TBC Bank Group PLC

9.4 At TBC level, regular reporting to the ESG and Ethics Committee on climate-related matters shall be in place. [...] 10.1 Roles and Responsibilities at TBC Level [...] The ESG and Ethics Committee supports the Board in the implementation of the Policy at TBC level. The role of the Committee is formalized to support and advise the Board in its oversight of the implementation of (i) strategy (ii) policies and (iii) programs of the Group Company and its subsidiaries in relation to Environmental, Social and Governance matters and ensuring that the ESG strategy is implemented across all relevant businesses of TBC. Furthermore, the ESG and Ethics Committee supports the Board in promoting its collective vision of values, conduct and culture and overseeing management's efforts (i) to foster a culture of ethics (ii) appropriate conduct, and (iii) Employee ethical engagement within TBC. The ESG and Ethics Committee meets at least four times per year Under the ESG oversight of the ESG and Ethics Committee are: a) periodical review of TBC's ESG strategy, including climate strategy, as well as implementation plans and monitoring of its execution; b) oversee TBC's disclosures on ESG matters, including reporting in line with the TCFD principles, in the Annual Report and Accounts [...] 10.2 Roles and Responsibilities at Banks Level [...] Supervisory Board and Committees of the Banks Supervisory Board and respective committees of the Banks supervise compliance with this Policy by the Management Board of the Banks. The ESG and Ethics Committee assists the Supervisory Board in monitoring and evaluating compliance with this Policy by the Management Board of the Banks. Other committees, as well, may have their responsibilities regarding this policy, according to their terms of reference. [...] ESG Coordination Department / ESG coordinator – a dedicated organizational unit/person within the Banks which/who coordinates the process of the climate action among involved parties, identifies opportunities for improvement and provides knowledge to respective parties. With regards to EMS, the ESG Coordination Department is responsible for technical support in all areas. [...] Environmental and Social Risk Management Team - a full-time unit dedicated to overseeing the Environmental and Social risk management of lending, Green Lending Procedure and Banks' Procedure for addressing External E&S Queries and Concerns. The Environmental and Social risk Management Group is part of SME and Corporate Business Credit Risk Department which reports directly to a member of the Management Board.

**Boards of Directors**\n\nThe Board of Directors of TBC ensures the oversight and implementation of the Policy.\n\n**Committees**\n\nThe ESG and Ethics Committee support the Board of Directors in the implementation of the Policy at the TBC level. The role of the Committee is formalized to support and advise the Board of Directors in its oversight of the implementation of (i) strategy (ii) policies and (iii) programs of the Company and its subsidiaries in relation to Environmental, Social and Governance matters and ensuring that the ESG strategy is implemented across all relevant businesses of the Group. Furthermore, the ESG and Ethics Committee supports the Board of Directors in promoting its collective vision of values, conduct and culture and overseeing management's efforts (i) to foster a culture of ethics (ii) appropriate conduct, and (iii) employee ethical engagement within the Group. The ESG and Ethics Committee meets at least four times per year Under the ESG oversight of the ESG and Ethics Committee are: a) periodical review of the Group's ESG strategy, including climate strategy, as well as implementation plans and monitoring of its execution; b) oversee Group's disclosures on ESG matters, including reporting in line with the TCFD principles, in the Annual Report and Accounts.\n\nThe Committee develops a monitoring system that provides evidence of how much progress has been made in the process of organizational change, identifies spots where reinforced efforts or new priorities are needed, and whether adjustments should be made to the working plan, for example, due to changes in external conditions.\n\n**Supervisory Board and Committees of the TBC Bank**\n\nSupervisory Board and respective committees of the TBC Bank supervise compliance with this Policy by the Management Board of the TBC Bank. In line with the Company's "mirror boards" policy, the role of the Committee at the Supervisory Board is replicated.\n\nThe ESG and Ethics Committee assist the Supervisory Board in monitoring and evaluating compliance with this Policy by the Management Board of the TBC Bank.\n\nThe Committee develops a monitoring system that provides evidence of how much progress has been made in the process of organizational change, identifies spots where reinforced efforts or new priorities are needed, and whether adjustments should be made to the working plan, for example due to changes in external conditions.\n\n**Management Board**\n\nThe Management Board ensures the implementation of the Policy in the bank. It is the responsibility of the Management Board to establish necessary committee(s) or organizational unit(s) and provide required resources.\n\nManagement Board ensures that involved employees are required to spend part of their working time on human rights mainstreaming in company's operations. Where necessary, the job descriptions of employees have to be amended in order to reflect responsibilities related to human rights activities, defined by the Policy.\n\n**The management level committees**\n\nThe ESG Committee at the executive management level supports the Management Board in the implementation of the Policy. The committees are led by a chairperson represented by a senior level management staff and comprises of members - mid-level management staff who are responsible for implementing the Policy in the areas of their responsibilities.\n\nThe ESG Committee develops a monitoring system that provides evidence of how much progress has been made in the process of organizational change, identifies spots where reinforced efforts or new priorities are needed, and whether adjustments should be made to the working plan, for example due to changes in external conditions.\n\nESG Coordination Department / ESG coordinator – a dedicated organizational unit/person within the TBC Bank which/who coordinates the process of the climate action among involved parties, identifies opportunities for improvement and provides knowledge to respective parties.\n\nEnvironmental and Social Risk Management Team - a full-time unit, dedicated to overseeing the implementation and operation of Environmental Management System. The Environmental and Social Risk Management Team is part of SME and Corporate Business Credit Risk Division.\n\nESG Competences Center – The Task Force on ESG matters, consisting of representatives from different functions of TBC Bank.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Sustainable development policies and management structures are represented in various policy documents and management domains. TBC has developed several thematic policies and codes that regulate various social and environmental protection issues related to company activity. They include: the Code of Ethics, the Incident Management Policy, the Anti-Corruption Policy, the Personal Data Protection Policy, the Conflict of Interests Management Policy, the Green Purchase Recommendations etc. In January 2022, the Group established an Environmental, Social and Governance ("ESG") and Ethics Committee at the Board level, as well as at the Supervisory Board level of the Company's main subsidiary, JSC TBC Bank, in line with the Company's "mirror boards" policy. This reflects the importance of sustainability in TBC's corporate governance. The role of the Committee is formalized to support and advise the Board of Directors in its oversight of the implementation of (i) strategy (ii) policies and (iii) programs of the Company and its subsidiaries in relation to Environmental, Social and Governance matters and ensuring that the ESG strategy is implemented across all relevant businesses of the Group.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes