National Bank of Greece SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	National Bank of Greece SA has put in place a sustainability governance structure, noting that "a dedicated Group CSR & Sustainability Division has been established ... under the Group Chief Compliance and Corporate Governance Officer, which is competent for csr, as well as sustainability and climate change related issues, activities and projects of the Bank," with that officer reporting directly to "the Board’s Compliance, Ethics and Culture Committee" which oversees CSR, environmental and climate-change policies. The bank emphasizes that "the Board should focus on sustainability and considers among others climate-related and environmental risks when developing the overall business strategy, objectives and risk management framework and exercises effective oversight of climate-related and environmental risks," and that it integrates "material environmental and social considerations ... into the Bank’s strategy, business model and risk management system." It also highlights its "Environmental Management System which is in conformity with ISO 14001" and confirms a "public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement." However, the disclosures do not describe any specific processes or oversight mechanisms for lobbying, including how it monitors, reviews or aligns its direct policy advocacy or its involvement with trade associations to ensure consistency with its climate objectives. View Sources	D

Overall Assessment

Analysis

Score

Limited

National Bank of Greece SA has put in place a sustainability governance structure, noting that "a dedicated Group CSR & Sustainability Division has been established ... under the Group Chief Compliance and Corporate Governance Officer, which is competent for csr, as well as sustainability and climate change related issues, activities and projects of the Bank," with that officer reporting directly to "the Board’s Compliance, Ethics and Culture Committee" which oversees CSR, environmental and climate-change policies. The bank emphasizes that "the Board should focus on sustainability and considers among others climate-related and environmental risks when developing the overall business strategy, objectives and risk management framework and exercises effective oversight of climate-related and environmental risks," and that it integrates "material environmental and social considerations ... into the Bank’s strategy, business model and risk management system." It also highlights its "Environmental Management System which is in conformity with ISO 14001" and confirms a "public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement." However, the disclosures do not describe any specific processes or oversight mechanisms for lobbying, including how it monitors, reviews or aligns its direct policy advocacy or its involvement with trade associations to ensure consistency with its climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	National Bank of Greece provides a fair level of transparency on the climate-policy issues it engages with. It identifies several concrete measures it has lobbied on, including the consultation draft of the National Climate Law on “Transition to climate neutrality and adaptation to climate change,” the Ministry of Environment and Energy’s “Circular Economy” legislative package, and the ECB Climate Risk Stress Test, demonstrating clarity about the specific policies under discussion. The bank also outlines how it seeks to influence these measures, noting direct participation in public consultations run by the Ministry of Environment and Energy and indirect engagement through its membership of the Hellenic Bank Association and involvement in an interbank committee, thereby revealing both the mechanisms and the institutional targets of its lobbying. However, beyond stating that it offers “support with no exceptions” for the policies consulted upon and that it wishes to advance climate-risk management practices, the bank does not articulate concrete legislative changes, amendments, or quantitative targets it is pursuing. The absence of detailed, measurable outcomes limits the overall depth of its disclosure, but the company still provides moderate insight into the scope and channels of its climate-related lobbying.	C