Vehicles).
•
Further enhancement and recalibration of the Bank’s ESG scorecards leveraging the data above.
•
Identifying enhancements or additions to the current set of models used for risk parameter estimation and prediction, in order to
integrate ESG risks.
The Group continues to develop and implement its ambitious ESG Workplan, aiming to enhance the sustainability of its business model and to
ensure long-term value creation for its Shareholders.
ESG Risk Assessment in the context of the Credit Approval Process
The ESG risk assessment is a key tool for the decision-making by the competent Committees, the implementation of the appropriate pricing
policy and the assessment of the quality of the Group’s lending portfolio in terms of ESG risks. As part of the busines s lending approval and
monitoring, an ESG assessment is carried out at the obligor, transaction, and overall level.
The ESG assessment at obligor level is based on specific ESG questionnaires completed by the Clients. The type of questionnaire (e.g. sectoral,
cross sectoral, simplified) that the Client is asked to complete depends mainly on the size of the company and its industry sector. The
submitted questionnaire is scored using internal evaluation models. The outcome of the ESG assessment at obligor level may be High,
Medium or Low risk.
The ESG assessment at transaction level concerns the activity for which the client is applying or has received financing based on the
information provided during the preparation of the credit request. The outcome of this assessment may be "sustainable" or "non-sustainable”
financing based on the criteria set out in the Group's Sustainable Finance Framework. Sustainable financings are further distinguished into
aligned or not aligned with the EU Taxonomy. Non-sustainable financings are classified as Low, Medium, or High ESG risk.
The overall ESG assessment is a combination of the ESG assessment at obligor and transaction level and is captured per transaction. When the
activity to be financed does not fall within the Exclusion List, the outcome of the overall ESG assessment may be: Sustainable, Low ESG
impact, Medium ESG impact, Increased ESG impact.
The Group has updated the Climate Related, Environmental, Social and Governance Risk Management Policy on Group’s Business Le nding
inter alia to allow finance of the defense sector up to a certain cap for conventional weapons related activities in accordance with the
“Defense Sector Financing Policy”, to amend the definition of the critical industry sectors connected with potential climate and ESG risks.
Furthermore, in the Wholesale Banking portfolio, in the case of events that may result in a significant Reputational Risk to the Bank and its
Group Companies, an assessment of these events is conducted by Reputational Risk Committee, and the outcome is considered by the
competent approval committee.
Geopolitical risks considerations in Credit Risk
The Bank assesses, monitors, and manages geopolitical risk along with the developments in the external environment, in alignment with the
respective guidelines. The Bank has adopted a series of actions/changes relating to credit risk.
On individual borrower level, increased communication with the Wholesale Banking customers is performed, in order to identify cases of
customers who are affected by the geopolitical events, focusing on companies that are either directly dependent on specific countries, due to
the object of activity, or operating in specific sensitive sectors. Additionally, for Wholesale Banking customers, a close monitoring is
performed at Committee level through sensitivity analysis, in order to assess resilience levels.
Regarding sectorial analysis, an ad hoc reassessment of the profile of the Greek Economy sectors was performed in 2025 based on the ICAP
CRIF expert input, so as to embed the current geopolitical risk. In the context of the Greek sectors rating process, ICAP CRIF presented the
evaluation of specific economic sectors to determine their vulnerability to geopolitical and trade-related shocks arose from international
politics and changes in trade policies (Middle East conflicts & US tariffs developments in focus).
Finally, scenario analysis and sensitivity analysis have been performed in order to assess the potential impact and its materialization through
the ECL framework.
CREDIT RISK CONCENTRATION MANAGEMENT
Concentration Risk is a specific form of credit risk and arises due to the low degree of diversification between counterparties, or group of
counterparties, sectors, geographic regions, products or collaterals.
The Group monitors on a regular basis concentration risk at sector level and at borrower/group of borrowers level as well, through detailed
reporting which informs senior management and Committees of the Board of Directors.
The Group categorizes the financed companies according to their NACE Rev.2 codes into Industry groups/Sectors, which are rated into risk
zones. The Sectors ranking relative to their credit risk is carried out by an independent and certified company and is based on a predictive
indicator that, focusing on future estimates rather than solely on past data, captures the risks and prospects of each sector. The Group
determines the Credit Risk Appetite per sector and manages the concentration risk by monitoring the evolution of its portfolio.
Additionally, the Group manages concentration risk at borrower/group of borrowers level by setting and monitoring compliance with limits
set both by regulatory guidelines and by internal policies that have been developed taking into account the existing exposure as well as the
credit risk rating of the borrowers.
DEFINITIONS
The following definitions are provided as guidance to the tables that follow:
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364 | ANNUAL FINANCIAL REPORT
The Public Sector includes loans to the Central Government, the Local Authorities and the companies controlled and fully or partially owned
by the State (excluding those engaged in commercial activity).
As Past Due Exposures is considered the sum of the principal, interest and charges/commissions that have not been paid at the date it was
due.
A Default event is considered to have occurred, regarding a particular Borrower, when at least one of the following criteria has taken place:
•
Past Due Criterion: The Borrower is past due more than 90 consecutive days on any material amount of the credit obligation(s).
Particularly, for Alpha Bank Greece, exposures at Alpha Leasing and ABC Factors are taken into consideration at the calculation of the Past
Due Criterion.
•
Unlikeliness to Pay (UTP) Criterion: The Group considers that the Borrower is unlikely to pay when assesses as unlikely the
repayment of obligations unless actions such as the liquidation of collaterals are enforced.
Additionally, it is necessary to harmonize the classification of exposures in Default and the classification of exposures according to EBA and
therefore any Forborne non-performing exposure (FNPL) or non-performing exposure (NPL) is considered as an exposure at Default.
For Retail exposures, the above definition of Default is applied at the level of an individual credit facility.
For Wholesale exposures, the definition of Default is applied at the obligor level meaning that when at least one of the above specified
criteria is met, the Obligor is considered as Defaulted. The Past Due Criterion is applied both at facility and at obligor level for exposures
classified as Wholesale, in order to be able to identify exposures for which the Past Due Criterion is satisfied at facility level, but not at obligor
level.
An exposure is considered as Non-Performing when at least one of the following criteria apply at the time of the credit risk rating assessment:
•
The exposure is more than 90 days past due (NPL).
•
It is assessed as Unlikely to Pay (UTP).
•
Legal actions have been undertaken by the Bank -Legal (NPL).
•
The exposure is classified as Forborne Non-Performing Exposure (FNPL), as defined in the Implementing Regulation (EU) 2021/451
of 17 December 2020.
When a Wholesale Banking borrower has an exposure that is more than 90 days past due and the amount of this exposure exceeds 20% of
total exposures of the borrower, then all exposures of the borrower are considered as non-performing (Pulling Effect).
An exposure is flagged as ‘Unlikely To Pay’ (UTP) when the Group assesses that the borrower is unlikely to fully meet his credit obligations
without the liquidation of collateral, regardless the existence of any past due amount or the number of days past due, with the exception of
collaterals that are part of the production and trade chain of the borrower (e.g. properties for Real Estate companies, corporate shares for
Holding companies). For the identification of these the following are determined, separately for Wholesale Banking and Retail Banking, a)
events which when occur lead to the transfer of the exposure to Non-Performing status without requiring an assessment by any Committee
(Hard UTP Triggers) and b) triggers which when occur, lead to borrower’s credit assessment by the competent Committee in order to
determine whether borrower’s exposures should be classified as Non-Performing and consequently as defaulted (Soft UTP Triggers).
An exposure is considered as Credit Impaired when the criteria specified by the definition of Non-Performing Exposures are met.
An exposure is considered as Default when the criteria specified by the definition of Non-Performing Exposures are met.
It is noted that the Group has decided since 2018 to align the perimeter of exposures recognized as “Non Performing loans”, as “Default
Exposures” and as “IFRS 9 Credit Impaired exposures’.
For credit risk reporting purposes the allowance for expected credit losses of loans measured at amortised cost includes also the fair value
adjustment for the contractual balance of loans which were impaired at their acquisition or origination (POCI) since the Group, from credit
risk perspective, monitors the respective adjustment as part of the expected credit losses. These loans were recognized either in the context
of acquisition of specific loans or companies (i.e. Emporiki Bank and Citibank Greece), or as a result of significant modification of the terms of
the previous loan that led to derecognition. Relevant adjustment has been performed to the carrying amount of the loans before allowance
for expected credit losses.
The collateral value taken into account is the latest market value of the collateral available. In the case of immovable properties, collateral
value is considered the lower between the prenotation amount and the market value. Value of guarantees only includes the amount that
exceeds the value of collaterals. All collateral values are capped at 100% of the outstanding amount of the loan.
EXPECTED CREDIT LOSS ESTIMATION METHODOLOGY
The Group, at each reporting date, recognizes a provision for expected credit losses on loans and advances to customers not measured at fair
value through profit or loss as well as for letters of guarantee, letters of credit and undrawn loan commitments.
The expected credit losses calculation Methodology is common and applicable for both the Wholesale and Retail Banking Portfolios.
Portfolio Classification in Stages based on the Credit Risk (Staging)
Following an exposure’s initial recognition, exposure is classified into stages based on credit risk. The classification of l oans in stages is based
on the changes of the credit quality since initial recognition. Upon initial recognition of an exposure, the Group must determine whether this
exposure is considered as credit impaired (Credit Impaired at Initial Recognition).
The POCI category (Purchased or Originated Credit Impaired, POCI) includes the following:
•
Exposures that at the time of purchase (Purchased) meet the criteria of non-performing exposures.
•
Exposures that the old one is derecognized and a new exposure is recognized and for which the following apply when Originated: if
the exposure was classified as credit impaired (NPE) prior to derecognition, the new exposure will continue to maintain this
classification and it will be classified as POCI.
The calculation for the credit risk of POCI exposures is calculated in lifetime.
For exposures not classified as POCI, the classification in stages is performed as follows:
•
Stage 1 includes performing credit exposures that have no significant increase in credit risk since the initial recognition date. In this
stage, expected credit losses calculated are based on the probability of default within the next twelve months and the assessment is
carried out on a collective basis.
•
Stage 2 includes credit exposures with significant increase in credit risk since the initial recognition but are not non-performing. In
this stage, expected credit losses calculated in lifetime and the assessment is carried out on a collective basis.
•
Stage 3 includes the non-performing / default exposures. In this stage expected credit losses calculated in lifetime and the
assessment is performed on a collective or individual basis.
All possible movements between Stages of credit risk are presented below:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
365 | ANNUAL FINANCIAL REPORT
•
An exposure which has been classified in Stage 1 in the previous quarter of reference could be classified either in Stage 1 in the next
reporting quarter, if the credit risk has not deteriorated and the exposure is still performing, or in Stage 2, if the exposure is still
performing but the credit risk has deteriorated, or in Stage 3 if the exposure is non-performing/default.
•
An exposure which has been classified in Stage 2 in previous quarter of reference could be classified either in Stage 1 in the next
reporting quarter, if the exposure is performing and does not meet any criteria of “Significant increase in credit risk” and in
particular, for case of Forborne Performing loans (FPL), if the exit criteria from the 2-years probation period are met or it could also
remain in Stage 2, if the credit risk has not substantially changed, or be transferred to Stage 3, if the exposure is non-
performing/default.
•
An exposure which has been classified in Stage 3 in previous quarter could be classified either in Stage 1 in the next reporting
quarter, if the exposure is performing and does not meet any of the criteria of “Significant increase in credit risk”, or tra nsferred in
Stage 2, if it is no longer considered as non-performing but meets one of the criteria of “Significant increase in credit risk”, or remain
in Stage 3, if it is still non-performing/default.
All exposures in default (Stage 3), except from those related to distressed restructuring, in order to be reclassified as non-default, a probation
period of at least 3 months is needed from the time when the conditions leading to default status are not applied. Exposures with distressed
restructuring, regardless of whether the restructuring took place before or after the default, should have a minimum probation period of 12
months from the most recent event of the following:
•
the time of restructuring
•
the time when the exposure has been classified as default
•
the end of the grace period provided by the restructuring terms
The Group does not make use of the exemption provided by the standard for low credit risk exposures.
For classification purposes, for wholesale banking revolving exposures, initial recognition date is the date of the most recent credit
assessment / credit risk rating reflecting of at least the annual thorough credit risk review.
Furthermore, the classification of the exposures in IFRS9 stages is also affected by the refinancing risk, which is an area of focus during the
credit review and UTP assessment process, either through the obligor rating, the financial difficulty indicator or through the identification of
relevant UTP triggers.
Significant Increase in Credit Risk
For the timely identification of significant increase in credit risk for an Exposure after the initial recognition (SICR) leading to the calculation of
lifetime credit losses of the exposure instead of twelve months credit losses, the risk of default at the reference date is compared to the risk
of default at the initial recognition date for all Performing Exposures, including those with no days past due (Delinquencies).
The assessment to determine whether an exposure shows significant increase in credit risk or not is based on the following:
•
Quantitative Indicators: They refer to the use of quantitative information and specifically to the comparison between the
probability of default (PD) at the reference date and the probability of default at the initial recognition date. The assessment of
significant increase in credit risk is based either on a relative or on an absolute increase of PD between the reporting date and the
initial recognition date. As a result of the annual update of credit risk parameters the relative increase can range between 75% and
200% depending on the asset class of the loans. The increase in absolute number, when used, can range between 3 and 5
percentage points depending on the asset class and rating category of the loans and acts as a backstop to the relative increase (i.e.,
just one of the two triggers needs to be hit in order to trigger stage 2). Additionally, in the case of wholesale exposures, the Credit
Risk Rating is taken into account separately as a criterion for determining the significant increase in credit risk. Finally, the threefold
increase in annualized PD as backstop is ensured. Threshold determination derives based on portfolio level analyses. The
assessment of the exposures for significant increase in credit risk is applied on account level. It is noted that the critical points - both
for the absolute increase and for the relative increase of PD between the reference date and initial recognition - are validated on an
annual basis, in order to confirm their correct application and to confirm that the established criteria have sufficient identified the
significant increase in credit risk.
•
Qualitative Indicators: They refer to use of qualitative information which is not necessarily depicted in the probability of default,
such as the assessment of an exposure as performing forborne (“FPL” within 2 years’ probation period according to EBA ITS) or as
exposure with Financial Difficulty or as exposure with Operating Risk (for Wholesale exposures). Additional qualitative indicators for
the Wholesale Banking portfolios and the Retail Banking portfolios are included in Credit Risk Early Warning mechanisms where
according to the assessment performed, an exposure may be considered as significant increase in credit risk or not. Especially for
Specialized Lending portfolios through rating (slotting category) additional qualitative indicators are identified.
•
Backstop Indicators: In addition to the above, and with a view to addressing cases where there is no evidence of significant credit
risk deterioration based on the quantitative and qualitative indicators, exposures over 30 days past due are considered by definition
to show significant increase in credit risk.
Allowance for expected credit losses estimation
Expected credit losses are calculated either on an individual basis or on a collective basis, taking into account the significance of the exposure
common risk characteristics and historical behavioral data.
Exposures assessed on individual basis (Individual Assessment): On an individual basis, the Exposures to Companies with the following
characteristics are assessed:
•
Borrowers with at least one Non-Performing Exposure whose Customer overall credit Limit in the Bank exceeds the amount of Euro
2 mil. or
•
Specialized Lending Borrowers regardless the overall credit limit with at least one Non-Performing Exposure or
•
Exposures that do not share common risk characteristics or for which no relevant historical data that enables a collective analysis is
available.
Any remaining wholesale exposures are assessed collectively.
On an individual basis, the exposures of Individual Borrowers are assessed when they are classified as Non-Performing Exposures (NPE), and
they relate to:
•
Consumer Loans: Exposures of Consumer Credit Borrowers with total on balance exposures over €500 thousand.
•
Mortgage Loans: Accounts of Mortgage Credit Borrowers with on balance exposures over € 2 mil.
Any remaining exposure to Individuals is assessed collectively.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
366 | ANNUAL FINANCIAL REPORT
Exposures assessed on collective basis (Collective Assessment): Collective Assessment applies to credit exposures which are not assessed
individually, i.e. exposures classified in Stage 1 and Stage 2 as well as non-performing exposures that do not meet the above criteria for
individual assessment, after having been categorized based on similar credit risk characteristics of the group and the portfolio to which the
borrower or the credit facility is allocated.
For the classification of credit facilities into groups with similar credit risk characteristics (e.g. Staging according to Credit Risk, Type of
Product, Days Past Due, Time in default, Indication of unlikeliness to pay, Modification of contractual terms for borrowers showing financial
difficulty (Forbearance Measures), Existence of Collateral/ Greek State Guarantee, Credit Risk Rating etc).
The groupings are reviewed on a regular basis to ensure that each group is comprised of homogenous exposures in terms of credit risk.
Expected Credit Loss is calculated on account level.
Calculation of allowance for expected credit losses
Allowance for expected credit losses is reassessed at each financial statement date, reflecting the reassessment of credit risk.
Credit risk parameters
Calculation of Expected Credit Loss is based on the following credit risk parameters which are incorporated in the internal statistical models
based on historical data.
•
Probability of Default (PD): It is an estimate of the probability of a borrower to default over a specific time horizon. The Probability
of Default is determined with the assistance of the Credit Risk Models. The Group uses statistical models through regression in order
to analyze the collected data and make estimates of the remaining probability of default over the life of the exposures and how they
will evolve over time. Specifically, based on historical time series of observations, specialized models have been developed per
portfolio type, which evaluate separately the twelve-month probability of default (12-month PD models) as well as the probability
of default throughout the lifetime of exposures (Lifetime PD models). The twelve-month default models basically evaluate the
behavioural characteristics of the loan (behavioural models), while the Lifetime models evaluate two types of factors: the
endogenous such as the maturity of the loan and the exogenous ones such as the macroeconomic environment (unemployment,
annual percentage change in GDP, change in property prices, inflation). The final estimate of the probability of default is derived
from the combination of the two components (12-month PD & Lifetime PDs).
•
Exposure at default (EAD): Exposure at Default is an estimate of the amount of the exposure at the time of the default taking into
account: (a) expected changes in the exposure after the reporting date, including principal and interest payments; (b) the expected
use of credit limits and (c) accrued interest. The approved credit limits that have not been fully disbursed represent a potential
credit exposure and are converted into a credit exposure equal to the approved undrawn loan commitments multiplied by a Credit
Conversion Factor (CCF). The Credit Conversion factor of credit exposure is calculated based on statistical models. The maximum
period for which credit losses are calculated is the remaining contractual maturity of a financial instrument unless the Group has the
legal right to recall the financial instrument earlier. Exceptionally, for Credit Cards and loan agreements to individuals, the maximum
period is set at three years, while for revolving loans to Small Businesses, the corresponding maturity is set at five years. Regarding
Wholesale Banking loan agreements, the period is set to one year, given the thorough credit review performed at least once a year.
If the residual maturity of the revolving exposures classified in Stage 2 was increased by one year, Expected Credit Losses would
increase by €2 as at 31.12.2025 (31.12.2024: € 2).
The Group uses models for exposure at default that reflect the characteristics of each portfolio.
Loss given default (LGD): Loss given default is an estimate of the loss that will occur if the default occurs at a given time. It is based on the
difference between the contractual cash flows due and those expected to be received, including the liquidation of collaterals, cure rate and
cash recoveries based on historical data.
For unsecured loans, the Estimated Expected loss at the time of the default, takes into account expected recovery rates which vary
throughout the recovery period as well as the cure rate.
Expected recoveries from tangible collaterals are based on the following inputs: the most recent (updated within the year) market value of
the collateral, the time required for the liquidation/sale of the collateral (ranging between 3 to 5 years depending on the legal action status of
the loan), the expected market value at liquidation /sale date based on the evolution of real estate prices within the next 4 years, the
expected recoveries through foreclosure process or sale (as derived from historical data obtained for foreclosures and sales of collateral). The
recovery rate is adjusted at the end to reflect value of preferential claims. Expected cash flows are discounted using the original effective
interest rate.
As part of the annual update, credit risk parameters are reviewed and revised if needed to incorporate the impact of any changes in the
business environment.
Finally, it is noted that the LGD varies based on each macroeconomic scenario since it differentiates the value of collateral, cash recoveries
and the cure rate.
Estimates of expected cash recoveries are adjusted by incorporating macroeconomic indexes (i.e. unemployment, annual percentage change
in GDP, change in real estate prices, inflation) through the development of corresponding statistical models. More specifically, based on
historical time series of observations, specialized models (regression) have been developed per portfolio, which evaluate the expected
recoveries combined with the impact of macroeconomic indicators.
In respect of cure rate estimates, statistical models (regression) per portfolio have been developed based on historical time series of
observations which incorporate the effect of the macroeconomic environment through relevant indicators (indicative unemployment, annual
percentage change in GDP, change in property prices, inflation).
Management overlays:
Sale scenarios: In case the Group's business plan includes targets and strategies for recovery through sale, then for the loans and advances to
customers included in the portfolio that may be sold, the recoverable amount is calculated by weighting
(i) the value in case of sale (sale price) and
(ii) the amount expected to be recovered according to the internal methods applied by the Bank for the impairment of non-
performing loans, i.e. based on the individual assessment for exposures exceeding a specified limit and based on the collective
assessment for the rest.
The weighting is based on the probability of sale attributed to each non-performing loan portfolio, assessing the stage of preparation of the
underlying portfolios, the importance of the conditions preceding the realization of the sale as well as the recovery time.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
367 | ANNUAL FINANCIAL REPORT
Taking into account developments in sales transactions of portfolios of non-performing loans included in the NPE Business Plan, as described
in note 54 "Assets For Sale", the calculation of expected credit losses incorporates a sale scenario with 100% probability for the loan portfolios
that are classified as Held for Sale.
As a result of the above, a charge of € 128 was recognized in impairment losses/(gains) for the period ended on 31.12.2025 an d mainly
regards:
(i) € 94 for non-performing Mortgage and Wholesale loans in the new “Athena” perimeter that have been classified as “Held for
Sale” within second quarter of 2025. (note 54).
(ii) € 15 for the non-performing loans and assets portfolio in Cyprus – (ACAC portfolio), that have been classified as “Held for Sale:
within the second quarter of 2025.
(iii) € 11 for non-performing Wholesale loans, in Solar perimeter from which € 6 regarded the expansion of the perimeter that have
been classified as “Held for Sale” within the first quarter of 2025. (note 54).
Post model adjustments (PMA)
Moreover, Management proceeds, when deemed necessary, to additional post model adjustments. These adjustments are recognized by the
Group following a detailed examination of the results of the models, market data and/or the Bank's strategy and other risk factors,
particularly in periods of economic uncertainty, which cannot be incorporated into the models.
The Group’s governance framework requires such adjustments are properly documented and approved by the appropriate authorization
levels within the Group.
In this context, the Group and the Bank recognized post model adjustments (PMAs, included in the ECL allowance) amounting to € 95
(31.12.2024: € 103) for the Group and € 88 (31.12.2024: € 100) for the Bank allocated as follows:
•
An amount of € 47 was recognized in order to reflect the uncertainty of the current macro-economic environment, driven by the
inflationary pressures, increased funding cost of households and enterprises and the ongoing geopolitical risks and uncertainty,
which are not fully captured by the models.
•
An amount of € 37 was recognized in order to capture the expected impact of management actions aimed to further reducing the
risk of redefault within certain retail exposures.
• An amount of € 11 was recognized within the expected credit loss (ECL) calculation after the enactment of the law for the
government-induced haircut on CHF mortgage portfolio, following alternative scenarios that have been examined in terms of
acceptance of the obligors, taking into consideration both the financial and collateral eligibility criteria imposed by the law.
Incorporation of forward looking information
The Group calculates allowance for expected credit losses based on the weighted probability of three alternative scenarios.
More specifically, the Group produces forecasts for the possible evolution of macroeconomic variables that affect the level of allowance for
expected credit losses of loan portfolios under a baseline and under two alternative macroeconomic scenarios (an upside and a downside
one) and also estimates the cumulative probabilities associated with these scenarios.
The macroeconomic variables affecting the level of expected credit losses are the Gross Domestic product (hereinafter “GDP”), the
unemployment rate, the inflation rate and forward-looking prices of residential and commercial real estates.
The main features of these scenarios can be described as follows:
Baseline Scenario
Despite the elevated uncertainty surrounding the global economic landscape, Greek real GDP increased by 2% y-o-y in the first nine months of
2025, outperforming the respective euro area average (1.5% y-o-y). The rise in economic activity in January-September 2025 was mainly
supported by private consumption, on the back of, among other factors, the ongoing employment gains, the increase in households’
disposable income and tourism performance. The Greek economy is expected to continue its upward trajectory over the scenario horizon
amidst favorable conditions:
•
the strong fiscal performance, which along with the projected growth path are expected to further reduce the debt-to-GDP ratio,
•
the increasing contribution of investment to the growth mix, also as a result of the implementation of the Public Investment Budget
(PIB) in 2026 with multiplier effects on domestic economic growth in the medium term, and
•
the strong performance of the tourism sector.
Private consumption is projected to continue growing on the back of rising real disposable income following ongoing employment gains and
recently announced tax reliefs. The unemployment rate is expected to continue declining, albeit at a slower pace, while inflationary pressures
are expected to gradually ease. The upward trend in residential property prices is expected to continue, albeit at a decelerating pace.
Upside Scenario
In the upside scenario, Greek economy is assumed to record stronger growth rates compared to the baseline scenario, reflecting, inter alia,
rising investment and consumption, a stronger performance in tourism, a faster deceleration of the unemployment rate and stronger growth
in residential property prices.
Downside scenario
In the downside scenario, Greek economy is assumed to register weaker growth rates compared to the baseline scenario, reflecting, inter alia,
increased geopolitical and trade policy uncertainty, weaker-than-expected growth in the European economy and delays in the
implementation of the Resilience and Recovery Facility funds.
Specifically in Greece, the average of the macroeconomic variables which impact both the Probability of Default and the Loss Given Default in
the estimation of expected credit losses at 31.12.2025 (period 2026-2029) and the comparative period (period 2025-2028) are the following:
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
368 | ANNUAL FINANCIAL REPORT
31.12.2025 2026-2029 GREECE Downside Scenario Baseline Scenario Upside Scenario Real GDP growth (0.1%) 1.6% 3.3% Unemployment rate 10.0% 7.7% 5.5% Inflation 3.1% 2.2% 1.3% RRE prices change (2.3%) 2.0% 6.6% CRE Price Index change (0.5%) 1.3% 3.2% 31.12.2024 202 5 – 202 8 GREECE Downside Scenario Baseline Scenario Upside Scenario Real GDP growth 0.1% 1.9% 3.6% Unemployment rate 11.4% 8.6% 5.8% Inflation 3.4% 2.4% 1.4% RRE prices change (0.4)% 2.5% 5.3% CRE Price Index change 0.1% 1.9% 3.8% In the countries where the Group mainly operates, the year-on-year average of macroeconomic variables for the period 2026-2028 affecting
the expected credit risk loss as at 31.12.2025, is presented in the following tables:
31.12.2025 2026-2029 CYPRUS Downside Scenario Baseline Scenario Upside Scenario Real GDP growth (% change) 0.4% 2.9% 5.3% Unemployment (% change) 6.3% 4.6% 2.8% Inflation prices (% change) 3.4% 2.0% 0.5% RRE Price Index (% change) 1.4% 3.2% 5.0% CRE Price Index (% change) 0.5% 1.7% 2.9% Respectively, the average of the macroeconomic variables for the period 2025-2027 t hat impacted the expected credit losses at 31.12.2024 is
presented in the following tables:
31.12.2024 202 5 – 202 8 CYPRUS Downside Scenario Baseline Scenario Upside Scenario Real GDP growth (% change) 0.4% 3.0% 5.6% Unemployment (% change) 6.5% 4.8% 3.0% Inflation prices (% change) 3.6% 2.0% 0.8% RRE prices (% change) 1.5% 3.4% 5.4% CRE Price Index (% change) 0.9% 2.2% 3.4%
The production of baseline scenario, supported by a consistent economic description, constitutes the most likely scenario according to the
current economic conditions and the Group’s basic assessment of the course of the economy.
The cumulative probabilities of the macroeconomic scenarios for the Greek economy indicate that the economy performs better or worse
than forecasts of the baseline scenario and the alternative scenarios, i.e. the upside and downside scenario. For each one of the alternative
scenarios, the allowance for expected credit losses is calculated and weighted against the probability of each scenario in order to calculate the
weighted expected credit loss.
The cumulative probability assigned to the baseline scenario remained 60%, while cumulative probability assigned to the downside and
upside scenario remained 20% for each of the scenario.
If the assigned cumulative probability of the downside scenario was weighted at 100%, Expected Credit Losses would increase b y € 127. at
31.12.2025 (31.12.2024: € 106).
If the assigned cumulative probability of the upside scenario was weighted at 100%, Expected Credit Losses would decrease by € 95 at
31.12.2025 (31.12.2024: € 72).
The following table shows in more detail this impact per Stage classification.
Downside Scenario Baseline Scenario Upside Scenario Group 31.12.2025 31.12.2024 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Retail Exposures 10 6 78 (7) (4) (85) (6 2) Stage 1 7 10 (1) (1) (13) (1 1) Stage 2 62 46 (4) (1) (42) (33) Stage 3 37 22 (3) (2) (29) (1 8) Wholesale Exposures 21 28 (2) (2) (10) (10) Stage 1 5 4 (1) (1) (6) (4) Stage 2 13 20 (1) (1) (3) (2) Stage 3 3 4 (2) (4) Total 127 106 (9) (6) (95) (72)
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
369 | ANNUAL FINANCIAL REPORT
Downside Scenario Baseline Scenario Upside Scenario Bank 31.12.2025 31.12.2024 31.12.2025 31.12.2024 31.12.2025 31.12.2024 Retail Exposures 104 74 (7) (5) (8 3) (59) Stage 1 7 9 (1) (1) (13) (11) Stage 2 62 44 (4) (2) (42) (3 2) Stage 3 36 21 (3) (2) (29) (16) Wholesale Exposures 19 27 (2) (1) (9) (9) Stage 1 4 4 (1) (1) (5) (4) Stage 2 11 19 (1) (2) (2) Stage 3 3 4 (2) (3) Total 123 101 (9) (6) (9 2) (68) Undrawn loan commitments
According to IFRS 9, these contracts fall within the scope for expected credit losses recognition.
When estimating the allowance for expected credit losses over the life of an undrawn loan commitment, the Group assesses the expected
part of the loan commitment that will be used throughout its expected life.
Governance
Credit Risk Committee is responsible for approving the Expected Credit Losses as well as the methodologies developed by the Group for
calculating the expected credit loss (ECL Methodology) for loan portfolio.
The Board of Directors approves the Group Loan Impairment Policy through the Risk Management Committee.
FORBEARANCE
The maintenance of a healthy loan portfolio requires the continuous monitoring and evaluation of borrowers, to enable the early diagnosis of
future liquidity problems that will affect the repayment of their obligations to the Group.
The credit tools which are normally used by the Group for managing the liquidity problems that borrowers are facing for repaying their
obligations are the restructuring of debt through the renegotiation of the original terms and conditions of the loan agreement they have
entered into.
The purpose of debt settlement arrangements and definitive debt settlement solutions is to facilitate repayment through a more favorable
program for Borrowers facing financial difficulties which prevents them from fulfilling their current obligations to the Group.
The Group's objective is the effective and efficient management of debts (whether they are in arrears or considered non-performing) through
the development and implementation of a satisfactory number of alternative types/frames of arrangement and definitive debt settlement
solutions, with the aim of personalized assessment of each borrower.
Forbearance measures are proposed to cooperative and viable borrowers provided that they are assessed as effective and sustainable in the
long term, taking into account both the causes of the financial difficulty and the borrower's ability to repay.
Financial difficulty is defined as the situation where the debtor is unable to comply or is about to face difficulties in servicing his credit
obligations as per the current loan repayment schedule due to the worsening of his financial status.
Forborne exposure is defined as an exposure to which forbearance measures have been applied.
A forbearance measure is a concession towards an obligor that is experiencing or is likely to experience difficulties in meeting its financial
commitments (financial difficulty).
The concession may entail a loss for the Group and shall refer to either of the following actions that would not have been granted if the
obligor had not experienced financial difficulty:
a) a modification of the terms and conditions of a debt obligation.
b) a total or partial refinancing of a debt obligation.
WRITE-OFFS AND WRITE-DOWNS OF BAD DEBTS
Bad Debt Write-off is defined as the reduction of the gross carrying amount of a financial asset, when there is no reasonable expectation of
recovery. The write-off refers to the accounting write-off of a debt or a portion of it, i.e. the removal of the financial asset or part of it from
the balance sheet, which does not necessarily entail the waiver of the legal right to recover the debt. In the event that the Group decides to
waive its legal right to recover the debt, this is called Debt Forgiveness and this waiver may include either on or off-balance sheet items as
well.
Bad Debt Write-down is defined as the definitive reduction of a debt or portion of it, as a result of a legally binding decision or agreement
(court judgment, contractual agreement etc.), which is not further claimable. It is noted that this category encompasses Definitive Write-
Downs which are unconditional and Contingent Write-Downs subject to the achievement by the Customer of a specific performance (usually,
upon the successful implementation of a specific repayment program). In the case of Definitive Write-downs, both the accounting and the
legal reduction (Debt Forgiveness) take place immediately and simultaneously, whereas in the case of Contingent Write-downs, the
accounting reduction takes place when the relevant decision is taken or when the agreement is concluded, while the legal reduction (Debt
Forgiveness) takes place either simultaneously with the relevant decision or at a later (future) time, depending on the type of the condition.
DUE FROM FINANCIAL INSTITUTIONS
Exposure to credit institutions relates to loans. interbank transactions (which include positions in derivatives), reverse repos transactions and
International trade activities. Following the basic rules of designation, monitoring and revision of corporate lending, boundaries are
established by the relevant Credit Committees for the monitoring of credit risk for the overall exposure per credit institution counterparty,
excluding positions related to bonds issued by them. The approved credit limits are monitored on a daily basis. The validity period of the limits
is specified in the approval of the limits in accordance with the counterparty credit institutions rating from international credit rating
agencies.
In addition to the regular revisions of counterparty credit institutions limits, interim revisions may be carried out either due to circumstances
associated with the trading activity of the Group or due to markets conditions or problems associated with counterparty credit institutions.
Criteria for an extraordinary review are regularly monitored per counterparty in order to review the relevant limits when such criteria exist.
At each reporting date,a loss allowance for expected credit losses on due from financial institutions is recognized.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
370 | ANNUAL FINANCIAL REPORT
Investments in debt securities relate to securities that are classified into investment security portfolio. If there is a loan relationship with the
counterparty issuer at the time of classification of the security position as investment, the Corporate Credit Policy procedures apply. These
positions are subject to Group investment limits and issuer’s limits and are monitored on a daily basis.
At each reporting date, a loss allowance for expected credit losses on bonds, which are not measured at fair value through profit or loss, is
recognized. The loss allowance is based on expected credit losses related to the probability of default within the next twelve months, unless there
has been a significant increase in credit risk from the date of initial recognition in which case expected credit losses are recognised over the entire
lifetime of the asset. Also, if the receivable or security falls within the definition of impaired financial instruments upon initial recognition
(Purchased or Originated Credit - Impaired - POCI), an impairment provision equal to the expected credit losses for its entire life is recognized.
Credit risk of investment in debt securities is assessed based on credit ratings of rating agencies or internal credit rating in case of Greek corporate
issuers for which loan exposure exists.
The Group defines as low credit risk all investment grade securities, for which it calculates a credit allowance equal to a 12-month expected credit
loss (Stage 1). For debt securities, which do not meet the criteria of investment grade, the assessment of the significant increase in credit risk for
which calculation of lifetime expected credit losses is required (Stage 2), is based on the two following conditions (whichever occurs first):
- Downgrade by at least two notches of the counterparty credit rating between the reporting date and the initial recognition date.
- The 12-month PD at reporting date is above 5% in absolute terms and has increased more than 50% compared to the respective PD existing at
initial recognition date.
In addition, the Group is monitoring, the change in credit spreads since the initial recognition date. A change in the credit spread of the issue of
more than 500bps since the initial recognition date is a trigger for the review of the debt instrument staging.
Depending on the outcome of the above review the debt instrument will remain at Stage 1 or be allocated at Stage 2, regardless of whether the
primary staging criteria for allocation to Stage 2 have been triggered or not.
FINANCIAL ASSETS EXPOSURE TO CREDIT RISK
The maximum credit risk exposure per category of financial asset in which the Group and the Bank are exposed is depicted in the “Net
exposure to credit risk” column.
31.12.2025 31.12.2024 Provision Net Provision Exposure Exposure Net Group for exposure for before before exposure to impairment to credit impairment impairment impairment credit risk losses risk losses A. Credit risk expo sure relating to ba lance sheet item s Balances with central Bank s 2,993 2,993 2,539 2,539 Receivab les from credit i nstitutions 2,863 70 2,793 2,366 70 2,296 Loans and adv ances to cust omers 44,120 637 43,483 40,426 601 39,825 Derivat ive financial ass ets 445 445 628 628 Trading securi ties 37 37 28 28 Investment s ecurities measur ed at fair value through other comprehensive inc ome 1,104 1,104 970 1 969 Investment s ecurities measur ed at amortised co st 16,193 17 16,176 15,664 19 15,645 Investment s ecurities measur ed at fair value through profit o r loss 11 11 11 1 10 Held for s ale assets - Loan’s po rtfolio 476 363 113 1,576 959 617 Total amount of bal ance sheet ite ms exposed to cr edit risk (a) 68,242 1,087 67,155 64,208 1,651 62,557 Β. Credit risk expo sure relating to off balance sheet i tems: 11,878 26 11,852 10,285 24 10,261 Total credit risk exp osure (a+b) 80,120 1,113 79,007 74,493 1,675 72,818 31.12.2025 31.12.2024 Provision Net Provision Exposure Exposure Net Bank for exposure for before before exposure to impairment to credit impairment impairment impairment credit risk losses risk losses A. Credit risk expo sure relating to ba lance sheet item s Balances with central Bank s 1,767 1,767 1,312 1,312 Receivab les from credit i nstitutions 2,941 70 2,871 2,311 71 2,240 Loans and adv ances to cust omers 41,070 570 40,500 38,4 51 570 37,881 Derivat ive financial ass ets 446 446 740 740 Trading securi ties 37 37 29 29 Investment s ecurities measur ed at fair value through other comprehensive inc ome 1,059 1,059 919 919 Investment s ecurities measur ed at amortised co st 14,485 16 14,469 14,728 18 14,710 Investment s ecurities measur ed at fair value through profit o r loss 10 10 10 10 Held for s ale assets - Loan’s po rtfolio 280 198 82 1,320 811 509 Total amount of bal ance sheet ite ms exposed to cr edit risk (a) 62,095 854 61,241 59,819 1,470 58,350 Β. Credit risk expo sure relating to off balance sheet i tems: 11,583 22 11,561 10,361 22 10,339 Total credit risk exp osure (a+b) 73,678 876 72,802 70,180 1,492 68,689 LOANS AND ADVANCES TO CUSTOMERS
For credit risk disclosure purposes, the allowance for expected credit losses of loans measured at amortised cost includes also the fair value
adjustment for the contractual balance of loans which were impaired at their acquisition or origination (POCI) since the Group, from credit
risk perspective, monitors the respective adjustment as part of the provisions. These loans were recognized either in the context of
acquisition of specific loans or companies (i.e. Emporiki Bank and Citibank’s retail operations in Greece), or as a result of significant
modification of the terms of the previous loan that led to derecognition. Relevant adjustment has also been performed at the carrying
amount of loans before allowance for expected credit losses.
It is noted that the credit risk tables do not include the outstanding balances and allowance for expected credit losses of loans that have been
classified as assets held for sale.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
371 | ANNUAL FINANCIAL REPORT
Loans by credit quality and IFRS 9 Stage
The following tables present past due and not past due loans, measured at amortised cost, per IFRS 9 Stage as well as loans that are measured at fair value through profit or loss, as at 31.12.2025 and
31.12.2024:
31.12.2025 Group Loans measur ed at amor tised cost Loans measur ed at fair va lue Stage 1 Stage 2 Stage 3 POCI Total through prof it or loss MORTGAGE Strong credit quality 3,945 3,945 Satisfactory credit quali ty 390 400 236 1,026 Watch list (hig her risk) 36 895 188 1,119 Default 746 136 882 Carrying amo unt (befor e allowanc e for expect ed credit loss es) 4,371 1,295 746 560 6,972 Allowance for expected cre dit losses (8) (57) (143) (33) (241) Net Carrying Am ount 4,363 1,238 603 527 6,731 - Value of col lateral 4,223 1,224 672 524 6,643 CONSUME R Strong credit quality 714 714 Satisfactory credit quali ty 113 43 57 213 Watch list (hig her risk) 13 115 60 188 Default 134 65 199 Carrying amo unt (befor e allowanc e for expect ed credit loss es) 840 158 134 182 1,314 Allowance for expected cre dit losses (5) (19) (69) (36) (129) Net Carrying Am ount 835 139 65 146 1,185 - Value of col lateral 300 51 29 103 483 CREDIT CA RDS Strong credit quality 733 733 Satisfactory credit quali ty 14 50 64 Watch list (hig her risk) 37 37 Default 28 1 29 Carrying amo unt (befor e allowanc e for expect ed credit loss es) 747 87 28 1 863 Allowance for expected cre dit losses (4) (9) (21) (1) (35) Net Carrying Am ount 743 78 7 - 828 - Value of col lateral 2 1 3 SMALL BU SINESSES Strong credit quality 1,014 1,014 Satisfactory credit quali ty 51 229 29 309 Watch list (hig her risk) 33 245 25 303 Default 236 58 294 Carrying amo unt (befor e allowanc e for expect ed credit loss es) 1,098 474 236 112 1,920 Allowance for expected cre dit losses (4) (36) (76) (40) (156) Net Carrying Am ount 1,094 438 160 72 1,764 - Value of col lateral 687 331 171 67 1,256 LARGE CO RPORATE Strong credit quality 22,015 22,015 162 Satisfactory credit quali ty 1,085 368 4 1,457 Watch list (hig her risk) 221 276 9 506 Default 55 18 73 Carrying amo unt (befor e allowanc e for expect ed credit loss es) 23,321 644 55 31 24,051 Allowance for expected cre dit losses (7) (11) (16) (12) (46)
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
372 | ANNUAL FINANCIAL REPORT
31.12.2025 Group Loans measur ed at amor tised cost Loans measur ed at fair va lue Stage 1 Stage 2 Stage 3 POCI Total through prof it or loss Net Carrying Am ount 23,314 633 39 19 24,005 162 Value of col lateral 14,476 507 50 29 15,062 109 SME’s Strong credit quality 4,308 5 4,313 Satisfactory credit quali ty 2,756 510 1 3,267 Watch list (hig her risk) 32 29 61 Default 163 15 178 Carrying amo unt (befor e allowanc e for expect ed credit loss es) 7,096 544 163 16 7,819 - Allowance for expected cre dit losses (3) (3) (50) (6) (62) Net Carrying Am ount 7,093 541 113 10 7,757 - Value of col lateral 4,547 404 130 14 5,095 PUBLIC SECTO R Strong credit quality 3 3 Satisfactory credit quali ty 73 73 Watch list (hig her risk) - Default - Carrying amo unt (befor e allowanc e for expect ed credit loss es) 76 - - - 76 Allowance for expected cre dit losses - Net Carrying Am ount 76 - - - 76 - Value of col lateral 76 76
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
373 | ANNUAL FINANCIAL REPORT
31.12.2024 Group Loans measured at a mortised co st Loans measured at fai r value Stage 1 Stage 2 Stage 3 POCI Total through profit or l oss MORTGAGE Strong credi t quality 3,847 3,847 Satisfact ory credit quality 359 170 214 743 Watch list (higher risk) 177 1,140 285 1,602 Default 595 99 694 Carrying amount (before allowanc e for expected credit losses) 4,383 1,310 595 598 6,886 - Allowance f or expected credit losses (7) (30) (112) (24) (173) Net Carrying A mount 4,376 1,280 483 574 6,713 - Value of c ollateral 4,236 1,225 543 552 6,556 CONSUMER Strong credi t quality 559 559 Satisfact ory credit quality 150 34 71 255 Watch list (higher risk) 4 139 63 206 Default 140 51 191 Carrying amount (before allowanc e for expected credit losses) 713 173 140 185 1,211 - Allowance f or expected credit losses (4) (20) (66) (29) (119) Net Carrying A mount 709 153 74 156 1,092 - Value of c ollateral 254 41 25 102 422 CREDIT CARDS Strong credi t quality 739 739 Satisfact ory credit quality 16 41 57 Watch list (higher risk) 32 32 Default 34 1 35 Carrying amount (before allowanc e for expected credit losses) 755 73 34 1 863 - Allowance f or expected credit losses (4) (7) (24) (1) (36) Net Carrying A mount 751 66 10 - 827 - Value of c ollateral 2 1 3 SMALL BUSINES SES Strong credi t quality 899 899 Satisfact ory credit quality 20 250 28 298 Watch list (higher risk) 15 338 34 387 Default 218 61 279 Carrying amount (before allowanc e for expected credit losses) 934 588 218 123 1,863 - Allowance f or expected credit losses (3) (37) (77) (37) (154) Net Carrying A mount 931 551 141 86 1,709 - Value of c ollateral 669 410 142 76 1,297 LARGE CORPORAT E Strong credi t quality 19,664 30 19,694 127 Satisfact ory credit quality 960 504 4 1,468 Watch list (higher risk) 44 144 10 198 Default 60 4 64 Carrying amount (before allowanc e for expected credit losses) 20,668 678 60 18 21,424 Allowance f or expected credit losses (6) (9) (21) (36) Net Carrying A mount 20,662 669 39 18 21,388 127
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
374 | ANNUAL FINANCIAL REPORT
31.12.2024 Group Loans measured at a mortised co st Loans measured at fai r value Stage 1 Stage 2 Stage 3 POCI Total through profit or l oss Value of c ollateral 14,383 597 51 14 15,045 126 SME’s Strong credi t quality 3,632 3,632 Satisfact ory credit quality 2,826 414 2 3,242 Watch list (higher risk) 32 15 47 Default 207 19 226 Carrying amount (before allowanc e for expected credit losses) 6,490 429 207 21 7,147 - Allowance f or expected credit losses (4) (2) (78) (11) (95) Net Carrying A mount 6,486 427 129 10 7,052 - Value of c ollateral 4,234 322 150 14 4,720 PUBLIC SECTOR Strong credi t quality 20 20 Satisfact ory credit quality 11 11 Watch list (higher risk) - Default 1 1 Carrying amount (before allowanc e for expected credit losses) 31 - 1 - 32 - Allowance f or expected credit losses (1) (1) Net Carrying A mount 31 - - - 31 - Value of c ollateral 17 17
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
375 | ANNUAL FINANCIAL REPORT
31.12.2025 Bank Loans measured at a mortised co st Loans measured at fai r value Stage 1 Stage 2 Stage 3 POCI Total through profit or l oss MORTGAGE Strong credi t quality 3,365 3,365 Satisfact ory credit quality 269 380 221 870 Watch list (higher risk) 1 853 181 1,035 Default 685 121 806 Carrying amount (before allowanc e for expected credit losses) 3,635 1,233 685 523 6,076 Allowance f or expected credit losses (7) (57) (113) (27) (204) Net Carrying A mount 3,628 1,176 572 496 5,872 - Value of c ollateral 3,517 1,165 632 493 5,807 CONSUMER Strong credi t quality 632 632 Satisfact ory credit quality 99 38 56 193 Watch list (higher risk) 5 111 59 175 Default 131 52 183 Carrying amount (before allowanc e for expected credit losses) 736 149 131 167 1,183 Allowance f or expected credit losses (5) (19) (67) (28) (119) Net Carrying A mount 731 130 64 139 1,064 - Value of c ollateral 242 46 28 98 414 CREDIT CARDS Strong credi t quality 724 724 Satisfact ory credit quality 14 50 64 Watch list (higher risk) 37 37 Default 27 1 28 Carrying amount (before allowanc e for expected credit losses) 738 87 27 1 853 Allowance f or expected credit losses (4) (9) (20) (1) (34) Net Carrying A mount 734 78 7 - 819 - Value of c ollateral 1 1 2 SMALL BUSINES SES Strong credi t quality 991 991 Satisfact ory credit quality 39 226 28 293 Watch list (higher risk) 23 243 25 291 Default 234 53 287 Carrying amount (before allowanc e for expected credit losses) 1,053 469 234 106 1,862 Allowance f or expected credit losses (4) (36) (75) (38) (153) Net Carrying A mount 1,049 433 159 68 1,709 - Value of c ollateral 660 328 169 64 1,221 LARGE CORPORAT E Strong credi t quality 22,263 22,263 162 Satisfact ory credit quality 460 367 4 831 Watch list (higher risk) 58 168 9 235 Default 42 3 45 Carrying amount (before allowanc e for expected credit losses) 22,781 535 42 16 23,374 Allowance f or expected credit losses (6) (6) (4) (16) Net Carrying A mount 22,775 529 38 16 23,358 162
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
376 | ANNUAL FINANCIAL REPORT
31.12.2025 Bank Loans measured at a mortised co st Loans measured at fai r value Stage 1 Stage 2 Stage 3 POCI Total through profit or l oss Value of c ollateral 13,111 405 39 16 13,571 109 SME’s Strong credi t quality 3,973 3,973 Satisfact ory credit quality 2,215 480 1 2,696 Watch list (higher risk) 14 14 Default 153 8 161 Carrying amount (before allowanc e for expected credit losses) 6,188 494 153 9 6,844 Allowance f or expected credit losses (3) (3) (44) (3) (53) Net Carrying A mount 6,185 491 109 6 6,791 - Value of c ollateral 3,689 359 125 8 4,181 PUBLIC SECTOR Strong credi t quality 3 3 Satisfact ory credit quality 10 10 Watch list (higher risk) - Default - Carrying amount (before allowanc e for expected credit losses) 13 - - - 13 Allowance f or expected credit losses - Net Carrying A mount 13 - - - 13 - Value of c ollateral 13 13
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
377 | ANNUAL FINANCIAL REPORT
31.12.2024 Bank Loans measured at a mortised co st Loans measured at fai r value Stage 1 Stage 2 Stage 3 POCI Total through profit or l oss MORTGAGE Strong credi t quality 3,455 3,455 Satisfact ory credit quality 292 141 201 634 Watch list (higher risk) 177 1,086 276 1,538 Default 559 95 654 Carrying amount (before allowanc e for expected credit losses) 3,924 1,227 559 571 6,281 - Allowance f or expected credit losses (7) (28) (101) (23) (159) Net Carrying A mount 3,917 1,199 458 548 6,122 - Value of c ollateral 3,787 1,147 517 528 5,980 CONSUMER Strong credi t quality 519 519 Satisfact ory credit quality 137 28 69 233 Watch list (higher risk) 4 135 62 202 Default 138 51 189 Carrying amount (before allowanc e for expected credit losses) 660 163 138 182 1,143 - Allowance f or expected credit losses (4) (19) (66) (29) (118) Net Carrying A mount 656 144 73 153 1,025 - Value of c ollateral 223 35 24 101 383 CREDIT CARDS Strong credi t quality 734 734 Satisfact ory credit quality 16 41 57 Watch list (higher risk) 32 32 Default 34 1 35 Carrying amount (before allowanc e for expected credit losses) 750 73 34 1 857 - Allowance f or expected credit losses (3) (7) (24) (1) (36) Net Carrying A mount 747 65 10 - 821 - Value of c ollateral 1 1 2 SMALL BUSINES SES Strong credi t quality 887 887 Satisfact ory credit quality 20 248 27 295 Watch list (higher risk) 15 338 34 386 Default 217 61 278 Carrying amount (before allowanc e for expected credit losses) 922 585 217 122 1,846 - Allowance f or expected credit losses (3) (37) (77) (37) (154) Net Carrying A mount 9 19 548 140 85 1,692 - Value of c ollateral 659 408 142 75 1,284 LARGE CORPORAT E Strong credi t quality 19,934 19,934 116 Satisfact ory credit quality 801 360 4 1,165 Watch list (higher risk) 30 43 9 82 Default 53 4 57 Carrying amount (before allowanc e for expected credit losses) 20,765 403 53 17 21,238 - Allowance f or expected credit losses (7) (2) (1 5) (1) (2 5) Net Carrying A mount 20,758 401 38 16 21,213 116
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
378 | ANNUAL FINANCIAL REPORT
31.12.2024 Bank Loans measured at a mortised co st Loans measured at fai r value Stage 1 Stage 2 Stage 3 POCI Total through profit or l oss Value of c ollateral 13,615 331 50 14 14,010 115 SME’s Strong credi t quality 3,396 3,396 Satisfact ory credit quality 2,349 372 2 2,723 Watch list (higher risk) 2 9 11 Default 197 19 21 6 Carrying amount (before allowanc e for expected credit losses) 5,747 38 1 197 21 6,346 - Allowance f or expected credit losses (4) (2) (73) (11) (9 0) Net Carrying A mount 5,743 379 12 4 10 6,256 - Value of c ollateral 3,514 275 144 14 3,947 PUBLIC SECTOR Strong credi t quality 20 20 Satisfact ory credit quality 11 11 Default 1 1 Carrying amount (before allowanc e for expected credit losses) 31 - 1 - 32 - Allowance f or expected credit losses (1) (1) Net Carrying A mount 31 - - - 31 - Value of c ollateral 17 17 Letters of guarantee, letters of credit and un drawn loan commitments by credit quality and IFRS 9 Stage 31.12.2025 Group Stage 1 Stage 2 Stage 3 POCI Total Letters of guarant ee, letters of cr edit and other guara ntees Strong credi t quality 5,672 5,672 Satisfact ory credit quality 516 83 599 Watch list (higher risk) 238 7 245 Default 190 2 192 Carrying amount (before allowanc e for expected credit losses) 6,426 90 190 2 6,708 Allowance f or expected credit losses (2) (22) (24) Net Carrying A mount 6,424 90 168 2 6,684 Value of collateral of impaired letter s of guarantee, lett ers of credit and other guarant ees 226 7 27 2 262 Undrawn loan co mmitments Strong credi t quality 4,578 4,578 Satisfact ory credit quality 478 66 3 547 Watch list (higher risk) 16 29 45 Default 1 1 Carrying amount (before allowanc e for expected credit losses) 5,072 95 1 3 5,171 Allowance f or expected credit losses (1) (1) Net Carrying A mount 5,071 95 1 3 5,170 Value of collateral of impaired un drawn loan co mmitments 1 1
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
379 | ANNUAL FINANCIAL REPORT
31.12.2024 Group Stage 1 Stage 2 Stage 3 POCI Total Letters of guarant ee, letters of cr edit and other guara ntees Strong credi t quality 4,551 4,551 Satisfact ory credit quality 575 159 734 Watch list (higher risk) 238 10 248 Default 203 203 Carrying amount (before allowanc e for expected credit losses) 5,364 169 203 - 5,736 Allowance f or expected credit losses (1) (21) (22) Net Carrying A mount 5,363 169 182 - 5,714 Value of collateral of impaired letter s of guarantee, lett ers of credit and other guarant ees 207 12 29 248 Undrawn loan co mmitments Strong credi t quality 3,9 55 3,9 55 Satisfact ory credit quality 424 144 3 571 Watch list (higher risk) 5 23 28 Default - Carrying amount (before allowanc e for expected credit losses) 4,384 167 - 3 4,5 54 Allowance f or expected credit losses (2) (2) Net Carrying A mount 4,382 167 - 3 4,5 52 Value of collateral of impaired un drawn loan co mmitments 31.12.2025 Bank Stage 1 Stage 2 Stage 3 POCI Total Letters of guarant ee, letters of cr edit and other guara ntees Strong credi t quality 5,611 5,611 Satisfact ory credit quality 500 83 583 Watch list (higher risk) 233 7 240 Default 190 190 Carrying amount (before allowanc e for expected credit losses) 6,344 90 190 - 6,624 Allowance f or expected credit losses (2) (21) (23) Net Carrying A mount 6,342 90 169 - 6,601 Value of collateral of impaired letter s of guarantee, lett ers of credit and other guarant ees 209 7 28 244 Undrawn loan co mmitments Strong credi t quality 4,441 4,441 Satisfact ory credit quality 375 64 3 442 Watch list (higher risk) 4 26 30 Default - Carrying amount (before allowanc e for expected credit losses) 4,820 90 - 3 4,913 Allowance f or expected credit losses - Net Carrying A mount 4,820 90 - 3 4,913 Value of collateral of impaired un drawn loan co mmitments -
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
380 | ANNUAL FINANCIAL REPORT
31.12.2024 Bank Stage 1 Stage 2 Stage 3 POCI Total Letters of guarant ee, letters of cr edit and other guara ntees Strong credi t quality 4,604 4,604 Satisfact ory credit quality 590 143 733 Watch list (higher risk) 238 10 248 Default 201 201 Carrying amount (before allowanc e for expected credit losses) 5,432 153 201 - 5,786 Allowance f or expected credit losses (1) (21) (22) Net Carrying A mount 5,431 153 18 0 - 5,764 Value of collateral of impaired letter s of guarantee, lett ers of credit and other guarant ees 205 12 30 248 Undrawn loan co mmitments Strong credi t quality 3,985 3,985 Satisfact ory credit quality 369 143 3 515 Watch list (higher risk) 5 22 27 Default - Carrying amount (before allowanc e for expected credit losses) 4,3 59 16 5 - 3 4,527 Allowance f or expected credit losses Net Carrying A mount 4,3 59 16 5 - 3 4,527 Value of collateral of impaired un drawn loan co mmitments
The value of the collaterals that relates to impaired exposures for Group, amounts to € 1,279 as at 31.12.2025 (31.12.2024: € 1,085) and for the Bank € 1,184 as at 31.12.2025 (31.12.2024: € 1,049).
Ageing analysis by IFRS 9 Stage and product line of loans
The following tables present the ageing analysis as of 31.12.2025 and 31.12.2024 and the allocation of the net carrying amount of the loans per loan portfolio and IFRS 9 Stage including the collateral value.
31.12.2025 Loans measured at fai r value thro ugh profit or loss (FVPL) Loans measured at a mortised co st Group Retail lending Corporate lendi ng Retail lending Total Mortgage Consumer Large Corporate SME’s Stage 1 Stage 2 Stage 3 POCI Total Current 162 162 4,336 1,137 233 449 6,155 1 - 30 days 35 104 15 17 171 31 - 60 days 34 10 10 54 61 - 90 days 20 10 5 35 91 - 180 days 67 19 86 181 - 360 days 111 28 139 > 360 days 300 32 332 Carrying amount (before allowanc e for expected credit losses) 4,371 1,295 746 560 6,972 Allowance f or expected credit losses (8) (57) (143) (33) (241) Net Carrying A mount 162 162 4,363 1,238 603 527 6,731 Value of c ollaterals 109 1 09 4,223 1,224 672 524 6,643
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
381 | ANNUAL FINANCIAL REPORT
31.12.2025 Loans measured at a mortised co st Group Retail lending Consumer Credit cards Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 821 122 30 122 1,095 743 74 3 820 1 - 30 days 19 23 6 9 57 4 7 11 31 - 60 days 9 3 3 15 4 4 61 - 90 days 4 2 2 8 2 2 91 - 180 days 15 5 20 4 4 181 - 360 days 25 10 35 6 6 > 360 days 53 31 84 15 1 16 Carrying amount (before allowanc e for expected credit losses) 840 158 134 182 1,314 747 87 28 1 863 Allowance f or expected credit losses (5) (19) (69) (36) (129) (4) (9) (21) (1) (35) Net Carrying A mount 835 139 65 146 1,185 743 78 7 - 828 Value of c ollaterals 300 51 29 103 483 2 1 3 31.12.2025 Loans measured at a mortised co st Group Retail lending Corporate lendi ng Small Business Large Corporate Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 1,088 422 48 55 1,613 21,537 459 42 15 22,053 1 - 30 days 10 33 3 4 50 1,784 179 1,963 31 - 60 days 13 4 17 - 61 - 90 days 6 2 8 6 6 91 - 180 days 27 2 29 - 181 - 360 days 35 4 39 3 3 > 360 days 117 47 164 13 13 26 Carrying amount (before allowanc e for expected credit losses) 1,098 474 236 112 1,920 23,321 644 55 31 24,051 Allowance f or expected credit losses (4) (36) (76) (40) (156) (7) (11) (16) (12) (46) Net Carrying A mount 1,094 438 160 72 1,764 23,314 633 39 19 24,005 Value of c ollaterals 687 331 171 67 1,256 14,476 507 50 29 15,062
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
382 | ANNUAL FINANCIAL REPORT
31.12.2025 Loans measured at a mortised co st Group Corporate lendi ng Public Sector SME’s Greece Other countries Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 6,669 490 57 1 7,217 13 13 63 63 1 - 30 days 427 25 11 1 464 - - 31 - 60 days 28 2 30 - - 61 - 90 days 1 1 5 7 - - 91 - 180 days 14 14 - - 181 - 360 days 5 5 - - > 360 days 73 9 82 - - Carrying amount (before allowanc e for expected credit 7,096 544 163 16 7,819 13 - - - 13 63 - - - 63 losses) Allowance f or expected credit losses (3) (3) (50) (6) (62) - - Net Carrying A mount 7,093 541 113 10 7,757 13 - - - 13 63 - - - 63 Value of c ollaterals 4,547 404 130 14 5,095 13 13 63 63 31.12.2024 Loans measured at fai r value thro ugh profit or loss (FVPL) Loans measured at a mortised co st Group Retail lending Corporate lendi ng Retail lending Total Mortgage Consumer Large Corporate SME’s Stage 1 Stage 2 Stage 3 POCI Total Current 127 127 4,340 1,149 175 503 6,167 1 - 30 days 43 87 15 25 170 31 - 60 days 38 12 12 62 61 - 90 days 36 11 11 58 91 - 180 days 69 14 83 181 - 360 days 67 15 82 > 360 days 246 18 264 Carrying amount (before allowanc e for expected credit losses) 4,383 1,310 595 598 6,886 Allowance f or expected credit losses (7) (30) (112) (24) (173) Net Carrying A mount - 127 - 127 4,376 1,280 483 574 6,713 Value of c ollaterals 126 126 4,236 1,225 543 552 6,556
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
383 | ANNUAL FINANCIAL REPORT
31.12.2024 Loans measured at a mortised co st Group Retail lending Consumer Credit cards Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 694 138 37 139 1,008 750 61 3 814 1 - 30 days 19 24 7 9 59 5 7 1 13 31 - 60 days 7 4 2 13 3 3 61 - 90 days 4 3 3 10 2 2 91 - 180 days 17 5 22 4 4 181 - 360 days 18 7 25 5 5 > 360 days 54 20 74 21 1 22 Carrying amount (before allowanc e for expected credit losses) 713 173 140 185 1,211 755 73 34 1 863 Allowance f or expected credit losses (4) (20) (66) (29) (119) (4) (7) (24) (1) (36) Net Carrying A mount 709 153 74 156 1,092 751 66 10 - 827 Value of c ollaterals 254 41 25 102 422 2 1 3 31.12.2024 Loans measured at a mortised co st Group Retail lending Corporate lendi ng Small Business Large Corporate Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 927 530 53 64 1,574 19,115 549 45 18 19,727 1 - 30 days 7 45 5 4 61 1,553 129 1,682 31 - 60 days 8 3 2 13 - 61 - 90 days 5 3 1 9 10 10 91 - 180 days 18 2 20 - 181 - 360 days 21 2 23 - > 360 days 115 48 163 5 5 Carrying amount (before allowanc e for expected credit losses) 934 588 218 123 1,863 20,668 678 60 18 21,424 Allowance f or expected credit losses (3) (37) (77) (37) (154) (6) (9) (21) (36) Net Carrying A mount 931 551 141 86 1,709 20,662 669 39 18 21,388 Value of c ollaterals 669 410 142 76 1,297 14,383 597 51 14 15,045
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
384 | ANNUAL FINANCIAL REPORT
31.12.2024 Loans measured at a mortised co st Group Corporate lendi ng Public Sector SME’s Greece Other countries Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 6,047 384 75 2 6,508 17 17 15 15 1 - 30 days 443 26 5 474 - - 31 - 60 days 13 5 18 - - 61 - 90 days 6 6 - - 91 - 180 days 13 13 - - 181 - 360 days 17 17 - - > 360 days 92 19 111 1 1 - Carrying amount (before allowanc e for expected credit losses) 6,490 429 207 21 7,147 17 - 1 - 18 15 - - - 15 Allowance f or expected credit losses (4) (2) (78) (11) (95) (1) (1) - Net Carrying A mount 6,486 427 129 10 7,052 17 - - - 17 15 - - - 15 Value of c ollaterals 4,234 322 150 14 4,720 17 17 - 31.12.2025 Loans measured at fai r value thro ugh profit or loss (FVPL) Loans measured at a mortised co st Bank Retail lending Corporate lendi ng Retail lending Total Mortgage Consumer Large Corporate SME’s Stage 1 Stage 2 Stage 3 POCI Total Current 162 162 3,618 1,086 230 425 5,359 1 - 30 days 17 95 15 15 142 31 - 60 days 33 9 9 51 61 - 90 days 19 11 5 35 91 - 180 days 66 18 84 181 - 360 days 107 28 135 > 360 days 247 23 270 Carrying amount (before allowanc e for expected credit losses) - 3,635 1,233 685 523 6,076 Allowance f or expected credit losses (7) (57) (113) (27) (204) Net Carrying A mount - 162 162 3,628 1,176 572 496 5,872 Value of c ollaterals 1 09 1 09 3,517 1,165 632 493 5,807
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
385 | ANNUAL FINANCIAL REPORT
31.12.2025 Loans measured at a mortised co st Bank Retail lending Consumer Credit cards Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 720 115 30 118 983 734 74 3 811 1 - 30 days 16 22 6 9 53 4 7 11 31 - 60 days 9 3 3 15 4 4 61 - 90 days 3 2 2 7 2 2 91 - 180 days 14 5 19 4 4 181 - 360 days 25 9 34 6 6 > 360 days 51 21 72 14 1 15 Carrying amount (before allowanc e for expected credit losses) 736 149 131 167 1,183 738 87 27 1 853 Allowance f or expected credit losses (5) (19) (67) (28) (119) (4) (9) (20) (1) (34) Net Carrying A mount 731 130 64 139 1,064 734 78 7 - 819 Value of c ollaterals 242 46 28 98 414 1 1 2 31.12.2025 Loans measured at a mortised co st Bank Retail lending Corporate lendi ng Small Business Large Corporate Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 1,046 420 48 53 1,567 21,049 418 39 13 21,519 1 - 30 days 7 32 4 3 46 1,732 112 1,844 31 - 60 days 11 4 1 16 - 61 - 90 days 6 2 8 5 5 91 - 180 days 26 2 28 - 181 - 360 days 35 4 39 3 3 > 360 days 115 43 158 3 3 Carrying amount (before allowanc e for expected credit losses) 1,053 469 234 106 1,862 22,781 535 42 16 23,374 Allowance f or expected credit losses (4) (36) (75) (38) (153) (6) (6) (4) (16) Net Carrying A mount 1,049 433 159 68 1,709 22,775 529 38 16 23,358 Value of c ollaterals 660 328 169 64 1,221 13,111 405 39 16 13,571
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
386 | ANNUAL FINANCIAL REPORT
31.12.2025 Loans measured at a mortised co st Bank Corporate lendi ng Public Sector SME’s Greece Other countries Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 5,816 443 56 1 6,316 13 13 1 - 30 days 372 23 9 404 31 - 60 days 27 2 29 61 - 90 days 1 1 2 91 - 180 days 14 14 181 - 360 days 5 5 > 360 days 66 8 74 Carrying amount (before allowanc e for expected credit losses) 6,188 494 153 9 6,844 13 - - 13 - - - - - Allowance f or expected credit losses (3) (3) (44) (3) (53) - Net Carrying A mount 6,185 491 109 6 6,791 13 - - 13 - - - - Value of c ollaterals 3,689 359 125 8 4,181 13 13 31.12.2024 Loans measured at fai r value thro ugh profit or loss (FVPL) Loans measured at a mortised co st Bank Retail lending Corporate lendi ng Retail lending Total Mortgage Consumer Large Corporate SME’s Stage 1 Stage 2 Stage 3 POCI Total Current 116 116 3,881 1,077 16 6 480 5,604 1 - 30 days 43 77 15 23 158 31 - 60 days 37 12 11 60 61 - 90 days 36 11 11 57 91 - 180 days 65 14 79 181 - 360 days 60 14 74 > 360 days 230 18 24 8 Carrying amount (before allowanc e for expected credit losses) 3,924 1,227 559 571 6,281 Allowance f or expected credit losses (7) (28) (101) (23) (159) Net Carrying A mount - 116 - 116 3,917 1,199 458 548 6,122 Value of c ollaterals 115 115 3,787 1,147 517 528 5,980
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
387 | ANNUAL FINANCIAL REPORT
31.12.2024 Loans measured at a mortised co st Bank Retail lending Consumer Credit cards Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 641 129 38 136 944 745 61 2 808 1 - 30 days 19 23 7 9 58 5 7 1 13 31 - 60 days 7 4 2 13 3 3 61 - 90 days 4 3 3 10 2 2 91 - 180 days 16 5 21 4 4 181 - 360 days 17 7 24 5 5 > 360 days 53 20 73 22 1 23 Carrying amount (before allowanc e for expected credit losses) 660 163 138 182 1,143 750 73 34 1 858 Allowance f or expected credit losses (4) (19) (66) (29) (118) (3) (7) (24) (1) (35) Net Carrying A mount 656 144 72 153 1,025 747 66 10 - 823 Value of c ollaterals 223 35 24 101 383 1 1 2 31.12.2024 Loans measured at a mortised co st Bank Retail lending Corporate lendi ng Small Business Large Corporate Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 915 527 53 63 1,558 19,350 274 40 17 19,681 1 - 30 days 7 45 5 4 61 1,415 129 1,544 31 - 60 days 8 3 2 13 - 61 - 90 days 5 3 1 9 10 10 91 - 180 days 18 2 20 - 181 - 360 days 21 2 23 - > 360 days 114 48 162 3 3 Carrying amount (before allowanc e for expected credit losses) 922 585 217 122 1,846 20,765 403 53 17 21,238 Allowance f or expected credit losses (3) (37) (77) (37) (154) (7) (2) (15) (1) (25) Net Carrying A mount 919 548 140 85 1,692 20,758 401 38 16 21,213 Value of c ollaterals 659 408 142 75 1,284 13,615 331 50 14 14,010
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
388 | ANNUAL FINANCIAL REPORT
31.12.2024 Loans measured at a mortised co st Bank Corporate lendi ng Public Sector SME’s Greece Other countries Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Current 5,340 339 74 2 5,755 17 17 15 15 1 - 30 days 407 25 3 435 - - 31 - 60 days 12 5 17 - - 61 - 90 days 5 5 - - 91 - 180 days 13 13 - - 181 - 360 days 17 17 - - > 360 days 85 19 104 1 1 - Carrying amount (before allowanc e for expected credit losses) 5,747 381 197 21 6,346 17 - 1 - 18 15 - - - 15 Allowance f or expected credit losses (4) (2) (73) (11) (90) (1) (1) - Net Carrying A mount 5,743 379 124 10 6,256 17 - - - 17 15 - - - 15 Value of c ollaterals 3,514 275 144 14 3,947 17 17 -
Reconciliation of loans by IFRS 9 Stage
The following tables present the movement of the loans measured at amortised cost by IFRS 9 Stage for the years 2025 and 2024:
31.12.2025 Group Retail lending Corporate lendi ng and public secto r Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2025 6,786 2,144 987 907 10,824 27,188 1,107 268 39 28,602 33,974 3,251 1,255 946 39,426 Changes for the year 1.1 - 31.12.2025 Transfers t o Stage 1 from Stage 2 or 3 1,239 (1,205) (34) - 1,122 (1,121) (1) - 2,361 (2,326) (35) - - Transfers t o Stage 2 from Stage 1 or 3 (1,510) 1,686 (176) - (1,610) 1,612 (2) - (3,120) 3,298 (178) - - Transfers t o Stage 3 from Stage 1 or 2 (137) (482) 619 - (8) (22) 30 - (145) (504) 649 - - New loans o riginated or p urchased 1,510 27 1,537 9,861 1 19 9,881 11,371 1 - 46 11,418 Derecogni tion of loans (2) (2) (687) (8) (695) (689) (8) - - (697) Changes due to modificati ons that did not result in derecognition (9) (4) (8) (3) (24) (2) (1) (3) (11) (4) (9) (3) (27) Write-offs (1) (1) (81) (19) (102) (34) (9) (43) (1) (1) (115) (28) (145) Repayments, f oreign excha nge and other movement s (820) (123) (46) (20) (1,009) (5,371) (381) (35) (3) (5,790) (6,191) (504) (81) (23) (6,799) Reclassifi cation of loans (to) / from “Assets he ld for sale” (1) (117) (37) (155) (7) 1 (6) - (1) (124) (36) (161) Balance 31.12.2025 7,056 2,014 1,144 855 11,069 30,493 1,188 218 47 31,946 37,549 3,202 1,362 902 43,015 Allowance f or expected credit losses (21) (121) (309) (110) (561) (10) (14) (66) (18) (108) (31) (135) (375) (128) (669) Balance of loan s 31.12.2025 7,035 1,893 835 745 10,508 30,483 1,174 152 29 31,838 37,518 3,067 987 774 42,346
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
389 | ANNUAL FINANCIAL REPORT
31.12.2024 Group Retail lending Corporate lendi ng and public secto r Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 6,032 3,016 1,457 1,092 11,597 23,632 750 341 84 24,807 29,664 3,766 1,798 1,176 36,404 Changes for the year 1.1 - 31.12.2024 Transfers t o Stage 1 from Stage 2 or 3 1,865 (1,844) (21) - 447 (435) (12) - 2,312 (2,279) (33) - Transfers t o Stage 2 from Stage 1 or 3 (1,203) 1,620 (417) - (727) 750 (23) - (1,930) 2,370 (440) - Transfers t o Stage 3 from Stage 1 or 2 (118) (430) 548 - (23) (47) 70 - (141) (477) 618 - New loans o riginated or p urchased 993 993 8,703 8,703 9,696 9,696 Derecogni tion of loans (6) 20 1 15 (807) (10) (817) (813) (10) 20 1 (802) Changes due to modificati ons that did not result in derecognition (1) 2 (10) (3) (12) 1 (1) (2) (2) 1 (12) (3) (14) Write-offs (2) (97) (29) (128) (21) (10) (31) (2) (118) (39) (159) Repayments, f oreign excha nge and other movement s (765) (172) (57) (6) (1,000) (4,067) (74) (27) (19) (4,187) (4,832) (246) (84) (25) (5,187) Reclassifi cation of loans (to) / from “Assets he ld for sale” (11) (46) (436) (148) (641) 30 174 (58) (16) 130 19 128 (494) (164) (511) Balance 31.12.2024 6,786 2,144 987 907 10,824 27,188 1,107 268 39 28,602 33,974 3,251 1,255 946 39,426 Allowance f or expected credit losses (18) (94) (279) (91) (482) (10) (11) (100) (11) (132) (28) (105) (379) (102) (614) Balance of loan s 31.12.2024 6,768 2,050 708 816 10,342 27,178 1,096 168 28 28,470 33,946 3,146 876 844 38,812 31.12.2025 Bank Retail lending Corporate lendi ng and public secto r Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2025 6,256 2,048 948 877 10,129 26,542 784 251 38 27,615 32,798 2,832 1,199 915 37,744 Changes for the year 1.1 - 31.12.2025 Transfers t o Stage 1 from Stage 2 or 3 1,195 (1,161) (34) - 1,066 (1,065) (1) - 2,261 (2,226) (35) - - Transfers t o Stage 2 from Stage 1 or 3 (1,478) 1,644 (166) - (1,566) 1,568 (2) - (3,044) 3,212 (168) - - Transfers t o Stage 3 from Stage 1 or 2 (137) (475) 612 - (9) (22) 31 - (146) (497) 643 - - New loans o riginated or p urchased 1,117 1,117 8,142 (8) 8,134 9,259 (8) - - 9,251 Derecogni tion of loans (10) (4) (8) (3) (25) (3) (2) (5) (13) (4) (10) (3) (30) Changes due to modificati ons that did not result in derecognition (1) (1) (80) (19) (101) (33) (8) (41) (1) (1) (113) (27) (142) Write-offs (757) (111) (45) (20) (933) (5,103) (228) (28) (2) (5,361) (5,860) (339) (73) (22) (6,294) Repayments, f oreign excha nge and other movement s (23) (23) (87) (87) (110) - - - (110) Reclassifi cation of loans (to) / from “Assets hel d for sale” (2) (150) (38) (190) (21) (3) (24) - (2) (171) (41) (214) Balance 31.12.2025 6,162 1,938 1,077 797 9,974 28,982 1,029 195 25 30,231 35,144 2,967 1,272 822 40,205 Allowance f or expected credit losses (20) (121) (275) (94) (510) (9) (9) (48) (3) (69) (29) (130) (323) (97) (579) Balance of loan s 31.12.2025 6,142 1,817 802 703 9,464 28,973 1,020 147 22 30,162 35,115 2,837 949 725 39,626
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
390 | ANNUAL FINANCIAL REPORT
31.12.2024 Bank Retail lending Corporate lendi ng and public secto r Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 5,554 2,889 1,369 1,059 10,871 23,154 566 328 81 24,129 28,708 3,455 1,697 1,140 35,000 Changes for the year 1.1 - 31.12.2024 Transfers t o Stage 1 from Stage 2 or 3 1,795 (1,775) (20) - 352 (342) (10) - 2,147 (2,117) (30) - Transfers t o Stage 2 from Stage 1 or 3 (1,131) 1,545 (414) - (648) 670 (22) - (1,779) 2,215 (436) - Transfers t o Stage 3 from Stage 1 or 2 (114) (409) 523 - (20) (47) 67 - (134) (456) 590 - New loans o riginated or p urchased 900 900 9,009 9,009 9,909 9,909 Derecogni tion of loans (4) (4) (805) (10) (3) (818) (809) (10) (3) (822) Changes due to modificati ons that did not result in derecognition (1) 2 (9) (3) (11) 1 (1) - 2 (10) (3) (11) Write-offs (2) (97) (28) (127) (15) (10) (25) (2) (112) (38) (152) Repayments, f oreign excha nge and other movement s (742) (156) (35) (5) (938) (4,501) (5 3) (32) (18) (4,604) (5,243) (2 09) (67) (23) (5,542) Reclassifi cation of loans (to) / from “Assets he ld for sale” (1) (46) (369) (146) (562) (64) (12) (76) (1) (46) (433) (158) (638) Balance 31.12.2024 6,256 2,048 948 877 10,1 29 26,542 78 4 251 38 27,615 32,798 2,832 1,199 915 37,744 Allowance f or expected credit losses (17) (92) (267) (90) (466) (11) (4) (89) (12) (116) (28) (96) (356) (102) (582) Balance of loan s 31.12.2024 6,2 39 1,956 681 787 9,663 26,531 7 80 162 26 27,499 32,770 2,736 843 813 37,162
Reconciliation of allowance for expected credit losses of loans by IFRS 9 Stage
The following tables include the movement of allowance for expected credit losses of loans measured at amortized cost for the years 2025 and 2024:
31.12.2025 Allowance for exp ected credit los ses Group Retail lending Corporate lendi ng and public secto r Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2025 18 94 279 91 482 10 11 100 11 132 28 105 379 102 614 Changes for the year 1.1. - 31.12.2025 Transfers t o Stage 1 from Stage 2 or 3 47 (43) (4) - 3 (3) - 50 (46) (4) - - Transfers t o Stage 2 from Stage 1 or 3 (10) 38 (28) - (2) 2 - (12) 40 (28) - - Transfers t o Stage 3 from Stage 1 or 2 (2) (39) 41 - - (2) (39) 41 - - Net remeas urement of expec ted credit loss es(a) (39) 52 43 2 58 (3) 7 6 10 (42) 59 49 2 68 Impairment loss es on new l oans (b) 4 4 5 5 9 - - - 9 Change in risk parameters (c) 3 20 131 45 199 (3) (2) (16) (2) (23) - 18 115 43 176 Impairment losses on loans (a)+(b)+(c) (32) 72 174 47 261 (1) 5 (10) (2) (8) (33) 77 164 45 253 New loans o riginated or p urchased 14 14 7 7 - - - 21 21 Write of fs (1) (80) (19) (100) (34) (8) (42) - (1) (114) (27) (142) Foreign excha nge and other movements 1 1 2 (1) 7 2 8 - (1) 8 3 10 Change in the p resent v alue of the impairment lo sses 3 1 4 1 1 - - 4 1 5 Transfer o f allowance for e xpected credit l osses to "Asset s held for sale (77) (25) (102) 2 8 10 - - (75) (17) (92) Balance 31.12.2025 21 121 309 110 561 10 14 66 18 108 31 135 375 128 669
During 2025, allowance for expected credit losses has been affected by the following movements:
• Transfer to Stage 1 from Stage 2 and Stage 3 of loans with GBV of € 2 bn due to an improvement in their creditworthiness comp ared to their initial recognition. This resulted to a transfer of ECL to Stage
1 of € 50 from Stage 2 and Stage 3.
• In the context of post model adjustments (PMAs) recognized, the ECL allowance as at 31.12.2025 includes an accumulated PMA of € 95 as follow.
o Α PMA of € 47 in order to account for the uncertainty of the current macro-economic environment that have been driven by the inflationary pressures and the increased funding cost of
households and enterprises and the ongoing geopolitical uncertainty.
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
391 | ANNUAL FINANCIAL REPORT
o Α PMA of € 37 has been recognized in order to capture the expected impact from management actions for retail exposures.
o A PMA of € 11 has been recognized following the enactment of the law for the government-induced haircut on CHF mortgage portfolio.
The above are further elaborated in the Post Model Adjustments section.
The undiscounted expected credit losses at initial recognition for new POCI loans amounted to € 16.
It is noted that the loans that were written off within 2025 that are still subject to enforcement activity amount to € 143 (31.12.2024: € 157).
31.12.2024 Allowance for exp ected credit los ses Group Retail lending Corporate lendi ng and public secto r Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 13 130 406 145 694 5 5 133 28 171 18 135 539 173 865 Changes for the year 1.1. - 31.12.2024 Transfers t o Stage 1 from Stage 2 or 3 66 (64) (2) - 3 (3) - 69 (67) (2) - - Transfers t o Stage 2 from Stage 1 or 3 (5) 69 (64) - 11 (11) - (5) 80 (75) - - Transfers t o Stage 3 from Stage 1 or 2 (36) 36 - - - (36) 36 - - Net remeas urement of expec ted credit loss es(a) (56) 4 26 (8) (34) (3) (7) 22 12 (59) (3) 48 (8) (22) Impairment loss es on new l oans (b) 3 3 3 3 6 - - - 6 Change in risk parameters (c) (3) (6) 228 62 281 (1) 3 25 5 32 (4) (3) 253 67 313 Impairment losses on loans (a)+(b)+(c) (56) (2) 254 54 250 (1) (4) 47 5 47 (57) (6) 301 59 297 Write of fs (2) (97) (29) (128) 6 (21) (10) (25) 6 (2) (118) (39) (153) Foreign excha nge and other movements 1 (2) 1 - (3) 4 1 (3) 1 2 1 1 Change in the p resent v alue of the impairment lo sses 3 2 5 2 2 - - 5 2 7 Transfer o f allowance for e xpected credit l osses to "Asset s held for sale (2) (255) (82) (339) 2 (54) (12) (64) - - (309) (94) (403) Balance 31.12.2024 18 94 279 91 482 10 11 100 11 132 28 105 379 102 614
During 2024, allowance for expected credit losses has been affected by the following movements:
• Transfer to Stage 1 of loans amounting € 2 bn from Stage 2 and Stage 3 due to an improvement in their creditworthiness compared to their initial recognition.
• In the context of post model adjustments (PMAs) recognized, the ECL allowance as at 31.12.2025 includes an accumulated PMA of € 103. The PMA was applied to specific retail non-performing
exposures amounting to € 462 for which based on the current circumstances the collection of the outstanding balance (through liquidation or other alternative strategy) is extremely difficult.
Furthermore, based on the Group’s assessment these specific retail non-performing exposures are more vulnerable to the inflationary pressures and are at a non-performing status for a long period,
which makes their collection even more difficult. As result of the above assessment, Management has identified that these specific factors that are interrelated with the characteristics of these retail
non-performing exposures and the profile of the underlying borrowers, cannot be captured by the credit risk models and therefore proceeded with an adjustment in the loss rate applied for this retail
sub-portfolio. In this context the Group has recognised an accumulated PMA as of 31.12.2024 of € 103.
It is noted that the loans that were written off within 2024 that are still subject to enforcement activity amount to € 157 (31.12.2023: € 236).
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
392 | ANNUAL FINANCIAL REPORT
31.12.2025 Allowance for exp ected credit los ses Bank Retail lending Corporate lendi ng and public secto r Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2025 17 92 268 90 467 11 4 89 12 116 28 96 357 102 583 Changes for the year 1.1. - 31.12.2025 Transfers t o Stage 1 from Stage 2 or 3 46 (42) (4) - 3 (3) - 49 (45) (4) - - Transfers t o Stage 2 from Stage 1 or 3 (10) 37 (27) - (3) 3 - (13) 40 (27) - - Transfers t o Stage 3 from Stage 1 or 2 (2) (38) 40 - - (2) (38) 40 - - Net remeas urement of expec ted credit loss es(a) (38) 52 42 2 58 (2) 7 6 11 (40) 59 48 2 69 Impairment loss es on new l oans (b) 4 4 4 4 8 - - - 8 Change in risk parameters (c) 4 21 131 45 201 (4) (2) (19) 1 (24) - 19 112 46 177 Impairment losses on loans (a)+(b)+(c) (30) 73 173 47 263 (2) 5 (13) 1 (9) (32) 78 160 48 254 Derecogni tion of loans - - - - - - - Write of fs (1) (1) (80) (19) (101) (32) (9) (41) (1) (1) (112) (28) (142) Foreign excha nge and other movements - 8 8 - - 8 - 8 Change in the p resent v alue of the impairment lo sses 2 1 3 - - - 2 1 3 Transfer o f allowance for e xpected credit l osses to "Asset s held for sale (97) (25) (122) (4) (1) (5) - - (101) (26) (127) Balance 31.12.2025 20 121 275 94 510 9 9 48 3 69 29 130 323 97 579 31.12.2024 Allowance for exp ected credit los ses Bank Retail lending Corporate lendi ng and public secto r Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 12 126 375 143 656 4 2 127 28 161 16 128 502 171 817 Changes for the year 1.1. - 31.12.2024 Transfers t o Stage 1 from Stage 2 or 3 65 (63) (2) - 2 (1) (1) - 67 (64) (3) - - Transfers t o Stage 2 from Stage 1 or 3 (5) 68 (63) - 11 (11) - (5) 79 (74) - - Transfers t o Stage 3 from Stage 1 or 2 (34) 34 - - - (34) 34 - - Net remeas urement of expec ted credit loss es(a) (56) 4 25 (9) (36) (1) (9) 22 12 (57) (5) 47 (9) (24) Impairment loss es on new l oans (b) 3 3 5 5 8 - - - 8 Change in risk parameters (d) (2) (6) 208 64 264 2 25 2 29 - (6) 233 66 293 Impairment losses on loans (a)+(b)+(c)+(d) (55) (2) 233 55 231 6 (9) 47 2 46 (49) (11) 280 57 277 Derecogni tion of loans - (1) (1) - - - (1) (1) Write of fs (1) (97) (28) (126) 6 (21) (10) (25) 6 (1) (118) (38) (151) Foreign excha nge and other movements - (7) 1 5 (1) (7) 1 5 - (1) Change in the p resent v alue of the impairment lo sses 3 1 4 2 2 - - 5 1 6 Transfer o f allowance for e xpected credit l osses to "Asset s held for sale (2) (215) (81) (298) (59) (7) (66) - (2) (274) (88) (364) Balance 31.12.2024 17 92 268 90 46 7 11 4 89 12 116 28 96 35 7 102 58 3
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
393 | ANNUAL FINANCIAL REPORT
Reconciliation of letters of guarantee, letters of credit and undrawn loan commitments by IFRS 9 Stage
The movement for the years 2025 and 2024 of letters of guarantee, letters of credit and undrawn loan commitments is presented in the tables
that follow:
31.12.2025 Group Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2025 9,748 336 203 3 10,290 Changes for t he year 1.1 - 31.12.2025 Transfers t o Stage 1 from Stage 2 or 3 316 (311) (5) - Transfers t o Stage 2 from Stage 1 or 3 (159) 162 (3) - Transfers t o Stage 3 from Stage 1 or 2 (1) 1 - New lett ers of guarante e, letters of credit a nd undrawn lo an commitments 2,957 1 2 2,960 originate d or purchased Foreign excha nge, repayments an d other movements (1,364) (2) (5) (1,371) Balance 31.12.2025 11,498 185 191 5 11,879 Allowance f or expected credit losses (3) (22) (25) Balance 31.12.2025 11,495 185 169 5 11,854 31.12.2024 Group Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 9,058 247 265 3 9,573 Changes for t he year 1.1 - 31.12.2024 Transfers t o Stage 1 from Stage 2 or 3 148 (140) (8) - Transfers t o Stage 2 from Stage 1 or 3 (254) 261 (7) - Transfers t o Stage 3 from Stage 1 or 2 (1) (1) 2 - New lett ers of guarante e, letters of credit a nd undrawn lo an commitments 2,110 2,110 Foreign excha nge, repayments an d other movements (1,313) (31) (49) (1,393) Balance 31.12.2024 9,748 336 203 3 10,290 Allowance f or expected credit losses (2) (1) (21) (24) Balance 31.12.2024 9,746 335 182 3 10,266 31.12.2025 Bank Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2025 9,791 317 201 3 10,313 Changes for t he year 1.1 - 31.12.2025 Transfers t o Stage 1 from Stage 2 or 3 317 (312) (5) - Transfers t o Stage 2 from Stage 1 or 3 (159) 16 3 (3) - Transfers t o Stage 3 from Stage 1 or 2 (1) 1 - New lett ers of guarante e, letters of credit a nd undrawn lo an commitments 2,776 2,776 Foreign excha nge, repayments an d other movements (1,561) 13 (4) (1,552) Balance 31.12.2025 11,164 180 190 3 11,537 Allowance f or expected credit losses (2) (21) (23) Balance 31.12.2025 11,162 180 169 3 11,514 31.12.2024 Bank Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 9,333 219 265 3 9,820 Changes for t he year 1.1 - 31.12.2024 Transfers t o Stage 1 from Stage 2 or 3 149 (141) (8) - Transfers t o Stage 2 from Stage 1 or 3 (254) 261 (7) - Transfers t o Stage 3 from Stage 1 or 2 (1) (1) 2 - New lett ers of guarante e, letters of credit a nd undrawn lo an commitments 2,099 2,099 Foreign excha nge, repayments an d other movements (1,535) (21) (5 1) (1,607) Balance 31.12.2024 9,791 317 20 1 3 10,313 Allowance f or expected credit losses (2) (21) (23) Balance 31.12.2024 9,789 317 18 0 3 10,290
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
394 | ANNUAL FINANCIAL REPORT
Reconciliation of allowance for expected credit losses of letters of guarantee, letters of credit and undrawn loan commitments by IFRS 9
Stage
The Group has recognized allowance for expected credit losses for the undrawn loan commitments, letters of credit and letters of guarantee,
the reconciliation of which is presented in the following tables for the years 2025 and 2024:
31.12.2025 Group Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2025 3 - 21 - 24 Changes for the year 1.1 - 31.12.2025 Transfers t o Stage 1 from Stage 2 or 3 - Transfers t o Stage 2 from Stage 1 or 3 - Transfers t o Stage 3 from Stage 1 or 2 - Net remeas urement of expec ted credit loss es(a) - Impairment loss es on new expo sures (b) 1 1 Change in risk parameters (c) (1) (1) Impairment losses (a)+(b)+(c) 1 - (1) - New lett ers of guarante e, letters of credit a nd undrawn 1 1 loan commitment s originate d or purchased Foreign excha nge and other movements (2) 2 - Balance 31.12.2025 3 - 22 - 25 31.12.2024 Group Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 1 1 27 - 29 Changes for the year 1.1 - 31.12.2024 Transfers t o Stage 1 from Stage 2 or 3 - Transfers t o Stage 2 from Stage 1 or 3 1 (1) - Transfers t o Stage 3 from Stage 1 or 2 - Net remeas urement of expec ted credit loss es(a) (1) (1) Impairment loss es on new expo sures (b) 2 2 Change in risk parameters (c) 1 (1) (6) (6) Impairment losses (a)+(b)+(c) 3 (2) (6) - (5) Foreign excha nge and other movements (1) 1 - Balance 31.12.2024 3 - 21 - 24 31.12.2025 Bank Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2025 2 22 23 Changes for the year 1.1 - 31.12.2025 Transfers t o Stage 1 from Stage 2 or 3 - Transfers t o Stage 2 from Stage 1 or 3 - Transfers t o Stage 3 from Stage 1 or 2 - Net remeas urement of expec ted credit loss es(a) - Impairment loss es on new expo sures (b) 2 2 Change in risk parameters (c) (2) (2) Impairment losses (a)+(b)+(c) 2 - (2) - - Foreign excha nge and other movements (2) 2 - Balance 31.12.2025 2 - 21 - 23 31.12.2024 Bank Stage 1 Stage 2 Stage 3 POCI Total Balance 1.1.2024 5 - 25 - 30 Changes for the year 1.1 - 31.12.2024 Transfers t o Stage 1 from Stage 2 or 3 - Transfers t o Stage 2 from Stage 1 or 3 1 (1) - Transfers t o Stage 3 from Stage 1 or 2 - Net remeas urement of expec ted credit loss es(a) (1) (1) Impairment loss es on new expo sures (b) 2 2 Change in risk parameters (c) (3) (4) (8) Impairment losses (a)+(b)+(c) (1) (1) (4) - (7) Foreign excha nge and other movements (2) 2 - Balance 31.12.2024 2 - 22 - 23
FINANCIAL STATEMENTS FOR THE GROUP AND THE BANK AS AT 31.12.2025
395 | ANNUAL FINANCIAL REPORT
Advances to customers
Advances to customers derive mainly from Bank’s and Group’s commercial activity other than lending, including mainly receivab les from
letters of guarantee, receivables from credit cards and other receivables from banking activities. The calculation of allowance for expected
credit losses for the receivables that are exposed to credit risk, is being performed using the simplified approach, taking into account their
lifetime (without being allocated into stages), as provided by IFRS 9.
The expected credit loss rate applied by the Group was determined based on the assessment of expected credit losses taking into account the
time that the aforementioned receivables, which are mainly short-term, remain due.
The following tables present the reconciliation of advances to customers for the years 2025 and 2024:
Group Bank 2025 2024 2025 2024 Balance 1.1 329 232 278 175 Repayments, f oreign excha nge and other movement s 105 97 111 103 Balance 31.12 434 329 389 278 Allowance f or expected credit losses (28) (38) (22) (32) Balance of advanc