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National Bank of Greece S.A.

Annual / Quarterly Financial Statement Mar 2, 2023

2642_10-k_2023-03-02_f81017c6-eeec-4681-86d9-09af323067ce.pdf

Annual / Quarterly Financial Statement

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Certified Public Accountants: Kostas Stathopoulos (Reg. No. SOEL 42201) Andreas Hadjidamianou (Reg. No. SOEL 61391) Auditing Company: ERNST & YOUNG (HELLAS) Certified Auditors-Accountants S.A. Type of Auditor's Report: Unmodified opinion Date of auditors report issue: 2 March 2023

Website: www.bankofgreece.gr

A S S E T S 31.12.2022 31.12.2021 L I A B I L I T I E S 31.12.2022 31.12.2021
1. Gold and gold receivables 8,315,986,789 7,828,166,312 1. Banknotes in circulation 35,771,610,915 35,142,503,430
2. Claims on non-euro area residents denominated in foreign currency 5,173,082,228 6,868,711,471 2. Liabilities to euro area credit institutions related to
Receivables from the International Monetary Fund (IMF) 1,728,659,968 3,597,379,314 monetary policy operations denominated in euro 43,694,914,508 49,119,566,410
Balances with banks and security investments,
external loans and other external assets
3,444,422,260 3,271,332,157 2.1
Current accounts (covering the minimum reserve system)
2.2
Deposit facility
2.3
Fixed-term deposits
2,507,194,960
41,187,719,548
0
49,119,566,410
0
0
3. Claims on euro area residents denominated in foreign currency 482,908,368 425,143,903 2.4
Fine-tuning reverse operations
2.5
Deposits related to margin calls
0
0
0
0
General government 23,944,221 22,735,845
Other claims 458,964,147 402,408,058 3. Other liabilities to euro area credit institutions
denominated in euro
0 8,992,726
4. Claims on non-euro area residents denominated in euro 22,784 22,856 4. Liabilities to other euro area residents denominated in euro 25,057,106,363 27,235,028,591
Balances with banks, security investments and loans 22,784 22,856
Claims arising from the credit facility under ERM II 0 0 4.1
General government
23,800,806,836 26,139,126,808
4.2
Other liabilities
1,256,299,527 1,095,901,783
monetary policy operations denominated in euro 35,423,400,000 50,843,400,000 5. Liabilities to non-euro area residents denominated in euro 3,076,522,869 2,452,690,164
Main refinancing operations 0 0 6. Liabilities to euro area residents denominated in foreign currency 1,756,096,807 3,626,240,543
Longer-term refinancing operations 35,423,400,000 50,843,400,000
Fine-tuning reverse operations 0 0 7. Liabilities to non-euro area residents denominated in foreign currency 2,715 2,557
Structural reverse operations 0 0
Marginal lending facility 0 0 7.1
Deposits and other liabilities
2,715 2,557
Credits related to margin calls 0 0 7.2
Liabilities arising from the credit facility under ERM II
0 0
6. Other claims on euro area credit institutions denominated in euro 1,486,496 1,936,171
8. Intra-Eurosystem liabilities 112,440,835,732 104,172,293,204
7. Securities of euro area residents denominated in euro 160,420,762,541 147,957,532,914
8.1
Liabilities related to promissory notes backing
Securities held for monetary policy purposes 148,154,939,009 137,826,696,663 the issuance of ECB debt certificates 0 0
Other securities of euro area residents denominated in euro 12,265,823,532 10,130,836,251 8.2
Net liabilities related to the allocation of euro
banknotes within the Eurosystem 0 0
8. General government long-term debt denominated in euro 3,478,819,849 3,922,306,370 8.3
Net liabilities arising from balances of TARGET2 accounts
8.4
Other liabilities within the Eurosystem (net)
112,440,835,732
0
104,172,293,204
0
9. Intra-Eurosystem claims 22,287,438,863 17,131,009,436
9. Items in course of settlement 13,199,947 869,572
Participating interest in the ECB 503,561,541 488,470,721
Claims equivalent to the transfer of foreign 10. Other liabilities 1,392,845,189 1,303,171,891
reserves to the ECB 997,925,769 997,925,769
Net claims related to the allocation of euro banknotes 10.1 Off-balance-sheet instruments revaluation differences 163,611 0
within the Eurosystem 20,073,139,395 15,389,256,095 10.2 Accruals and income collected in advance 856,846,888 633,120,410
Net claims arising from balances of TARGET2 accounts 0 0 10.3 Sundry 535,834,690 670,051,481
Other claims within the Eurosystem (net) 712,812,158 255,356,851
11. Provisions 4,465,767,289 4,838,094,545
10. Items in course of settlement 0 0
12. Revaluation accounts 7,336,388,673 6,310,667,444
11. Other assets 2,880,765,658 2,648,570,653
13. Capital and reserves 3,459,382,569 3,416,679,009
11.1 Coins of euro area 46,813,436 53,453,963
11.2 Tangible and intangible fixed assets 570,170,655 577,335,736 13.1 Capital 111,243,362 111,243,362
11.3 Other financial assets 115,818,250 111,672,679 13.2 Ordinary reserve 111,243,362 111,243,362
11.4 Off-balance-sheet instruments revaluation differences 45,202 21,820 13.3 Extraordinary reserve 490,531,600 447,831,600
11.5 Accruals and prepaid expenses 1,595,246,747 1,339,054,674 13.4 Special reserve for financial risks 2,744,771,262 2,744,771,262
11.6 Sundry 552,671,368 567,031,781 13.5 Other special reserves 1,592,983 1,589,423
T O T A L A S S E T S 238,464,673,576 237,626,800,086 T O T A L L I A B I L I T I E S 238,464,673,576 237,626,800,086
A S S E T S 31.12.2022 31.12.2021 L I A B I L I T I E S
31.12.2022
31.12.2021
1. Gold and gold receivables 8,315,986,789 7,828,166,312 1. Banknotes in circulation
35,771,610,915
35,142,503,430
2. Claims on non-euro area residents denominated in foreign currency 5,173,082,228 6,868,711,471 2. Liabilities to euro area credit institutions related to
monetary policy operations denominated in euro
43,694,914,508
49,119,566,410
2.1
Receivables from the International Monetary Fund (IMF)
1,728,659,968 3,597,379,314
2.2
Balances with banks and security investments,
2.1
Current accounts (covering the minimum reserve system)
2,507,194,960
49,119,566,410
external loans and other external assets 3,444,422,260 3,271,332,157 2.2
Deposit facility
41,187,719,548
0
2.3
Fixed-term deposits
0
0
3. Claims on euro area residents denominated in foreign currency 482,908,368 425,143,903 2.4
Fine-tuning reverse operations
0
0
3.1
General government
23,944,221 22,735,845 2.5
Deposits related to margin calls
0
0
3.2
Other claims
458,964,147 402,408,058 3. Other liabilities to euro area credit institutions
denominated in euro
0
8,992,726
4. Claims on non-euro area residents denominated in euro 22,784 22,856
4. Liabilities to other euro area residents denominated in euro
25,057,106,363
27,235,028,591
4.1
Balances with banks, security investments and loans
22,784 22,856
4.2
Claims arising from the credit facility under ERM II
0 0 4.1
General government
23,800,806,836
26,139,126,808
4.2
Other liabilities
1,256,299,527
1,095,901,783
5. Lending to euro area credit institutions related to
monetary policy operations denominated in euro 35,423,400,000 50,843,400,000 5. Liabilities to non-euro area residents denominated in euro
3,076,522,869
2,452,690,164
5.1
Main refinancing operations
0 0 6. Liabilities to euro area residents denominated in foreign currency
1,756,096,807
3,626,240,543
5.2
Longer-term refinancing operations
35,423,400,000 50,843,400,000
5.3
Fine-tuning reverse operations
0 0 7. Liabilities to non-euro area residents denominated in foreign currency
2,715
2,557
5.4
Structural reverse operations
0 0
5.5
Marginal lending facility
0 0 7.1
Deposits and other liabilities
2,715
2,557
5.6
Credits related to margin calls
0 0 7.2
Liabilities arising from the credit facility under ERM II
0
0
6. Other claims on euro area credit institutions denominated in euro 1,486,496 1,936,171
8. Intra-Eurosystem liabilities
112,440,835,732
104,172,293,204
7. Securities of euro area residents denominated in euro 160,420,762,541 147,957,532,914
8.1
Liabilities related to promissory notes backing
7.1
Securities held for monetary policy purposes
7.2
Other securities of euro area residents denominated in euro
148,154,939,009
12,265,823,532
137,826,696,663
10,130,836,251
the issuance of ECB debt certificates
0
8.2
Net liabilities related to the allocation of euro
0
banknotes within the Eurosystem
0
0
8. General government long-term debt denominated in euro 3,478,819,849 3,922,306,370 8.3
Net liabilities arising from balances of TARGET2 accounts
112,440,835,732
104,172,293,204
8.4
Other liabilities within the Eurosystem (net)
0
0
9. Intra-Eurosystem claims 22,287,438,863 17,131,009,436
9. Items in course of settlement
13,199,947
869,572
9.1
Participating interest in the ECB
503,561,541 488,470,721
9.2
Claims equivalent to the transfer of foreign
10. Other liabilities
1,392,845,189
1,303,171,891
reserves to the ECB 997,925,769 997,925,769
9.3
Net claims related to the allocation of euro banknotes
10.1 Off-balance-sheet instruments revaluation differences
163,611
0
within the Eurosystem 20,073,139,395 15,389,256,095 10.2 Accruals and income collected in advance
856,846,888
633,120,410
9.4
Net claims arising from balances of TARGET2 accounts
9.5
Other claims within the Eurosystem (net)
0
712,812,158
0
255,356,851
10.3 Sundry
535,834,690
670,051,481
11. Provisions
4,465,767,289
4,838,094,545
10. Items in course of settlement 0 0
12. Revaluation accounts
7,336,388,673
6,310,667,444
11. Other assets 2,880,765,658 2,648,570,653
13. Capital and reserves
3,459,382,569
3,416,679,009
11.1 Coins of euro area 46,813,436 53,453,963
11.2 Tangible and intangible fixed assets 570,170,655 577,335,736 13.1 Capital
111,243,362
111,243,362
11.3 Other financial assets 115,818,250 111,672,679 13.2 Ordinary reserve
111,243,362
111,243,362
11.4 Off-balance-sheet instruments revaluation differences
11.5 Accruals and prepaid expenses
45,202
1,595,246,747
21,820
1,339,054,674
13.3 Extraordinary reserve
490,531,600
13.4 Special reserve for financial risks
2,744,771,262
447,831,600
2,744,771,262
11.6 Sundry 552,671,368 567,031,781 13.5 Other special reserves
1,592,983
1,589,423
T O T A L A S S E T S 238,464,673,576 237,626,800,086 T O T A L L I A B I L I T I E S
238,464,673,576
237,626,800,086
OFF-BALANCE-SHEET ITEMS 31.12.2022 31.12.2021 NOTES:
1. Greek government securities relating to the management of the "Common capital
of legal entities in public law and social security funds" according to Law 2469/97 62,827,172,348 53,003,474,348 1. Under Article 54A of the Bank's Statute, the financial statements of the Bank of Greece are drawn up in accordance with the accounting principles and methods applying from time to time to the European System of Central Banks (ESCB),
as established by the European Central Bank (ECB) by Guideline (ΕU) 2016/2249 of 3.11.2016 (ECB/2016/34) and its subsequent amendments. These principles are based on generally accepted accounting principles (GAAP), tailored
2. Greek government securities and other debt securities relating to the management to best suit the needs and reflect the special status of the national central banks (NCBs) of the Eurosystem. It should also be noted that the Bank's liabilities in respect of post-employment benefits are accounted for in accordance with
and custody of assets of public entities, social security funds and private agents 5,886,169,738 5,059,466,870 Decision (EU) 2016/2247 of the European Central Bank of 3.11.2016 on the annual accounts of the European Central Bank (ECB/2016/35) as amended. Any issues that are not covered by the aforementioned principles and ECB
3. Assets eligible as collateral for Eurosystem monetary policy operations and intraday credit 50,863,532,362 60,727,960,751 guidelines or are governed by non-mandatory provisions are to be treated either in accordance with the ECB recommendations or in accordance with the Bank's Statute, Law 4548/2018 "Reform of the law on sociétés anonymes" and
4. Other off-balance-sheet items 12,610,228,014 12,339,508,154 Law 4308/2014 "Greek Accounting Standards, relevant arrangements, and other provisions", to the extent that they do not contravene the provisions of the Statute.
2. Gold has been valued at the price provided by the ECB as at 30.12.2022: €1,706.075 per fine ounce, compared with €1,609.483 as at 31.12.2021.
TOTAL OFF-BALANCE-SHEET ITEMS 132,187,102,462 131,130,410,123 3. Claims/liabilities denominated in foreign currency have been converted to euro, using the euro foreign exchange reference rates of the ECB as at 30.12.2022.
  1. Debt securities (other than those held-to-maturity, non-marketable securities and securities held for monetary policy purposes) have been valued at the mid-market prices of 30.12.2022. Marketable debt securities classified as

held-to-maturity, non-marketable securities and securities held for monetary policy purposes are valued at amortised cost and are subject to impairment.

  1. The Bank's provisions include provisions against financial and operational risks, provisions for staff insurance benefits, as well as special provisions. The latter include a litigation provision against potential liabilities in respect of pending lawsuits initiated by third parties against the Bank.

  2. Revaluation accounts include unrealised revaluation gains on gold, foreign currency instruments and securities, as well as the remeasurement results of the net defined benefit obligations of the Bank in respect of post-employment benefits, which reflect actuarial gains/losses.

  3. Other off-balance-sheet items include the liability of the Hellenic Republic to the IMF from the SDR allocations, of a total amount of SDR 3.1 billion, equivalent to €3.9 billion as at 31.12.2022.

  4. Certain items of the profit and loss account for the year 2021 have been reclassified to be comparable with the respective items of the year 2022.

PROFIT AND LOSS ACCOUNT FOR THE YEAR 2022

Profit for the year 456,775,424 3,270,530,651
2022 2021 (Article 71 of the Statute)
(in euro)
1. Net interest income 2,290,875 435,917,185
1.1
Interest income
1,106,018,380 883,886,131 2022
2021
1.2
Interest expense
-1,103,727,505 -447,968,946 (in euro)
2. Net result of financial operations, write-downs Profit for the year
Dividend to be distributed for the year 2022 (€ 0.6720 per share for 19,864,886 shares)
456,775,424
3,270,530,651
-13,349,203
-13,349,203
and risk provisions 76,385,714 172,464,662 Extraordinary reserve -42,700,000
-13,331,600
2.1
Realised gains arising from financial operations
76,385,714 172,464,662 Special reserve for financial risks 0
-2,744,771,262
2.2
Write-downs on financial assets and positions
-54,242,254 -7,228,738 Amount to be transferred to the Government -400,726,221
-499,078,586
2.3
Transfer from provisions for financial risks
54,242,254 7,228,738 0
0
3. Net income from fees and commissions 130,353,332 128,221,252
3.1
Fees and commissions income
139,799,392 135,802,303 * The profit distribution is subject to approval by the General Meeting of Shareholders.
3.2
Fees and commissions expense
-9,446,060 -7,581,051
4. Income from equity shares and participating interests 3,993,279 10,837,011
5. Net result of pooling of monetary income 706,062,158 247,506,533
6. Other income 19,670,908 16,096,575 Athens, 2 March 2023
Total net income 938,756,266 1,011,043,218 FINANCIAL DEPARTMENT
7. Staff costs and pension benefit expenses -272,373,563 -290,474,304 THE DIRECTOR THE ACCOUNTANT
8. Other administrative expenses -65,797,826 -62,261,079 THE GOVERNOR
9. Depreciation of tangible and intangible fixed assets -11,158,851 -8,670,784
Total expenses before provisions -349,330,240 -361,406,167
Profit before provisions 589,426,026 649,637,051 YANNIS STOURNARAS YANNIS ASIMAKOPOULOS THEOCHARIS NTOVAS
License No Class A 0137991
10. Provisions -132,650,602 2,620,893,600
NET PROFIT FOR THE YEAR 456,775,424 3,270,530,651

(Article 71 of the Statute) STATEMENT OF PROFIT DISTRIBUTION (*)

B A N K O F G R E E C E E U R O S Y S T E M

Ν Ι Ν Ε Τ Y F I F T H Y E A R (in euro)

B A L A N C E S H E E T A S A T 31 D E C E M B E R 2 0 2 2

YANNIS STOURNARAS YANNIS ASIMAKOPOULOS THEOCHARIS NTOVAS
License No Class A 0137991

THIS REPORT HAS BEEN TRANSLATED FROM THE ORIGINAL VERSION IN GREEK

INDEPENDENT AUDITOR'S REPORT

To the Shareholders of the Bank of Greece

Report on the Audit of the Financial Statements

Opinion

We have audited the accompanying financial statements of the Bank of Greece (the Bank), which comprise the balance sheet as at 31 December 2022, the profit and loss account and the statement of profit distribution for the year then ended, and notes to the financial statements, including a summary of significant accounting policies and other explanatory notes.

In our opinion, the accompanying financial statements present fairly, in all material respects, the financial position of the Bank as at 31 December 2022 and its financial performance for the year then ended in accordance with the accounting principles and methods established by the European Central Bank (ECB), under the "Guideline (EU) 2016/2249 of 3.11.2016 (ECB/2016/34)" as amended and currently in force, as adopted by the Bank in Article 54A of its Statute. Formattersthat may not be covered by the aforementioned ECB rules or whose application is not mandatory but recommended, either the ECB recommendations or the provisions of the Bank's Articles of Association in conjunction with Law 4548/2018 "Sociétés anonymes Law reform" and Law 4308/2014 "Greek Accounting Standards, relevant arrangements and other provisions" shall be followed, as appropriate, to the extent that they do not contradict with the provisions of the Articles of Association.

Basis for Opinion

We conducted our audit in accordance with International Standards on Auditing (ISAs) as these have been incorporated into Greek legislation. Our responsibilities under those standards are further described in the "Auditor's Responsibilities for the Audit of the Financial Statements" section of our report. We have been independent of the Bank during the whole period of our appointment in accordance with the International Ethics Standards Board for Accountants' Code of Ethics for Professional Accountants (IESBA Code) as incorporated into Greek legislation and the ethical requirements in Greece relevant to the audit of the financial statements and we have fulfilled our ethical requirements in accordance with the applicable legislation and the above-mentioned 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 Matter

A key audit matter is this matter that, in our professional judgement, was of most significance in our audit of the financial statements of the current period. Thismatter and the relevant risks of material misstatement was addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on this matter.

In this context, we describe below how our audit addressed the issue below.

We have fulfilled the responsibilities described in the "Auditor's Responsibilities for the Audit of the Financial Statements" section of our report, including those related to the key audit matter. Accordingly, our audit included performing procedures designed to address the risks of material misstatement of the financial statements. The results of our auditing procedures, including the procedures performed on the matter below, provide a basis for our opinion on the accompanying financial statements.

Key audit matter How our audit addressed the key audit matter
Provision against financial risks
The Bank recognises, measures and monitors the financial risks Based on the audit risk assessment and following a risk-based
arising from its assets such as euro-denominated securities issued approach ,we assessed the financial risks measurement process.
by euro area residents and euro-denominated loans not related to Our audit procedures include, among others, the following:
monetary policy operations.
1.
Understanding of the process of the financial risks and
In addition, financial risks include risks arising from the exercise of methodology used by the Bank to recognise, measure
the monetary policy of the Eurosystem which are measured by the and monitor the accounting estimates of provisions and
European Central Bank.

Following a decision of the Bank's Risk Management Committee, which took into account the measurement of financial risks based on the VaR (Value at Risk) method, a provision for financial risks has been established, which amounted to EUR 1,622 million as at 31 December 2022.

The measurement process for financial risks (including credit risk and market risk) is complex, involves methodological assumptions and has a significant impact on the Bank's results. We therefore considered it to be a key audit matter.

The Bank's management has provided information on the provision against financial risks in the section IV. Note 11 "Provisions", paragraph "c. Provisions against Financial and Operational Risks" of the financial statements.

verify the approvals of the amount of the provision by the relevant level of authority within the Bank of Greece.

    1. Assessment of the design and implementation of the internal controls related to the measurement of financial risks (credit risk and market risk).
    1. With the participation of EY specialists, we reviewed the methodology and the relevant assumptions used by the Bank for the measurement of provisions and performed independent recalculations on a sample basis.
    1. Examination of the accuracy and completeness of the Bank's assets used to measure the provisions.
    1. Assessment of the completeness and the accuracy of the disclosures in the financial statements related to this key audit matter.

Other matter

The financial statements of the Bank for the prior financial year ended 31 December 2021 were audited by other Chartered Accountants, who issued an audit report with an unqualified opinion on 1 March 2022.

Other information

Management is responsible for the other information. The other information is included in the General Council's Report, referred to in the "Report on Other Legal and Regulatory Requirements".

Our opinion on the 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 financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated.

If, based on the work we have performed on the other information that we obtained prior to the date of this auditor's report, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard.

Responsibilities of the Management and Those Charged with Governance for the Financial Statements

Management is responsible for the preparation and fair presentation of the financial statements in accordance with the accounting principles and methods established by the European Central Bank (ECB), under the "Guideline (EU) 2016/2249 of 3.11.2016 (ECB/2016/34)" as amended and currently in force, as adopted by the Bank in Article 54A of its Statute.

For matters that may not be covered by the aforementioned ECB rules or whose application is not mandatory but recommended, either the ECB recommendations or the provisions of the Bank's Articles of Association in conjunction with Law 4548/2018 " Sociétés anonymes Law reform " and Law 4308/2014 "Greek Accounting Standards, relevant arrangements, and other provisions" shall be followed, as appropriate, to the extent that they do not contradict with the provisions of the Articles of Association, where these have been implemented by the Bank, and for such internal controls as Management determines are necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, Management is responsible for assessing the Bank's ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting.

The Audit Committee (article 44 of Law 4449/2017) of the Bank is responsible for overseeing the Bank's financial reporting process.

Auditor's Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the 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 it 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 aggregate, they could reasonably be expected to influence the economic decisions of users made on the basis of these 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 risks of material misstatement of the 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 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 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 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 to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements present fairly the underlying transactions and events.

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 we communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards.

From the matters communicated with those charged with governance, we determine those of most significance in the audit of the financial statements for the current period and are, therefore, the key audit matters.

Report on Other Legal and Regulatory Requirements

1. General Council's Report

Taking into consideration that Management is responsible for the preparation of the General Council's Report for the financial year 2022, which also includes the Corporate Governance Statement, according to the provisions of paragraph 5 of article 2 of Law 4336/2015 (part B), we note the following:

a) The General Council's Report includes the Corporate Governance Statement, which provides the

information required by article 152 of Law 4548/2018.

b) In our opinion, the General Council's Report for the financial year 2022 has been prepared in

accordance with the applicable legal requirements of articles 150-151 and

paragraph 1 (subparagraphs c' and d') of article 152 of Law 4548/2018 and its content is consistent

with the accompanying financial statements for the year ended 31 December 2022.

c) Based on the knowledge we obtained during our audit of the Bank of Greece and its environment, we have not identified any material inconsistencies in the General Council's Report.

2. Additional Report to the Audit Committee

Our audit opinion on the accompanying financial statements is consistent with the additional report to the Bank's Audit Committee referred to in Article 11 of European Union (EU) Regulation 537/2014.

3. Non-audit Services

We have not provided to the Bank any prohibited non-audit services referred to in Article 5 of European Union (EU) Regulation 537/2014.

4. Appointment

We were appointed statutory auditors for the first time by the General Assembly of the Bank of Greece on 07 April 2022.

2 March 2023

The Certified Auditor Accountant Kostas Stathopoulos SOEL R.N. 42201 Ernst & Young (Hellas) Certified Auditors Accountants S.A. 8B Chimarras St., Maroussi 151 25, Greece Company SOEL R.N. 107

The Certified Auditor Accountant Andreas Hadjidamianou SOEL R.N. 61391 Ernst & Young (Hellas) Certified Auditors Accountants S.A. 8B Chimarras St., Maroussi 151 25, Greece Company SOEL R.N. 107

The present constitutes an informal translation in English of the original Report prepared by ERNST & YOUNG (HELLAS) Certified Auditors-Accountants SA ("EY") in Greek language.

This translation is provided for information purposes only and should not be relied upon or used for any other purpose unless EY has provided its relevant consent in writing. Under no circumstances will EY and the other companies of the EY Network in Greece and abroad, their partners or employees, be liable against the Client or any third party, for any decision or action taken on the basis of this translation or for any direct or consequential damages suffered by any third party deriving from the use of the translation or its contents.

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