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National Bank of Greece S.A.

Annual / Quarterly Financial Statement Jan 22, 2018

2642_10-k_2018-01-22_de021658-8a69-458e-8869-a682202cc1f7.pdf

Annual / Quarterly Financial Statement

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Michalis Karavas (Reg. No. SOEL 13371)

Despina Xenaki (Reg. No. SOEL 14161)
Michalis Karavas (Reg. No. SOEL 13371)
Deloitte Certified Public Accountants S.A.
Unmodified opinion
22 January 2018
www.bankofgreece.gr
A S S E T S 31.12.2017 31.12.2016 L I A B I L I T I E S 31.12.2017 31.12.2016
1. Gold and gold receivables 5,190,832,297 5,261,753,291 1. Banknotes in circulation 31,111,777,700 29,929,190,200
2. Claims on non-euro area residents denominated in foreign currency 2,597,159,265 2,578,715,907 2. Liabilities to euro area credit institutions related to
monetary policy operations denominated in euro
1,959,800,623 907,409,514
2.1
Receivables from the International Monetary Fund (IMF)
685,692,703 737,322,397
2.2
Balances with banks and security investments,
external loans and other external assets
1,911,466,562 1,841,393,510 2.1 Current accounts (covering the minimum reserve system)
2.2 Deposit facility
2.3
Fixed-term deposits
1,959,800,623
0
0
876,909,514
0
0
3. Claims on euro area residents denominated in foreign currency 271,455,735 204,874,084 2.4
Fine-tuning reverse operations
2.5
Deposits related to margin calls
0
0
0
30,500,000
3.1
General government
15,920,425 16,419,464
3.2
Other claims
255,535,310 188,454,620 3. Other liabilities to euro area credit institutions
denominated in euro
0 0
4. Claims on non-euro area residents denominated in euro 23,489 23,659
4.1
Balances with banks, security investments and loans
23,489 23,659 4. Liabilities to other euro area residents denominated in euro 12,397,028,127 9,527,107,565
4.2
Claims arising from the credit facility under ERM II
0 0 4.1 General government 11,090,282,518 8,269,754,053
5. Lending to euro area credit institutions related to 4.2 Other liabilities 1,306,745,609 1,257,353,512
monetary policy operations denominated in euro 12,059,000,000 22,953,000,000 5. Liabilities to non-euro area residents denominated in euro 2,423,950,875 2,461,327,349
5.1
Main refinancing operations
5.2
Longer-term refinancing operations
680,000,000
11,100,000,000
15,430,000,000
7,500,000,000
6. Liabilities to euro area residents denominated in foreign currency 711,599,699 751,912,348
5.3
Fine-tuning reverse operations
0 0 7. Liabilities to non-euro area residents denominated in foreign currency 2,415 2,754
5.4
Structural reverse operations
5.5
Marginal lending facility
0
279,000,000
0
23,000,000
7.1 Deposits and other liabilities 2,415 2,754
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 21,614,898,570 43,665,037,526 8. Counterpart of special drawing rights allocated by the IMF 0 0
7. Securities of euro area residents denominated in euro 73,944,793,921 57,197,297,804 9. Intra-Eurosystem liabilities 64,160,258,188 85,571,386,262
7.1
Securities held for monetary policy purposes
60,624,764,994 42,484,409,198 9.1 Liabilities related to promissory notes backing
7.2
Other securities of euro area residents denominated in euro
13,320,028,927 14,712,888,606 the issuance of ECB debt certificates 0 0
8. General government long-term debt denominated in euro 5,717,976,316 6,353,182,528 9.2 Net liabilities related to the allocation of euro
banknotes within the Eurosystem
4,758,609,980 13,314,137,100
9.3 Net liabilities arising from balances of TARGET2 accounts 59,401,648,208 72,257,249,162
9. Intra-Eurosystem claims 1,914,063,363 1,854,318,415 9.4 Other liabilities within the Eurosystem (net) 0 0
9.1
Participating interest in the ECB
9.2
Claims equivalent to the transfer of foreign
564,765,496 564,765,496 10. Items in course of settlement 913,852 1,004,753
reserves to the ECB 1,178,260,606 1,178,260,606 11. Other liabilities 1,068,668,202 1,226,620,075
9.3
Net claims related to the allocation of euro banknotes
within the Eurosystem
0 0 11.1 Off-balance-sheet instruments revaluation differences 544 21,829
9.4
Net claims arising from balances of TARGET2 accounts
0 0 11.2 Accruals and income collected in advance 71,722,619 26,548,519
9.5
Other claims within the Eurosystem (net)
171,037,261 111,292,313 11.3 Sundry 996,945,039 1,200,049,727
10. Items in course of settlement 85,254 0 12. Provisions 7,600,331,097 7,477,308,544
11. Other assets 2,130,224,128 2,316,135,103 13. Revaluation accounts 3,412,541,786 3,715,573,000
11.1 Coins of euro area 63,463,487 59,834,993 14. Capital and reserves 593,639,774 815,495,953
11.2 Tangible and intangible fixed assets 564,103,667 792,236,542
11.3 Other financial assets
11.4 Off-balance-sheet instruments revaluation differences
97,185,041
102,453
95,176,220
45,122
14.1 Capital
14.2 Ordinary reserve
111,243,362
111,243,362
111,243,362
111,243,362
11.5 Accruals and prepaid expenses 817,745,677 779,083,565 14.3 Extraordinary reserve 84,500,000 84,500,000
11.6 Sundry 587,623,803 589,758,661 14.4 Special reserve from the revaluation of land
and buildings
14.5 Other special reserves
285,443,789
1,209,261
507,247,856
1,261,373
T O T A L A S S E T S 125,440,512,338 142,384,338,317 T O T A L L I A B I L I T I E S 125,440,512,338 142,384,338,317
OFF-BALANCE-SHEET ITEMS 31.12.2017 31.12.2016 NOTES:
A S S E T S 31.12.2017 31.12.2016 L I A B I L I T I E S 31.12.2017 31.12.2016
1. Gold and gold receivables 5,190,832,297 5,261,753,291 1. Banknotes in circulation 31,111,777,700 29,929,190,200
2. Claims on non-euro area residents denominated in foreign currency 2,597,159,265 2,578,715,907 2. Liabilities to euro area credit institutions related to
monetary policy operations denominated in euro
1,959,800,623 907,409,514
2.1
Receivables from the International Monetary Fund (IMF)
685,692,703 737,322,397
2.2
Balances with banks and security investments,
2.1 Current accounts (covering the minimum reserve system) 1,959,800,623 876,909,514
external loans and other external assets 1,911,466,562 1,841,393,510 2.2 Deposit facility
2.3
Fixed-term deposits
0
0
0
0
3. Claims on euro area residents denominated in foreign currency 271,455,735 204,874,084 2.4
Fine-tuning reverse operations
0 0
3.1
General government
15,920,425 16,419,464 2.5
Deposits related to margin calls
0 30,500,000
3.2
Other claims
255,535,310 188,454,620 3. Other liabilities to euro area credit institutions
denominated in euro 0 0
4. Claims on non-euro area residents denominated in euro 23,489 23,659 4. Liabilities to other euro area residents denominated in euro 12,397,028,127 9,527,107,565
4.1
Balances with banks, security investments and loans
23,489 23,659
4.2
Claims arising from the credit facility under ERM II
0 0 4.1 General government 11,090,282,518 8,269,754,053
4.2 Other liabilities 1,306,745,609 1,257,353,512
5. Lending to euro area credit institutions related to
monetary policy operations denominated in euro
12,059,000,000 22,953,000,000 5. Liabilities to non-euro area residents denominated in euro 2,423,950,875 2,461,327,349
5.1
Main refinancing operations
680,000,000 15,430,000,000 6. Liabilities to euro area residents denominated in foreign currency 711,599,699 751,912,348
5.2
Longer-term refinancing operations
5.3
Fine-tuning reverse operations
11,100,000,000
0
7,500,000,000
0
7. Liabilities to non-euro area residents denominated in foreign currency 2,415 2,754
5.4
Structural reverse operations
0 0
5.5
Marginal lending facility
279,000,000 23,000,000 7.1 Deposits and other liabilities 2,415 2,754
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 21,614,898,570 43,665,037,526 8. Counterpart of special drawing rights allocated by the IMF 0 0
7. Securities of euro area residents denominated in euro 73,944,793,921 57,197,297,804 9. Intra-Eurosystem liabilities 64,160,258,188 85,571,386,262
7.1
Securities held for monetary policy purposes
60,624,764,994 42,484,409,198 9.1 Liabilities related to promissory notes backing
7.2
Other securities of euro area residents denominated in euro
13,320,028,927 14,712,888,606 the issuance of ECB debt certificates 0 0
9.2 Net liabilities related to the allocation of euro
8. General government long-term debt denominated in euro 5,717,976,316 6,353,182,528 banknotes within the Eurosystem 4,758,609,980 13,314,137,100
9.3 Net liabilities arising from balances of TARGET2 accounts 59,401,648,208 72,257,249,162
9. Intra-Eurosystem claims 1,914,063,363 1,854,318,415 9.4 Other liabilities within the Eurosystem (net) 0 0
9.1
Participating interest in the ECB
564,765,496 564,765,496 10. Items in course of settlement 913,852 1,004,753
9.2
Claims equivalent to the transfer of foreign
reserves to the ECB
1,178,260,606 1,178,260,606 11. Other liabilities 1,068,668,202 1,226,620,075
9.3
Net claims related to the allocation of euro banknotes
within the Eurosystem 0 0 11.1 Off-balance-sheet instruments revaluation differences 544 21,829
9.4
Net claims arising from balances of TARGET2 accounts
0 0 11.2 Accruals and income collected in advance 71,722,619 26,548,519
9.5
Other claims within the Eurosystem (net)
171,037,261 111,292,313 11.3 Sundry 996,945,039 1,200,049,727
10. Items in course of settlement 85,254 0 12. Provisions 7,600,331,097 7,477,308,544
11. Other assets 2,130,224,128 2,316,135,103 13. Revaluation accounts 3,412,541,786 3,715,573,000
11.1 Coins of euro area 63,463,487 59,834,993 14. Capital and reserves 593,639,774 815,495,953
11.2 Tangible and intangible fixed assets 564,103,667 792,236,542
11.3 Other financial assets 97,185,041 95,176,220 14.1 Capital 111,243,362 111,243,362
11.4 Off-balance-sheet instruments revaluation differences 102,453 45,122 14.2 Ordinary reserve 111,243,362 111,243,362
11.5 Accruals and prepaid expenses
11.6 Sundry
817,745,677
587,623,803
779,083,565
589,758,661
14.3 Extraordinary reserve
14.4 Special reserve from the revaluation of land
84,500,000 84,500,000
and buildings 285,443,789 507,247,856
14.5 Other special reserves 1,209,261 1,261,373
T O T A L A S S E T S 125,440,512,338 142,384,338,317 T O T A L L I A B I L I T I E S 125,440,512,338 142,384,338,317
1. Greek government securities relating to the management of the "Common capital 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 established
of legal entities in public law and social security funds" according to Law 2469/97 28,415,135,348 29,303,705,275 by the European Central Bank (ECB) and applying to all members of the European System of Central Banks (ESCB). Any issues that are not covered by the aforementioned
2. Greek government securities and other debt securities relating to the management rules and ECB 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
and custody of assets of public entities, social security funds and private agents 4,389,741,122 4,413,187,120 Statute, Codified Law 2190/1920 on sociétés anonymes and Law 4308/2014 "Greek Accounting Standards, relevant arrangements, and other provisions".
3. Assets eligible as collateral for Eurosystem monetary policy operations and intraday credit 18,544,999,389 28,265,134,198 2. Gold has been valued at the price provided by the ECB as at 29 December 2017: €1,081.881 per fine oz, compared with €1,098.046 as at 30 December 2016.
4. Assets accepted by the Bank of Greece as eligible collateral for emergency liquidity 3. Claims/liabilities denominated in foreign currency have been converted to euro using the euro foreign exchange reference rates of the ECB as at 29 December 2017.
assistance to credit institutions 78,917,229,205 103,386,216,109 4. Securities (other than those held-to-maturity, non-marketable securities and securities held for monetary policy purposes) are valued at the market prices of 29 December
5. Other off-balance-sheet items 14,773,453,517 32,377,921,059 2017. Marketable securities classified as held-to-maturity, non-marketable securities and securities held for monetary policy purposes are valued at amortised cost subject
to impairment.
TOTAL OFF-BALANCE-SHEET ITEMS 145,040,558,581 197,746,163,761 5. An impairment test was conducted on the Bank's real estate (land and buildings) and the Bank recognised impairment losses of €221.9 million. Impairment of €221.8 million

TOTAL OFF-BALANCE-SHEET ITEMS 145,040,558,581 197,746,163,761 5. An impairment test was conducted on the Bank's real estate (land and buildings) and the Bank recognised impairment losses of €221.9 million. Impairment of €221.8 million was charged against the special reserve from the revaluation of land and buildings established earlier, in accordance with the Bank's accounting policy, while impairment of €0.1 million was charged against other special reserve.

  1. The Bank's provisions include a provision against financial and operational risks, a provision for staff insurance benefits expenditure, as well as special provisions against possible operating risks, unexpected losses and doubtful claims. The special provisions include an adequate litigation provision.

  2. "Other off-balance-sheet items" include the liability of the Hellenic Republic to the IMF from the SDR allocations, as well as the promissory note issued by the Hellenic Republic in favour of the IMF for the outstanding part of the loans received. As at 31.12.2017 the value of the promissory note was SDR 9.5 billion, equivalent to €11.3 billion.

8. Certain items of the profit and loss account for the year 2016 have been reclassified to be comparable with the respective items of the year 2017.

Interest expense -41,578,063 -19,514,465
2 0 1 7 2 0 1 6
2. Net result of financial operations, write-downs (in euro)
and risk provisions 12,676,418 17,841,267 Dividend to be distributed: €0.47712 per share for 19,864,886 shares 9,477,934 9,477,934
Realised gains arising from financial operations 12,676,418 17,841,267
Write-downs on financial assets and positions -4,530,231 -32,995,688 Tax on dividends (tax rate 29%, Articles 47 and 58, Law 4172/2013, as currently in force) 3,871,269 3,871,269
Transfer from provisions for foreign exchange rate,
interest rate, credit and gold price risks 4,530,231 32,995,688 To the Government 928,451,000 1,079,000,000
941,800,203 1,092,349,203
3. Net income from fees and commissions 78,042,738 81,860,972
Fees and commissions income 80,936,433 84,141,588
Fees and commissions expense -2,893,695 -2,280,616
Note: The gross dividend for financial year 2017 amounts to €0.6720 per share.
PROFIT AND LOSS ACCOUNT FOR THE YEAR 2017 DISTRIBUTION OF PROFIT
2 0 1 7 2 0 1 6 (Article 71 of the Statute)
(in euro)
1. Net interest income 1,157,858,591 1,494,479,484
1.1
Interest income
1,199,436,654 1,513,993,949
1.2
Interest expense
-41,578,063 -19,514,465
2 0 1 7 2 0 1 6
2. Net result of financial operations, write-downs (in euro)
and risk provisions 12,676,418 17,841,267 Dividend to be distributed: €0.47712 per share for 19,864,886 shares 9,477,934 9,477,934
2.1
Realised gains arising from financial operations
12,676,418 17,841,267
2.2
Write-downs on financial assets and positions
-4,530,231 -32,995,688 Tax on dividends (tax rate 29%, Articles 47 and 58, Law 4172/2013, as currently in force) 3,871,269 3,871,269
2.3
Transfer from provisions for foreign exchange rate,
interest rate, credit and gold price risks 4,530,231 32,995,688 To the Government 928,451,000 1,079,000,000
941,800,203 1,092,349,203
3. Net income from fees and commissions 78,042,738 81,860,972
3.1
Fees and commissions income
80,936,433 84,141,588
3.2
Fees and commissions expense
-2,893,695 -2,280,616
Note: The gross dividend for financial year 2017 amounts to €0.6720 per share.
4. Income from equity shares and participating interests 38,841,503 38,863,345 Dividend to be distributed (€0.47712 per share) is subject to withholding tax
at a rate of 15% in accordance with Law 4172/2013, Article 64 paragraph 1,
5. Net result of pooling of monetary income 140,265,261 82,785,679 as currently in force.
6. Other income 14,021,505 12,426,688
Total net income 1,441,706,016 1,728,257,435
Athens, 22 January 2018
7. Staff costs and pension benefit expenses -268,665,229 -258,636,323
8. Other administrative expenses -53,937,156 -48,939,789 THE GOVERNOR THE DIRECTOR OF THE ACCOUNTING DEPARTMENT
9. Depreciation of tangible and intangible fixed assets -14,742,577 -14,948,548
10. Consultancy fees for the auditing of the banking system -1,610,438 -8,939,682 YANNIS STOURNARAS MARIA PAGONI
11. Other expenses -52,341,066 0
12. Provisions -108,609,347 -304,443,890
Total expenses -499,905,813 -635,908,232
PROFIT FOR THE YEAR 941,800,203 1,092,349,203

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

DISTRIBUTION OF PROFIT (Article 71 of the Statute)

Ν Ι Ν Ε Τ I E T H Y E A R 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 1 7 (in euro)

Deloitte Certified Public Accountants S.A. 3a Fragoklissias & Granikou str. Maroussi Athens GR 151-25 Greece

Tel: +30 210 6781 100 Fax: +30 210 6776 221-2 www.deloitte.gr

INDEPENDENT AUDITOR'S REPORT (Translated from the original in Greek)

To the Shareholders of Bank of Greece Report on the Audit of the Financial Statements

Opinion

We have audited the financial statements of Bank of Greece (the Bank), which comprise the balance sheet as at 31 December 2017, the profit and loss account and the appropriation account for the year then ended, and notes to the financial statements, including a summary of significant accounting policies.

In our opinion, the accompanying financial statements present fairly, in all material respects, the financial position of the Bank as at 31 December 2017 and its financial performance for the year then ended in accordance with the accounting principles prescribed by the European Central Bank (ECB) with the "Guideline (EU) 2016/2249 of 3.11.2016 (ECB/2016/34)" as adopted by the Bank in Article 54A of its Statute and the accounting standards prescribed by Greek Law, where the Guideline of the ECB does not provide specific direction.

Basis for Opinion

We concluded our audit in accordance with International Standards on Auditing (ISAs). Our responsibilities under those standards are described in the Auditor's Responsibilities for the Audit of the Financial Statements section of our report. We are independent of the Bank in accordance with the International Ethics Standards Board for Accountants' Code of Ethics for Professional Accountants (IESBA Code), and we have fulfilled our ethical responsibilities in accordance with the IESBA Code. 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 judgement, were of most significance in our audit of the financial statements of the current period. These matters were 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 these matters.

Key audit matter How our audit addressed the key audit matter
Provisions against financial risks
Provisions against financial risks
are significant to the Bank due to
We assessed the policies, methodology and internal controls that
the Bank has implemented relating to the provisions against
financial risks.
their magnitude to the financial
statements. The assessment
process is complex and involves
the exercise of the Bank's critical
We assessed whether the methodology employed for the valuation
of financial risks has been appropriately and consistently
implemented.
judgements and estimates.
(Liabilities – Note 12 "Provisions"
of the Financial Statements)
We assessed the appropriateness and the reasonableness of key
assumptions and models used for the valuation of financial risks. In
this assessment we also involved risk specialists.

Provisions for defined benefit obligations to insured persons

Provisions for defined benefit
obligation to insured persons is a
key area of the Bank's financial
statements given its assessment
We assessed the methodology and internal controls that the Bank
has implemented relating to the provisions for defined benefit
obligations to insured persons.
and adequacy involves the exercise
of significant actuarial and other
assumptions, such as the
We assessed whether the methodology employed has been
appropriately and consistently implemented.
underlying legal framework, the
discount rate and the expected
growth rate of salaries and
pensions (Liabilities – Note 12
"Provisions" of the Financial
Statements).
We assessed the appropriateness and the reasonableness of key
actuarial and other assumptions used for the valuation of the
provisions for defined benefit obligations to insured persons, such
as the underlying legal framework, the discount rate, the expected
growth rate of salaries and pensions. In this assessment we also
involved specialists (actuarial specialists).
We ensured the completeness of data used for the valuation of the
provision and on a sample basis we ensured the accuracy of this

data.

Other Matter

The financial statements of the Bank for the year ended 31 December 2016 were audited by another auditor who expressed an unmodified opinion on those statements on 20 January 2017.

Other Information

Management is responsible for the other information. The other information comprises the Governor's Report for the year ended 31 December 2017, but does not include the financial statements and our auditor's report thereon. The Governor's Report is expected to be made available to us after the date of this auditor's report. 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 identified above when it becomes available 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.

When we read the Governor's Report, if we conclude that there is a material misstatement therein, we are required to communicate that matter to those charged with governance.

Responsibilities of 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 prescribed by the European Central Bank (ECB), as adopted by the Bank in Article 54A of its Statute and the accounting standards prescribed by Greek Law, where the Guideline of the ECB does not provide specific direction and for such internal control as management determines is 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.

Those charged with governance are 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 is not a guarantee that an audit conducted in accordance with ISAs 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 financial statements.

As part of an audit in accordance with ISAs, we exercise professional judgment and maintain professional skepticism throughout the audit. We also:

  • Identify and assess the 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 represent the underlying transactions and events in a manner that achieves fair presentation.

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 to 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 matters that were of most significance in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor's report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

Report on Other Legal and Regulatory Requirements

  • 1) Taking into consideration that Management is responsible for the preparation of the Report of the General Council for the year ended 31 December 2017, according to the provisions of paragraph 5 of article 2 (part B) of Law 4336/2015 we note the following:
  • a) In our opinion, the Report of the General Council for the year ended 31 December 2017 has been prepared in accordance with the Bank's Statute and the applicable legal requirements of article 43a of Greek Codified Law 2190/1920 and its content is consistent with the accompanying financial statements for the year ended 31 December 2017.
  • b) Based on the knowledge we obtained during our audit of Bank of Greece and its environment, we have not identified any material inconsistencies in the Report of the General Council.
  • 2) Our audit opinion on the financial statements is consistent with the additional report to the Bank's Audit Committee referred to in Article 11 of Regulation 537/2014.
  • 3) We have been appointed statutory auditors by the General Assembly of Bank of Greece on 24 February 2017. The year ended 31 December 2017 is the first year we serve as statutory auditors. The financial statements of the Bank for the year ended 31 December 2016 were audited by another auditor who expressed an unmodified opinion on those statements on 20 January 2017.
  • 4) We have not provided the prohibited non-audit services referred to in Article 5(1) of Regulation 537/2014 and we remained independent of the Bank in conducting the audit.
  • 5) We have not provided any services, in addition to the statutory audit, during the period from 1 January 2017 to the date of this report to Bank of Greece which have not been disclosed in the Note "Services of Independent Certified Public Accountant" of the financial statements.

22 January 2018

Despina Xenaki Certified Public Accountant Reg. No. SOEL 14161 Deloitte Certified Public Accountants S.A. 3a Fragkoklissias & Granikou Str. 151 25 Maroussi Reg. No. SOEL: Ε120

Michalis Karavas Certified Public Accountant Reg. No. SOEL 13371 Deloitte Certified Public Accountants S.A. 3a Fragkoklissias & Granikou Str. 151 25 Maroussi Reg. No. SOEL: Ε120

Deloitte Certified Public Accountants S.A., Deloitte Business Solutions S.A. and Deloitte Accounting Compliance & Reporting Services S.A. (hereinafter all together "Deloitte Greece") are the Greek sub-licensees of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ("DTTL"), its network of member firms, and their related entities. Deloitte Greece along with Deloitte Italy belong to and operate under the Central Mediterranean Member Firm of DTTL. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as "Deloitte Global") does not provide services to clients. Please see www.deloitte.com/about to learn more about our global network of member firms.

Co.Reg. No: 001223601000

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