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Banco Comercial Portugues

Environmental & Social Information Mar 28, 2023

1913_iss_2023-03-28_77cf546c-8dba-474b-9474-45291e63dc30.pdf

Environmental & Social Information

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2022 SUSTAINABILITY REPORT

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Table of contents

0 7 J O I N T M E S S A G E O F T H E C H A I R M A N O F T H E B O A R D O F D I R E C T O R S A N D O F T H E C H A I R M A N O F T H E E X E C U T I V E C O M M I T T E E

0 9 V A L U E C R E A T I O N

  • 1 1 S U M M A R Y O F I N D I C A T O R S
  • 14 MAIN EVENTS

1 8 I N T R O D U C T I O N

  • 1 9 SUSTAINABILITY REPORT
  • 2 0 E U R O P E A N R E G U L A T O R Y A G E N D A
  • 21 DEVELOPMENTS NON-FINANCIAL REPORTING
  • 2 2 SUSTAINABILITY POLICY
  • 2 2 GOVERNANCE MODEL
  • 2 3 2021/2024 STRATEGIC PLAN
  • 2 5 COMMITMENTS
  • 2 8 UNITED NATIONS SUSTAINABLE DEVELOPMENT GOALS (SDG)
  • 2 9 P R I N C I P L E S O F R E S P O N S I B L E B A N K I N G ( P R B )
  • 3 0 PARTNERSHIPS
  • 3 0 MANAGEMENT OF SOCIAL AND ENVIRONMENTAL RISKS / ESG
  • 3 1 SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR)

3 4 R E L A T I O N S H I P W I T H S T A K E H O L D E R S

  • 3 5 STAKEHOLDER ENGAGEMENT AND MATERIALITY ANALYSIS
  • 3 7 SMP 2022 SUSTAINABILITY MASTER PLAN

4 0 E C O N O M I C A N D G O V E R N A N C E R E S P O N S I B I L I T Y

  • 4 1 S U S T A I N A B L E D E V E L O P M E N T G O A L S ( S D G )
  • 4 2 MILLENNIUM NETWORK
  • 4 5 INNOVATION
  • 4 7 INFORMATION SECURITY
  • 4 9 SHAREHOLDERS
  • 4 9 EMPLOYEES
  • 6 5 S U P P L I E R S
  • 6 6 ETHICS AND PROFESSIONAL CONDUCT
  • 7 4 P R O D U C T S A N D S E R V I C E S
  • 85 SERVICE QUALITY
  • 9 3 FISCAL POLICY

97 S O C I A L R E S P O N S I B I L I T Y

  • 9 8 S U S T A I N A B L E D E V E L O P M E N T G O A L S ( S D G )
  • 9 9 PARTICIPATE AND SHARE
  • 1 0 3 FINANCIAL LITERACY
  • 1 0 7 EMPLOYEE BENEFITS
  • 114 H U M A N R I G H T S
  • 1 1 8 M I L L E N N I U M B C P F O U N D A T I O N
  • 1 3 0 B A N K M I L L E N N I U M F O U N D A T I O N

1 35 E N V I R O N M E N T A L R E S P O N S I B I L I T Y

  • 1 3 8 S U S T A I N A B L E D E V E L O P M E N T G O A L S ( S D G )
  • 1 3 9 S U S T A I N A B L E O P E R A T I O N S
  • 1 4 1 D E C A R B O N I S A T I O N
  • 1 4 3 E N E R G Y E F F I C I E N C Y
  • 1 5 0 E U R O P E A N U N I O N T A X O N O M Y
  • 1 5 1 C L I M A T E M A T E R I A L I T Y A S S E S S M E N T
  • 1 5 9 T A S K F O R C E O N C L I M A T E -R E L A T E D F I N A N C I A L D I S C L O S U R E S ( T C F D )
  • 1 63 H I G H L I G H T S : A C T I V O B A N K
  • 17 1 S U S T A I N A B I L I T Y I N D E X E S A N D A C K N O W L E D G E M E N T S
  • 174 E S G O B L I G A T I O N S - A L L O C A T I O N A N D I M P A C T R E P O R T
  • 1 88 M E T H O D O L O G Y N O T E
  • 191 E X T E R N A L A U D I T O R ' S R E P O R T

195 A N N E X E S

  • 1 9 6 G R I T A B L E G L O B A L R E P O R T I N G I N I T I A T I V E
  • 2 0 7 S A S B T A B L E S U S T A I N A B I L I T Y A C C O U N T I N G S T A N D A R D S B O A R D
  • 2 1 1 U N G P T A B L E U N G U I D I N G P R I N C I P L E S R E P O R T I N G F R A M E W O R K
  • 2 1 4 T A B L E O F A L I G N M E N T W I T H T C F D R E C O M M E N D A T I O N S
  • 2 1 5 T A B L E O F A L I G N M E N T W I T H T H E R E P O R T I N G M O D E L F O R D I S C L O S U R E O F N O N F I N A N C I A L I N F O R M A T I O N O F C M V M
  • 2 1 8 A L I G N M E N T T A B L E W I T H P R B P R I N C I P L E S F O R R E S P O N S I B L E B A N K I N G

Joint Message from the Chairman of the Board of Directors and the Chairman of the Executive Board

In global terms, the year 2022 was marked by instability caused by the outbreak of a war in Europe, which exacerbated the inflationary pressures resulting from a pandemic that had not yet been fully overcome. This complex environment, which gave rise to a sharp inversion of monetary policy by the central banks, was further aggravated in Poland with the deepening of the risks associated with the home loan portfolio in foreign currency and with the introduction of legislative measures that imposed the recognition of significant losses to commercial banks operating in that market.

It was in this context that the robustness of Millennium bcp's relationship banking business model stood out, with an intensification of commercial activity that was reflected in a significant increase in operating income in the various markets where the bank is present and which, despite relevant unfavorable impacts, allowed Millennium bcp to achieve a consolidated net profit of 207.5 million in 2022, a growth of 50.3% compared to the same period of the previous year, with a significant strengthening of the capital position, reaching this year the level targeted in the strategic plan for 2024.

Millennium bcp's journey of consolidation and preparation allows us to face the challenges of the future with increased confidence: we are executing our strategy, with well-defined priorities centered on excellent service to customers and on improving efficiency, making investments essential to the transformation of the bank and successively obtaining increased levels of recognition and trust from customers, who continue to choose and distinguish Millennium bcp for its innovation, distinctive offer, and quality of service, in person and using digital channels.

Millennium bcp places sustainability and ethical, inclusive and responsible business practices as cardinal points in the cartography of its values and corporate culture. In 2022, we are once again on the side of people, society and communities in the creation of lasting and consistent social value, and in the protection of the environment, the climate and biodiversity.

Deepening sustainability practices is one of the pillars of the Excelling 24 Strategic Plan, and Millennium bcp, within the framework of its Sustainability Master Plan (PDS), has been strengthening the risk, credit and financial management policies as well as supply chain processes. The solutions on offer, the products and services with ESG (Environmental, Social and Governance) criteria, also involve implementing a transformative dynamic that responds to the growing needs of customers and the expectations of regulators.

Through the Millennium bcp Foundation, we continued to support culture, enabling events aimed at different target audiences, either by sharing, in an accessible way, the bank's artistic collection, disseminating and recognizing creative merit, or by contributing to the recovery of historic archaelogical and museological heritage.

Education, science and research are areas in which the Millennium bcp Foundation is also present through an active and consistent policy of supporting multidisciplinary projects and initiatives that stand out for their innovation, social and environmental impact as well as their capacity to add value to society.

In terms of social support, we maintained, together with the communities we serve, the BCP Group's commitment to the most underprivileged, needy and vulnerable. In Portugal, we reinforced the long-running partnership with the Banco Alimentar food bank, and promoted protocols, initiatives and support in favor of institutions such as the Association of Ukrainians of Portugal, CASA – Centro de Apoio ao Sem-Abrigo, the Brigada do Mar and BIPP/Semear.

In Mozambique, special mention should be made of Millennium bim's Social Responsibility program "More Mozambique for Me", which oversaw a protocol with ADPP Mozambique providing emergency food aid for more than 220 families who were victims of the floods in the Nampula province.

In Poland, emphasis should be placed on the support program for refugees from the war in Ukraine and on the financial contribution to organizations that, on the ground, carry out effective work with an impact on the care, protection and referral of these people and families, including the Red Cross, Caritas and Humanitarian Action. Mention should also be made of Bank Millennium's "Financial ABC" program, a local benchmark in financial literacy initiatives for young people.

In terms of accessibility, the BCP Group provides integrated platforms and innovative electronic banking functionalities, in particular mobile banking, for the digital marketing of products and services, which represent a signiifcant contribution to inclusive banking and are a distinctive, differentiating factor recognized by customers in the different geographies where we are present.

Microcredit, the financing solution with which we continue to encourage entrepreneurship and self-employment in Portugal, enabled the creation, in 2022, of 85 new jobs. Since 2005, there have been more than 7,400 jobs attributable to projects financed by Millennium bcp Microcredit.

The BCP Group promotes a culture of environmental responsibility, combating and adapting to climate change and protecting the environment and biodiversity. The preservation of natural resources and the rationalization of consumption are central objectives in the BCP Group's environmental impact policy. As a result of this commitment, in 2022, greenhouse gas emissions (excluding the credit portfolio and suppliers) were reduced to around 5,500 tons of CO2 (-86% vs. 2021), accentuating a profile of emissions which in 2022 was recognized with the inclusion of Millennium bcp in the Financial Times' "Europe's Climate Leaders" ranking.

Millennium bcp is equally committed to gender equality. Initiatives to support births and parenting, reconciling work and family, professional development and leadership opportunities, have been implemented on an ongoing basis as part of the Plan for Gender Equality, which we review and publish annually, and which justify the bank's inclusion, for the fourth consecutive year, in Bloomberg's Gender-Equality Index.

Within the framework of equal opportunities, diversity and inclusion, mention should be made of the investment in the enhancement and professional development of the bank's employees, with more than 10,000 training actions, corresponding to around 716,000 hours of training.

In 2022 Millennium bcp also joined the United Nations Environment Program - Finance Initiative (UNEP-FI), subscribing to its Principles of Responsible Banking (PRB), emphasizing our commitment to responsible investment policies and assessment of the impacts of its activity, both on society and on the planet.

The BCP Group remains committed to respecting the 10 Principles of the United Nations Global Compact - in a bond that dates back to 2005 and was renewed in 2018 - also recognizing in the UN's Sustainable Development Goals (SDGs) a unifying and aspirational vision, capable of stimulating change and evolution that the economic, social and environmental reality imposes and demands.

In 2023, we will continue to promote decarbonized and resilient economic development models that encourage, among families, companies and countries where we operate, the creation of wealth and its fair distribution, protect the planet, the climate and biodiversity, while ensuring respect for human dignity, improving living conditions and maintaining democratic, plural and inclusive systems of social and political organization.

In the conviction that the economic development of Millennium bcp will depend on our continuing to be able to create more prosperity and sharing it with multiple stakeholders in a balanced way, with respect for diversity and a firm commitment to supporting the communities we serve, with high standards regarding the practices of the Bank and its governing bodies and workers in environmental, social and governance matters, we will proceed with determination to comply with our strategic plan, and the purposes and objectives established by the sustainability plan.

Miguel Maya Chairman of the Executive Committee Vice-Chairman of the Board of Directors

Nuno Amado Chairman of the Board of Directors

VALUE CREATION

Value Creation Model

(1) Includes only operations in Portugal

(2) Data from 2020 (in 2021 it was not performed)

(3) Value reflects the operations in which this regime is applicable (PT and MZ)

SUMMARY OF INDICATORS

MAIN INDICATORS

SUMMARY OF NON FINANCIAL INFORMATION

Unid. 2022 2021 2020 2019 2018 Var. % 22/21
CUSTOMERS
Total of Customers Thousands 7 203 6 812 6 667 6 617 5 826 2.2%
Number of Active Customers (1) Thousands 6 478 6 143 5 705 5 598 7.7%
Interest paid on deposits and interbank funding Million euros 422 91 188 301 327 -51.6%
Claims registered (2) Number 201 828 172 753 172 674 136 562 108 244 0.0%
Claims resolved Percentage 92.2% 93.4% 93.0% 92.2% 99.3%
ACCESSIBILITIES
Branches Number 1 239 1 288 1 380 1 536 1101.000 -6.7%
Activity in Portugal 407 434 478 505 546 -9.2%
International activity 832 854 902 1 031 555 -5.3%
Branches opened on Saturday 160 162 167 143 122 -3.0%
Branches w ith access conditions to people w ith reduced mobility 826 875 937 875 866 -6.6%
Internet Users number 2 762 685 2 653 754 2 453 555 2 214 885 1 980 905 8.2%
Call Center Users number 479 265 622 735 491 969 431 169 429 982 26.6%
Mobile banking Users number 4 293 837 3 700 969 3 214 664 2 601 401 2 106 289 15.1%
ATM Number 2 943 2 959 3 022 2 988 2952.000 -0.5%
EMPLOYEES
PORTUGAL EMPLOYEES Number 6 252 6 289 7 013 7 204 7 095 -10.3%
INTERNATIONAL EMPLOYEES Number
TOTAL 9 495 9 731 10 322 11 377 8 972 -5.7%
Number 15 747 16 020 17 335 18 581 16 067 -7.6%
LABOUR INDICATORS (3)
Breakdow n by professional category Number
Executive Committee 2 3 2 8 2 8 2 8 2 8 -17.9%
Senior Management 167 165 163 221 178 1.2%
Management 1 468 1 735 1 874 2 157 1 728 -15.4%
Commercial 9 147 9 048 9 949 10 664 9 446 1.1%
Technicians 4 140 4 067 4 067 4 388 3 682 1.8%
Other 798 973 1 250 1 116 1 027 -22.2%
Breakdow n by age Number
<30 2 562 2 565 2 841 3 350 2 393 -0.1%
[30-50[ 8 647 7 919 9 872 10 648 9 318 9.2%
>=50 4 534 5 532 4 618 4583 4 350 -18.0%
Average age Years 4 2 4 2 4 1 4 1 4 1 0.0%
Breakdow n by contract type Number
Permanent 14 450 14 956 15 969 16 84 14 685 -3.4%
Temporary 1 293 1 060 1 362 1 681 1 376 22.0%
Trainees 148 193 275 453 339 -23.3%
Employees w ith w orking hours reduction Number 197 213 230 254 215 -7.5%
Disabled employees Number 221 201 205 180 163 10.0%
Recruitment rate Percentage 12.8% 9.7% 6.4% 12.5% 12.3% ---
Internal mobility rate Percentage 14.7% 16.3% 20.7% 16.3% 16.6% ---
Leaving rate Percentage 13.7% 17.5% 13.8% 11.9% 11.0% ---
Free association (4) Percentage
Employees under Collective Work Agreements 99.7% 99.6% 99.8% 99.7% 99.7% ---
Union Syndicated Employees 74.0% 75.0% 77.0% 76,9% 78.6% ---
Hygiene and safety at w ork (HSW)
HSW visits (5) Number 182 331 186 184 159 -45.0%
Injury rate (6) Index 1.85 1.99 2.19 2.42 1.99 -7.0%
Death victims Number 0 0 0 0 0 0.0%
Absenteeism rate Percentage 5.1% 5.4% 6.3% 4.8% 4.3% ---
Low est company salary and minimum national salary Ratio 1.2 1.2 1.3 1.3 1.3 0.0%
ENVIRONMENT (5)
Greenhouse gas emissions tCO2eq 12 800 38 611 49 307 50 714 50 588 -66.8%
Electricity consumption MWh 46 464 43 750 59 214 62 527 59 664 6.2%
Production of w aste t 1 216 1 141 768 617 677 6.6%
Water consumption m 3 176 288 163 747 208 817 276 46 281 666 7.7%
SUPPLIERS
Time of payment and time contractually agreed, in Portugal Ratio 1 1 1 1 1 0.0%
Purchase from local suppliers Percentage 90.5% 92.3% 92.2% 91.4% 92.2% ---
DONATIONS Million euros 2.3 2.7 2.0 2.1 2.0 -14.8%

(1) Primary holders w ith at least 1 product w ith a balance > 50 cents, in absolute value and w ith card transactions in the last 90 days, or holding financial assets ≥ 100 euros.

(2) It includes a structural change effect in the complaint handling process at Bank Millennium Poland, aiming at improving the Customer experience by optimizing the immediate treatment. (3) Employees information (and not FTE) for: Portugal, Poland and Mozambique.

(4) The value reflects only operations w here the regimes are applicable. Collective w ork agreement: Portugal and Mozambique. Syndicate: Portugal and Mozambique.

(5) Data does not include Moçambique.

(6) Number of accidents per million hours w orked. In 2020 the calculation methodology w as changed in accordance w ith the GRI (Global Reporting Initiative), and the series w as retroactively adjusted.

Highlights

Donations Distribution of employees by gender 45% 55% (Percentage) Men Women

Total energy consumption (1) GRI 302 -1 Emissions GHG 2 (2) Total of energy consumption GHG Emissions

TOTAL ENERGY CONSUMPTION - GRI 302-1 (TJ and MWh/employee)

Includes co-generation power plant, excludes facilities with data centres Electricity consumption (MWh) by employee (2)

in Portugal and data from Mozambique.

(tCO2e)

6 421 6 988 4 619 42 634 31 440 7 769 252 182 412 3.3 2.9 1.0 0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 0 10 000 20 000 30 000 40 000 50 000 60 000 70 000 80 000 2020 2021 2022 Indirect Emissions (Scope 3) Indirect Emissions (Scope 2) Direct Emissons (Scope 1) Total emissions by employee

4.0

4.5

Does not include Mozambique figures.

MAIN EVENTS

2022 Main Events

The BCP Group annually carries out social and environmental actions and initiatives in its main geographic areas (Portugal, Poland and Mozambique), as part of its sustainability strategy and social responsibility policy.

JANUARY

  • Inclusion, for the third consecutive time, in the Bloomberg Gender-Equality Index, joining the group of companies that globally stand out in the implementation of gender equality, diversity and inclusion practices and policies;
  • Bank Millennium, in Poland, is part of the Warsaw Stock Exchange's WIG-ESG index, in consideration of the work developed within the environmental, social, economic and corporate governance dimensions;
  • Bank Millennium, in Poland, was awarded the "Wrocław without barriers" prize in the Corporate Social Responsibility category for solutions that facilitate the use of digital banking by people with disabilities and for training actions on how to serve people with special needs;
  • Attribution of Rui Osório de Castro Award/ Millennium bcp by Fundação Millennium bcp (6th edition), honouring the development of innovative projects and initiatives in the area of child cancer.

FEBRUARY

  • BCP Group remained in 2022 in "The Sustainability Yearbook", a benchmark publication in the area of Sustainability now published by S&P analyst based on information gathered from companies' responses to the "Dow Jones Sustainability Indices".
  • Fundação Millennium bcp continues to support

the GOS - Management of Social Organisations programme (23rd and 24th editions), developed by AESE Business School in partnership with ENTRAJUDA (Lisbon and Porto).

• Millennium bcp launches an internal challenge "Sustainability: we are (together) building the Future" and benefits from dozens of ideas and suggestions from its Employees to improve the Bank's performance in sustainability matters.

MARCH

  • The Millennium bcp Foundation supports the Junior Achievement Portugal (JAP) Learning and Venturing programme, encouraging the entrepreneurial spirit among university students;
  • Bank Millennium in Poland launches a programme to support refugees from the war in Ukraine and donates PLN 400,000 to four organisations, suggested by Employees, that are active on the ground in their care and protection: Red Cross, Caritas, Humanitarian Action and "Salvação" Foundation;
  • Millennium bim, in Mozambique, celebrates a protocol with ADPP Mozambique for financial support over three years to the project "Escola de Professores do Futuro" (School for the Teachers of the Future), in the province of Manica, for the training of more than 200 teachers.

APRIL

• Millennium bcp creates a community vegetable garden in Taguspark for its Employees, providing 12 spaces so that, as a team, they can plant and harvest organic vegetables and fruit

In 2022, the BCP Group stood by local communities in social support, but also in protection of the environment, climate and biodiversity

  • For Global Finance magazine, Millennium bcp is the best Bank for Sustainable Finance in Portugal, in recognition of its leadership in financing projects that fight climate change and improve people's quality of life;
  • For the 2nd consecutive year Millennium bcp is in the "Europe's Climate Leaders" ranking of the Financial Times and Statista, and in 2022 remained in the group of European companies that have made the most progress in reducing GHG (greenhouse gas) emissions;
  • Bank Millennium in Poland, recognised as "Best Employer 2022" in the Forbes and Statista rankings, ranking second in the financial sector;
  • Millennium bcp and NOS signed another Commercial Paper Programme, this time for 100 million euros and for a period of five years, with conditions that include a sustainability component;
  • Millennium bim, in Mozambique, promotes, as part of the initiatives to celebrate the "Month of Mozambican Women", a webinar on Women's Health and Well-Being.

JUNE

  • Millennium bcp joins the United Nations Environment Programme - Finance Initiative (UNEP-FI) and subscribes to its Principles of Responsible Banking (PRB);
  • Bank Millennium in Poland, one of the leading companies in the management of Corporate Social Responsibility policies and practices, will be in the Top 10 of the Responsible Business

Forum's ranking of Socially Responsible Companies in 2022;

  • Millennium bcp is once again associated with the "Portugal Chama" campaign, an initiative of the Portuguese State aimed at contributing to the prevention of forest fires and raising public awareness about risk behaviour;
  • Bank Millennium in Poland awarded for the seventh time with the "POLITYKA CSR Gold Leaf 2022", an award attributed to companies that implement Corporate Social Responsibility policies and practices in their daily activities.

JULY

  • 14th edition of the Millennium Festival ao Largo, an annual free-of-charge initiative that presents on stage, once again in Lisbon's Largo de S. Carlos, a variety of symphonic music, opera and ballet performances;
  • Millennium bim, in Mozambique, promotes female creativity through the 3rd edition of the contest "Great Women, Great Solutions", this time dedicated to the theme of sustainability;
  • Millennium bim, in Mozambique, promotes social solidarity action and supports with food and clothing more than 220 families that are victims of floods in the province of Nampula.

AUGUST

• Millennium bim, in Mozambique, together with public entities, is promoting the "Muro da Biodiversidade" (Biodiversity Wall), an initiative that aims at rehabilitating the degraded area outside Maputo's international airport by painting about 40 murals on Mozambican wildlife, marine life and flora.

SEPTEMBER

  • Fundação Millennium bcp supports the 14th edition of the TODOS Festival - Caminhada de Culturas 2022, an initiative of the Lisbon Municipality that promotes an intercultural city through contemporary performing arts.
  • Millennium bcp Foundation supports the "Trienal de Arquitetura de Lisboa Millennium bcp", which in 2022 had the central theme "Earth", and awards the 6th edition of the prizes in the categories Careers, Début and Universities.

OCTOBER

  • Millennium bcp sees its 2020 Report on the United Nations Sustainable Development Goals (SDGs) highlighted in the 1st Report "SDGs in Portuguese Companies" of the Center for Responsible Business & Leadership of the Universidade Católica - Lisbon School;
  • Millennium bim, in Mozambique, as part of the celebration of its 27 years and of the programme "Mais Moçambique pra Mim" (More Mozambique for Me), promotes another edition of the project "Uma Cidade Limpa pra Mim" (A Clean City for Me) and engages 230 volunteers in a new action of valorisation and conservation of public spaces;
  • Bank Millennium in Poland renews its long-term cooperation with WWF -World Wide Fund for Nature as part of its commitment to protect the climate, the environment and biodiversity;
  • Millennium bim, in Mozambique, resumes the "Olimpíadas Bancarias" (Banking Olympics), a project that is now in its 11th edition, which aims to contribute to the education and training of young Mozambicans through the introduction of banking concepts and personal finance management, promoting their financial inclusion in society.

NOVEMBER

• Millennium bcp, as part of a group of more than 80 Portuguese companies, signed the Manifesto "Towards COP27" of the BCSD Portugal, recognising the importance of this conference for the global dialogue on the decarbonisation of development models and for compliance with the Paris Agreement on climate

  • Social Responsibility Campaign "Um livro não tem preço (na educação de uma criança)" (A priceless book (in a child's education)), unites the Bank's employees in Portugal and Mozambique and collects 2,254 books for children in Mozambican schools in vulnerable areas;
  • Millennium bcp sees its Corporate Social Responsibility campaign "Millennium Solidarity: Christmas 2021" distinguished by the Fosun Foundation as part of the fifth edition of the "ONE FOSUN CSR Week", an initiative that aims to publicise and honour the CSR programmes or actions of companies owned or participated by Fosun.

DECEMBER

  • Bank Millennium in Poland, was awarded with the title of "Europe's Diversity Leader 2023", a ranking produced by the Financial Times and Statista, remaining in the group of European employers that promote and support diversity in their organisations;
  • Social Responsibility Campaign "Millennium Solidário 2022", brings together the Bank's Employees and the Millennium bcp Foundation in support of the Association of Ukrainians in Portugal and CASA - Centro de Apoio aos Sem Abrigo (Support Centre for the Homeless);
  • Millennium bcp signs the "Pacto Para Mais e Melhores Empregos para as Jovens" (Pact for More and Better Jobs for Youth), which aims to make a real change in the current context of vulnerability associated with youth employment;
  • Millennium bcp participates, again with the presence of more than 70 volunteers and at a national level, in the biannual food collection campaign promoted by the Food Bank.
  • Millennium bcp, together with more than 60 member companies of BCSD Portugal, sign the Manifesto "Por um Acordo na COP15" (For an Agreement at COP15), recognising the urgency of adopting a Global Biodiversity Strategy to stop biodiversity loss by 2030 and promote the recovery of natural ecosystems.

A leading bank at the service of the economy, society and families

INTRODUC-TION

Introduction

Banco Comercial Português publishes annually, since 2004, Sustainability Reports according to the GRI (Global Reporting Initiative ), now in its Standards version

Sustainability Report

The Sustainability Report, now in its 19th edition, offers a global and integrated vision of the economic, social and environmental performance of the BCP Group, as well as details of each of its main operations in Portugal, Poland and Mozambique.

Relating to the formats adopted and after the issue of autonomous Reports from 2004 to 2008, the Bank decided, in 2009, to include in Volume I of the Annual Report a brief chapter on the activities carried out by Millennium in the wake of Sustainability and to publish the full version of the Sustainability Report only in digital format.

In 2010, to translate the alignment of the sustainable development and social responsibility policies with the business strategy of BCP Group, this Report became part of the Annual Report. The document Progresses and Targets was also published, a report that describes the development stage of the actions envisaged in the Sustainability Master Plan (SMP) of the year it reports to. This reporting method adopted in 2010 continued to be used in 2011 and 2012.

In 2013, Millennium bcp decided to include a chapter - Responsible Business - on Sustainability in the Bank's Annual Report and it published again - in a separate and independent volume only available in digital format - a document detailing the activities annually developed by the BCP Group, which it continued to do until 2016.

In the context of the framework established by DL no. 89/2017 of 28 July, regarding the mandatory annual disclosure of non-financial information and information on diversity by certain large companies, Millennium bcp kept, between 2017 and 2020, a dual format, materialised in the summary information included in the chapter of the Annual Report - Non-financial Statement - and in the detailed information in the Sustainability Report.

Given our interpretation of the trends and guidelines on the reporting of non-financial information and the new regulatory requirements, the Bank has decided to discontinue the practice it has followed in recent years of including a chapter on Sustainability in the Annual Report, reverting to concentrating all non-financial information and indicators in the Sustainability Report in 2021.

This document, which covers all the geographic regions of the BCP Group, intends to continue to meet the expectations of stakeholders, identified through regular materiality analyses and the continuous feedback received through the available platforms, channels and communication flows.

This document was made in accordance with the principles set forth by the GRI (Global Reporting Initiative), for the option "in accordance core" and respective supplement of the financial sector, the principles of inclusivity, materiality and responsiveness of the Standard AA1000APS (2008) and verified by an external entity in compliance with the principles defined by the International Standard on Assurance Engagements 3000.

The scope and methods to estimate the reported indicators and reporting limits are detailed at the end of the report under "Methodology". The complementary information reported, namely the tables: (i) GRI indicators, which also includes correspondence with the UN Global Compact Principles; (ii) alignment with the Comissão de Mercado de Valores Mobiliários (Portuguese stock market regulator) (CMVM) guidelines for nonfinancial reporting; (iii) the Sustainability Accounting Standards Board (SASB) indicators; (iv) the UN Guiding Principles Framework and; (v) the UNEP FI Responsible Banking Principles (RBP); these are available for consultation in the annexes to the report and on the Bank's institutional website, at www.millenniumbcp.pt, Sustainability area.

The combined reporting perimeter of (i) the Millennium bcp Annual, (ii) the Bank Millennium Annual Report and Relatório ESG do Bank Millennium (Bank Millennium ESG Report), (iii) the Millennium bim Annual Report, (iv) the Millennium bcp Foundation Annual Report and (v) Bank Millennium, covers the disclosure, in its different dimensions, of the relevant information on the performance of the BCP Group on the issues identified in the materiality matrix available in the chapter "Relationship with Stakeholders".

The BCP Group, a signatory of the United Nations Global Compact since 2005, also recognises the importance of the Sustainable Development Goals (SDGs) and the United Nations Agenda 2030 and, therefore, throughout this document the most direct contributions of BCP Group's activity to their pursuit are identified.

European Regulatory Agenda

The national and European regulatory context on Sustainability matters, including those related to sustainable finance, is today, as a result of an accelerated legislative dynamic, more complex, demanding and multidisciplinary. The set of progressively extended ESG (Environmental, Social and Governance) guidelines and obligations with an impact on the governance model, value proposition and corporate reporting practices on non-financial information requires from organisations a permanent ability to adapt and adjust in order to meet the new requirements and expectations of stakeholders.

In the case of the BCP Group, the Sustainability Report addresses different reporting requirements on sustainability performance and indicators, namely:

  • Directive 2014/95 on disclosure by large companies and groups of non-financial information and diversity information (NFRD), published in October 2014, which requires a set of organisations to report nonfinancial information, namely information on social and environmental performance, transposed into Portuguese law through DL no. 89/2017;
  • Paris Agreement, promoted by the United Nations and signed in December 2015, is a climate change action plan that aims to limit global warming well below 2°C compared to pre-industrial levels and below 1.5°C, ratified by all European Union countries;
  • Sustainable Finance Action Plan, launched by the European Commission in March 2018, a document from which extremely relevant directives and regulations would emanate for the reporting of non-financial information by organisations that comprise the financial sector;
  • EU Regulation 2019/2088 concerning disclosure of sustainability-related information in the financial services sector (SFDR), adopted by the European Union in November 2019, which aims to make information on financial products and their contribution to sustainability comparable and more easily understood by investors and other information users and entered into force in March 2021. The 2nd phase of the SFDR requires financial market participants to disclose on the integration of "sustainability risks" into their investment decisions and the "major adverse impacts" of those decisions on environmental and social

criteria, and disclosure of financial products that promote "E" and/or "S" characteristics or have a sustainable goal. Already from 2023, the reporting duty includes entity and product information, on the website, in precontractual information and in periodic reports;

  • Taxonomy Regulation (EU Regulation 2020/852), adopted in June 2020, published as part of the Sustainable Finance Action Plan, which complements parts of the SFDR and consists of a single classification system for environmentally sustainable activities that aims to enable investors to redirect their investments towards more sustainable enterprises. The reporting obligations in this area, when established in their fullest version (in 2024), and which include the GAR - Green Asset Ratio, will allow an assessment of the extent to which bank assets contribute positively to the Taxonomy's goals;
  • Proposal for a Directive on Corporate Sustainability Reporting (CSRD), published in April 2021 by the European Commission, replacing Directive 2014/94 (NFRD), and which now requires a wider range of companies to publish non-financial information on their performance according to the European Sustainability Reporting Standards, which are under development; The CSRD will require all large companies and all listed SMEs to disclose how sustainability issues may affect them and society/environment and to disclose their share of "environmentally sustainable" economic activities under the Taxonomy Regulation;
  • Climate Act (Law no. 98/2021), published in December 2021, which, in its article 38, states that climate risk should be considered in corporate governance and incorporated into their decision-making processes and that information on identified climate risks should be reported;
  • Risk disclosure Pillar 3 Report Disclosures on ESG risks - from 28 June 2022, large institutions that have issued securities admitted to trading on a regulated market of any Member State as defined in Article 4(1) of Directive 2014/65/EU shall disclose information on ESG risks, including physical and transitional risks, as defined in the report referred to in Article 98(8) of Directive 2013/36/EU. The Bank is already preparing information in this field and is getting ready

for the expansion of Pillar 3 ESG in terms of disclosure on these factors;

• Pursuant to the Directive on Markets in Financial Instruments II (MiFID II), the Bank, as a Financial Intermediary, shall, prior to making investments on the products, services or financial instruments, request the Customer to provide specific information in order to assess the Customer's investment profile and the suitability of the investment to such profile (based on Article 54(2) of the EU Delegated Regulation 2017/565 on suitability assessment and on the definition of sustainability preferences introduced in Article 2(7).

Non-Financial Reporting Developments

The BCP Group's sustainability approach is guided by the main reporting and performance trends in environmental, social and governance issues, at national and international level, in line with the provisions of the Non-Financial Reporting Directive (NFRD), transposed to the Portuguese legal system by DL. no. 89/2017, and already anticipating the guidelines of the new Corporate Sustainability Reporting Directive (CSRD).

Therefore, in its Sustainability Master Plan, Millennium bcp includes several targets that respond to the most recent trends in Sustainable Finance and reporting of non-financial information, such as subscribing to the United Nations Principles for Responsible Banking (UNEP FI), fulfilling the targets defined under the United Nations SDGs, adapting to the new European Union (EU) guidelines on non-financial reporting, including the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD), aligning with the Regulations aimed at "Establishing a regime for the promotion of sustainable investment" EU Regulation No. 2020/852 (aka Taxonomy) or the "Disclosure of sustainability-related information in the financial services sector" (EU Regulation 2019/2088, SFDR), and the definition of targets certified by the Science Based Targets initiative (SBTi) and aligned with the Paris Agreement is also under assessment.

The Bank considers that it has a role in meeting national and international commitments, recognising the importance of the financial sector's involvement and alignment in the transition to a sustainable and inclusive economic development model. In terms of climate change, the Bank is committed to the Paris Agreement and the objective of limiting the increase in average temperature to below 1.5ºC. As far as ethical and responsible leadership is concerned, we underline the commitment of BCP Group to the Global Compact Principles, defined by the United Nations, which have as action purpose 10 Principles in the scope of Human Rights, Working Conditions, Environmental Protection and Anti-Corruption.

In terms of reporting guidelines, the Bank develops its Sustainability Report in line with the GRI Standards, also publishing the SASB indicators, namely those associated with the financial sector, as well as the recommendations of the TCFD and, in Portugal, the CMVM. This report also includes reporting on Human Rights in accordance with the UN Guiding Principles Framework.

On issues related to Sustainable Finance, the Bank monitors developments in the legal and regulatory environment of the financial sector (namely the diplomas resulting from the European Commission's Sustainable Finance Plan and the guidelines defined by the European Central Bank and the European Supervisory Authorities) and participates in various national and international working groups on these issues.

Additionally, BCP Group has been ensuring an increasingly effective alignment between its business processes and support operations with the ESG (Environmental, Social and Governance) areas and this is achieved by integrating environmental and social aspects in the company's activities, from the governance and risk management model to the offer and management of internal activities.

The risk management policy is being adapted and improved, reflecting the strategic priority that the Bank gives to ESG topics

Sustainability Policy

The BCP Group pursues dynamic strategies adapted to the new challenges imposed by the several interested parties with which it establishes relations. The main objectives of the adopted sustainability policies, which foster a culture of Corporate Social Responsibility, has been to positively influence the organisation's value proposition in the long term, balanced with the well-being of the people, the company and communities in which it operates, while preserving natural resources, climate and the environment.

Within this framework, it is possible to divide the Bank's intervention into three major axes:

  • Environment implementation of measures that promote a fair and inclusive transition to a decarbonised economic development model, including the incorporation of the environmental aspect in the Bank's risk models and the supply of products and services;
  • Social engagement with the external and internal community;
  • Corporate governance integration of sustainability principles into the Bank's decision-making processes.

Thus, Millennium bcp undertakes, as an integral part of its business model, the intent to create social value, developing actions for and with several groups of Stakeholders aiming to, directly and indirectly, contribute to the social development of the countries where it operates.

Governance Model

Material issue:

SUSTAINABILITY GOVERNANCE

Under the Sustainability Master Plan (SMP), Millennium bcp has been reviewing and perfecting its governance model for Sustainability and Responsible Business.

In this context, in 2020 it created the Sustainability Commission (SC Rules), a body dependent on the Executive Committee (EC) and chaired by the CEO, which is responsible for assessing, following up and monitoring the implementation of Millennium bcp's Sustainability strategy - which includes the economic, social, environmental and climate change dimensions - having, specifically, the following tasks:

  • To advise the EC in the integration of Sustainability principles (Environmental, Social and Corporate Governance) in the Bank's decision-making and management processes;
  • Analysis and approval of the initiatives necessary for the implementation of actions aimed at materialising the strategic axes and lines of action of the SMP in force, as well as other amendments or adaptations necessary for the fulfilment of the targets defined;
  • Supervision and monitoring of the progress of the approved initiatives, compliance with the respective deadlines and budgets and the evolution of the results achieved, as well as the main performance indicators of the SMP dimensions.

In 2022, within the scope of the Board of Directors (BoD) Committees, the new name and new regulations of the present Committee for Corporate Governance, Ethics and Sustainability (CCGES Regulations) were also approved, the body responsible for recommending the adoption by the BoD of policies in line with ethical and social responsibility principles and best practices in matters of corporate governance and sustainability, but also for monitoring the evolution of the SMP and the Corporate Social Responsibility Plan and issuing an opinion on the annual corporate governance and sustainability reports. The Committee for Risk Assessment (CRA Regulation) also saw its powers and duties extended to include the monitoring of ESG risks, including climate risks.

In addition, in line with the objective of strengthening the governance model of the topics included in the Sustainability perimeter, the Board of Directors also has competencies in the area of sustainability. Besides the competencies in matters of sustainability delegated to the CCGES and CRA, the Board of Directors is responsible for establishing a system of internal control, translated into a set of strategies, policies, processes, systems and procedures with the aim of ensuring the medium and long-term sustainability of the institution and the prudent exercise of its activity and ensuring that it is applied consistently in all the Bank's subsidiaries and branches, in Portugal or in international operations.

In order to ensure that the Board of Directors has sufficient knowledge to effectively manage sustainability issues, in 2022, training was promoted on sustainability and co-sourcing, provided by the Internal Audit area. This training aimed to demonstrate how to integrate sustainability areas in the Bank's internal processes.

BCP Group also assumes, in an ongoing dialogue with its Stakeholders, a set of corporate policies and principles - partially revised in 2022 - namely:

  • I. Sustainability Policy;
  • II. Environmental Policy;
  • III. Social Impact Policy;
  • IV. Human Rights Policy;
  • V. Policy for Diversity and Equal Opportunities;
  • VI. Occupational Health and Safety Policy;
  • VII. Corporate Volunteering Policy;
  • VIII. Anti-Corruption and Anti-Bribery Policy;
  • IX. Principles for a responsible financing: under conditions and excluded projects;
  • X. Sustainability Guidelines for Suppliers;
  • XI. Millennium bcp Principles on tax issues.

More information about the organisational model of BCP Group is available in the Corporate Governance report.

2021/2024 Strategic Plan

In the current cycle of the Strategic Plan "Superação 24", Millennium bcp tries to identify business opportunities related with sustainability and also manage the physical and transition risks of its portfolio, to assert itself as a reference in the market. It is also innovating in its own products with a green and social rating addressed to individuals (ex. increasing credit and investment solutions compliant with ESG criteria) and companies (ex. loans with an interest rate indexed to "E" or "S" criteria).

Besides, the Bank continues to explore partnership alternatives to extend its offer of ESG products, for example, in the financing of works in buildings, aimed at improving their energy self-sufficiency and the electric vehicle ecosystem. Millennium bcp will also explore partnerships to provide consultancy and advisory services to companies to support them in their green transition process.

Seeking to become the principal partner for the energy transition, the Bank is committed in increasing the issue of bonds linked with sustainability criteria (SLB) and of ESG bonds so as to become the leading company in Portugal in this domain, boosting the relevance of this type of bonds in the EU's strategy for Sustainable Finance.

The objectives that Millennium bcp proposes are in line with the aspiration to affirm itself as a reference in Portugal, in this domain, during the cycle of the 2021/ 2024 Strategic Plan: average of the ratings of the three main indexes (DJSI, CDP and MSCI) above 80%, keep all its premises in Portugal operating with totally renewable energies (what has been happening since 2021) and reduce the exposure to sectors with a significant use of coal.

Commitments

Following the subscription in 2005 of the United Nations "Global Compact Principles" and re-affirmed in 2018, BCP Group commits to support its 10 Principles that establish a set of values in what concerns Human Rights, Labour Conditions, Environment Protection and Anti-corruption.

In 2019, within the scope of the "Think tank on Sustainable Funding in Portugal", promoted by the Ministries of Environment, Finances and Economy (within the context of the Route to Carbon Neutrality in 2050), which had the participation from the major banks that operate in the market, supervisors and sector associations, two documents were produced: (i) "Guidelines to accelerate sustainable funding in Portugal"; and (ii) "Engagement Letter for the Sustainable Funding in Portugal" subscribed by Millennium bcp -, that seek to highlight the importance of including environmental, social and governance risks in the financial sector's decision-making and risk management processes and which continue to constitute benchmark guidelines for the Bank.

In 2020, Millennium bcp also subscribed to the " Lisbon European Green Capital Commitment", promoted by CML (Lisbon City Council), which brought together more than 200 entities with a presence in the city, including companies, schools and institutions, in a commitment to climate action and towards sustainability in order to foster a collective dynamic to meet the targets set by the Paris Agreement and accelerate the path to carbon neutrality.

Within this framework, Millennium bcp has set itself the following initiatives to be implemented by 2030:

1 Energy – Install LED lighting in all buildings;

2 Energy Install (more) equipment for the production of photovoltaic solar energy in the buildings more exposed to the sun and with a sufficient area for that purpose;

3 Water - Implement solutions enabling water re-use;

4 Circular Economy eliminate the use of plastics used only once;

5 Citizenship and Participation – Disclose materials from the Green Capital to the employees and/or Customers.

In 2019, the Bank also joined the "Business Mobility Pact for the City of Lisbon", a joint initiative from the Lisbon City Council (CML), from the WBCSD - World Business Council for Sustainable Development and from BCSD Portugal, that aggregates in a public voluntary agreement, companies that operate in Lisbon and have as a common goal to improve and transform mobility in the city, making it more sustainable.

Hence, Millennium bcp is decided to (i) increase the proportion of electric and hybrid plug-in vehicles in its operational fleet and in those for private use and (ii) keep, for the employees use, a pool of cars able of being reserved and used as necessary for service travels.

Millennium bcp also subscribed in 2019 the "CEO Guide to Human Rights" an initiative from the World Business Council for Sustainable Development (WBCSD) and from the Business Council for Sustainable Development (BCSD, Portugal). The Guide includes the policies and practices of reference and intends to contribute for the implementation and promotion of the human rights in the organization and in their value chains.

To further enhance its commitment with human rights and an ethical and inclusive management, in 2020, BCP subscribed the "Statement from Business Leaders for Renewed Global Cooperation", from Global Compact of the United Nations, an international statement focused on showing the commitment with an ethical leadership, based on good governance practices, materialised through values, strategy, policies, operations and proximity relations and involvement with all stakeholders. This commitment also aims at establishing a partnership with the United Nations, Governments and Civil Society to contribute for the straightening of justice and transparency, promoting equality and respect for human rights.

Also in 2020, Millennium bcp joined the "Women's Empowerment Principles" (WEP) from the Global Compact of the United Nations, an important international platform for the promotion of gender equality that translates our long-term view and the will to be part of - and encourage - a collective dynamics based on cooperation and trust.

Within the scope of the commitment with Diversity and Equality of Gender - already translated in the corporate Policy "Diversity and Equal Opportunities" -, the Bank approved an action plan for gender equality, updated every year, already updated for 2023 - Plan for Gender Equality -, involving the regular follow-up of its execution by the Human Resources Commission. The initiatives proposed are aggregated in six major pillars, namely:

  • Gender Equality measures;
  • Management indicators regularly monitored;
  • Strict application of the Remunerations and Promotions Policy;
  • Increased participation of the gender less represented in the programs for the development of Leadership competences;
  • Recruitment of new employees using gender diversity and wage equality criteria; and
  • Work-Life balance support.

Since 2017, Millennium bcp is a subscriber of the Charter of Principles from BCSD Portugal Corporate Council for Sustainable Development. This document establishes the principles that are the guidelines for good corporate management, enabling the subscribing companies to be recognized by their customers, suppliers and by the society in general for the adoption of solid sustainability commitments.

Since 2018, Bank Millennium is a subscriber of the Letter for Diversity in Poland, a commitment that reaffirms its determination in respecting and promoting diversity amongst customers and employees.

The Bank was also included in the "European Diversity Leaders 2022" ranking. In the latest Financial Times list, 850 employers were selected from among 15,000 European companies as benchmarks for implementing and promoting diversity practices in their organisations.

In 2022, Millennium bcp, within the framework of the initiatives promoted by BCSD Portugal, subscribed to (i) the Manifesto "Towards COP27" of BCSD Portugal, recognizing the importance of this conference for the global dialogue on the decarbonisation of development models and for compliance with the Paris Agreement on climate and (ii) the Manifesto "For an Agreement at COP15", noting the urgency of adopting a Global Biodiversity Strategy to stop the loss of biodiversity by 2030 and promote the recovery of natural ecosystems.

COMMITMENTS MADE
LISBON Green Capital GOAL DEGREE OF ACHIEVEMENT
LED lighting - Installation of LED lighting in all buildings (interior and exterior, if applicable) Ten. 2025 80%(1)
Photovoltaic Solar - Installation of photovoltaic solar electricity production equipment, in buildings with
adequate sun exposure and availability
Ten. 2030 100%(two)
Water reuse - Implementation of water reuse solutions Ten. 2021 100%
Single-use plastics Eliminate the use of single-use plastics Ten. 2021 100%
Awareness - Disclosure by employees and or associates of the Lisbon objectives regarding the
environment and climate action
Ten. 2020 100%
Electric vehicles - Increase the promotion of electric vehicles in fleets of private use vehicles and in
operational fleets.
2025: 30% 2030: 80% 5.5% (electric and hybrid)
Pool of cars - To have available to employees a pock of cars that can be reserved and used as needed
for business travel.
To have pool vehicles
for employee use
20.8% of the current fleet
Business Mobility Pact for the City of Lisbon (PMEL)(3) GOAL DEGREE OF ACHIEVEMENT
Electric vehicles - Increase the promotion of electric vehicles in fleets of private use vehicles and in
operational fleets.
2025: 30% 2030: 80% 5.5% (electric and hybrid)
Pool of cars - To have available to employees a poco of cars that can be reserved and used as needed
for business travel.
To have pool vehicles
For employee use
20.8% of the current fleet
Commitment Letter for Sustainable Financing GOAL DEGREE OF ACHIEVEMENT
Promote the debate on Sustainability and on environmental, social and governance risks and opportunities
at the level of the BoDs, with a view to considering these risks and opportunities when defining the
respective strategies.
2030 Reinforcement of the Commitment to
Sustainability defined in the 2024 Strategic
Plan
Promoting training in Sustainable Financing aimed at its employees at the different levels of the
organization, with a focus on the area of credit risk analysis, financial products, sales andfor production.
2030 In 2021, we carried out universal training on
Sustainability in Portugal, which is now an
integral part of the courses given to new
employees (5,815 employees in 2021 and 509 in
2022)
Monitor the review of the PME Lider and PME Excelência criteria, in order to gradually incorporate
sustainability issues into these criteria and accept the possibility of creating a PME Verde or PME
Sustentavel category
2030 Ongoing
Promoting the gradual integration of environmental, social and governance criteria in financing and
investment analyzes
2030 Ongoing
Monitor and participate in future work arising from the Reflection Group for Sustainable Financing 2030 Ongoing

Millennium bcp signs the Manifesto "Towards COP27" from BCSD Portugal, recognizing the importance of decarbonising development models and complying with the Paris Agreement

Sustainable Development Goals (SDG) of the United Nations

The SDG of the United Nations, approved in September 2015, represent the most significant global voluntary commitment - already formalised by 193 countries from the five Continents - and thrive at improving the quality of life of the world population - in the social, environmental and economical components - until 2030.

Considering that the accomplishment of its 17 objectives and of its 169 targets implies a joint effort from the States, the civil society and private entities, namely from companies, the Bank assumes the commitment of actively working towards a sustainable development, featured by social inclusion and responsibility in terms of environment, in all countries where it operates.

The justification for Millennium bcp's involvement in achieving the SDGs can be found, first and foremost, in the Bank's matrix and values, in particular its relationship of proximity to People and its capacity to add social value, but also in the search for innovative and inclusive products and distribution channels and in the spirit of service to the Customer and to the communities in which we operate.

BCP acknowledges that the SDG represent an unifying and aspirational reference framework that will enable to produce a new "social contract" and enhance changes imposed and required by the current economical, social and environmental situation.

Thus, within the scope of an ongoing process with which we intend to establish the relation - and identify the convergence points - between the Bank's activity, its ethical values and corporate culture and that recommended by the SDG, we have identified - and characterized across this report - the Bank's contribution for the accomplishment of the Goals and the way we are matching our value proposal in the different countries to the needs and expectations of the interested parties.

BCP identifies, at this stage, as a priority for the implementation of the 2030 Agenda for Sustainable Development, the SDG 1 (End Poverty), 4 (Quality Education), 5 (Gender Equality), 7 (Affordable and Clean Energy), 8 (Decent Work and Economic Growth), 10 (Reduce Inequalities), 13 (Climate Action), 15 (Life on Land) and 17 (Partnerships for the Goals Implementation).

Principles for Responsible Banking (PRB)

Within the context of the 2021 Sustainability Master Plan, Millennium bcp decided to join the United Nations Environment Programme - Finance Initiative (UNEP-FI) and subscribe its Principles for Responsible Banking (PRB), this way stressing its commitment to responsible investment policies and awareness of the impacts of its activity, both on society and on the planet. By joining UNEP-FI and subscribing to the PRB1 , Millennium bcp is committed to putting Sustainability at the heart of its strategy, integrating these Principles in its value proposal, processes and operations, in the different business and geographic areas.

In order to understand the level of alignment with the PRB, the Bank carried out an initial exercise to assess the positioning of Millennium bcp, of Bank Millennium and of Millennium bim, in relation to these Principles. In this exercise, it was possible to identify a number of actions to be considered, such as the analysis of the impact of the activity of Bank on people and on the environment using the Portfolio Impact Tool, recommended by the UNEP-FI.

The year 2022 marks Millennium bcp's formal subscription to the PRB (June) and, during this year, the bank continued to develop data collection and apply the Portfolio Impact Tool (support tool that was updated in 2022).

In 2023, Millennium bcp intends to conclude its impact analysis and prepare the first PRB report, in accordance with the Responsible Banking Reporting and Self-Assessment Template. This report will provide details of the BCP Group's progress in each of the six principles of the PRB. In Annex 6 of this report, we already provide, on a voluntary basis, preliminary information that will be used for the full report.

Science Based Targets

Assuming its role, as an organization and funding entity, in facilitating the global transition to a low carbon economy, Millennium bcp recognises the need to reduce its own greenhouse gas emissions in its operations and also of those deriving from its credit/investment portfolio. In this context, the Bank is internally assessing the possibility of setting science-based emission reduction targets, under the Net-Zero Banking Alliance (NZBA) and/or the Science Based Targets initiative (SBTi).

Both NZBA and SBTi are global initiatives that enable companies to set emissions reduction targets aligned with science and the level of decarbonisation required to meet the Paris Agreement goals.

1 PRBs were developed by UNEP-FI together with 30 founding banks and are considered six Principles of Responsible Banking: 1. Alignment; 2. Impact & Target Setting; 3. Customers & Customers; 4. Stakeholders; 5. Governance & Culture; 6. Transparency & Accountability. More than 300 institutions have already subscribed to the PRBs (February 2023).

Corporate social responsibility should stimulate a transformative dynamic for promoting decarbonised and resilient economic development models that, by fostering wealth creation and a new fair and inclusive "social contract", protect the planet, the climate and biodiversity

Partnerships

BCP, aware of the importance of sharing good practices, public testemony and of an active participation in the pursue of Responsible Business principles, is an associate and a member of the corporate bodies (Management and Executive Secretariat) and of the Advisory Board of BCSD Portugal - Conselho Empresarial para o Desenvolvimento Sustentável.

It is also a member of the Global Compact Network Portugal from the United Nations (GCNP) and, within a logic of proximity and support to the surrounding communities, of the Programme Oeiras Solidária (POS).

It also participates in a selected number of work groups and think thank forums on Sustainability and Sustainable Finance, a presence that should be understood within the scope of the Action Plan from the European Union, the ongoing alterations in the ruling and regulatory framework and the evolution of the risk and business management practices applicable to ESG issues, in what also represents an opportunity to (re-)assess impacts, anticipate trends, reinfor competences and project future transformations.

Thus, it is a member, among others, of the Working Groups (i) Regulatory Framework for Sustainable Financing of the APB - Portuguese Banking Association; (ii) Sustainable Finance of the EBF - European Banking Federation; (iii) Report and Sustainable Finance of BCSD Portugal, where it is one of the promoters of the website www.sustainablefinance.pt, and (iv) of the Specialised Committee on Sustainable Finance and Sustainability of the AEM - Associação de Empresas Emitentes de Valores Cotados em Mercado.

It also a member of: (v) the Technical Debate Group for Sustainable Financing in Portugal from the Ministry of Environment; (vi) the Technical Commission on Sustainable Finance ISO/TC 217 from APEE - Associação Portuguesa de Ética Empresarial and of ISO - International Organization for Standardization, (vii) the Task Force on ESG Taxonomy from APB and (viii) the International Chamber of Commerce (ICC) Working Group on Sustainable Finance.

After joining the Women's Empowerment Principles (WEP), formalised in 2020, Millennium bcp is also a member of the (ix) Steering Committee WEP Portugal since 2021, promoted by GCNP.

In 2022, we also joined the (x) Sustainability Working Group of the Business Roundtable Portugal Association (BRP).

Management of social and environmental risks

BCP has an annual process to identify, assess and manage more than 60 types of risks. ESG risks, which have acquired growing relevance within the scope of the Bank's activity - both due to the densification of the legal, regulatory and supervisory framework and requirements and to the deepening of good practices in risk management - are part of this process. The risk management process has been adapted in a manner consistent with the strategic priority given by the Bank to ESG issues, which is reflected in its Strategic Plan Superação 24.

Additionally, in 2022, the Bank developed its first materiality assessment of climate and environmental risks, thus deepening the understanding of these factors' impacts on the Group's activities, and integrating it in the definition of actions and decisionmaking for its management and mitigation, and in the identification of business opportunities that emerge in the dynamics of transition to a low carbon economy.

Millennium bcp's priorities and ambitions regarding social and environmental risks are also addressed in its Sustainability Master Plan, in particular in the risk management dimension, with lines of action and measures very directly related to the approach to risks and their integration in the business, among which the following stand out:

  • assess the impact of climatic and environmental, physical and transitional factors on the different risk typologies;
  • establish processes for monitoring the evolution of the climatic and environmental risk factors;
  • develop a management and control framework for climatic and environmental risks, including the definition of a governance model;
  • implement the capacity for climatic stress tests.

Note: more detailed information on climate and biodiversity-related risks is presented in the Environmental Responsibility chapter.

Sustainable Finance Disclosure Regulation (SFDR)

Sustainability and ESG factors are increasingly relevant topics for society, Customers and our business.

In line with the commitment to promote a culture of environmental, social and financial responsibility, namely in the fight against climate change and social inequalities, BCP Group has been working to disclose information on the integration of sustainability risks, in accordance with the provisions of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 (Sustainable Finance Disclosure Regulation - SFDR).

With the entry into force of the SFDR on 10 March 2021, it became mandatory to comply with a set of requirements and disclosures related to sustainability, with visibility on the entities website and in the documentation (pre-contractual and periodic) of the financial products.

The Bank involved the different areas of the organisation in the implementation of this regulation, from business, to risk and processes, and developed a governance model for the monitoring and follow-up of compliance with the requirements arising therefrom.

At the entiy level

Our ambition is to continue to be an active player in this change and, in this sense, we are committed to integrating ESG aspects in our operations, in our products and services and in the supply chain, positively influencing the long-term value of the organization, contributing to the well-being of people and communities and to the preservation of natural resources, the environment and of biodiversity.

It is with this purpose that BCP Group promotes the transparency of the reference framework applicable to ESG risks, disclosing the corporate Sustainability Policies and Principles on its institutional website.

BCP Group monitors and guides its action taking into consideration the legal and regulatory initiatives related to climate change as a systemic risk for the financial system, reinforcing the communication of the negative impacts for sustainability at its action level.

The ongoing monitoring of the prudential and supervisory areas, as well as the development of criteria and technical standards to be widely and unequivocally adopted in the market, are priorities to avoid imbalances in approaches adopted by companies, with potential disruptive effects on the financing of the economy.

We continue to identify risks related to climate change, in order to ensure the continuity of operations in the event of natural disasters able of causing the interruption of activities. We seek to understand the positioning of our portfolio in order to assess and promote its resilience in the transition to a low carbon economy. Over the years, we have been financing ecological and energy efficient projects, including projects related to the replacement of energy production from coal with low-emission energy sources, modern energy infrastructure, and emission reduction in polluting industries.

Environmental risk analysis is part of the Customer assessment, credit granting, project finance and discretionary portfolio management processes, and is therefore incorporated into our management policies, standards and procedures.

We do recognize the existence of sectors of activity or projects, which do not meet the commitment assumed by BCP Group in preserving the environment and biodiversity, promoting sustainable development and fighting climate change. Therefore, we consider in decisions the sector principles of financing and investment for industries with high exposure to environmental or reputation risks, and we do not finance certain activities or projects, as described in Principles for Responsible Financing.

BCP Group is also evaluated by the most relevant ESG indexes and analysts, including the S&P DJSI, Vigeo Eiris, MSCI, Sustainalytics, CDP, among others (see chapter Sustainability Indexes).

We continue to work on the introduction of improvements in our policies, processes and operations, in order to improve our positioning, which we want to be a reference, in the most relevant Sustainability indexes.

BCP's remuneration policy is reviewed annually by the Bank's management bodies and aims to make Employees and members of the management and supervisory bodies aware of the rules and principles underlying the Bank's remuneration management, thus promoting the transparency of remuneration policies with regard to the integration of sustainability risks.

For that purpose, it includes a set of rules of good governance, in the sense that it contemplates provisions aimed at ensuring an

alignment of its senior executives and remaining Employees with a sound and prudent management of the institution and that considers the interests of all its stakeholders, not promoting an incentive to risk-taking at levels higher than those defined by BCP, avoiding the creation, or contribution to the creation, of situations of conflict of interest and, through those rules and alignment, contributing to the ethical and sustainable development of the Company. These rules are detailed in the Remuneration Policies of the Employees of BCP Group and of the members of the Management and Supervisory bodies.

In the case of the variable remuneration of the Executive Committee and the Employees, one of the KPIs under consideration is the execution degree of the Sustainability Master Plan (SMP).

The Chief Risk Officer (Executive Director responsible for Risk) also has a performance indicator relating to the monitoring of climate and environmental risks.

In terms of investment products / services

Millennium bcp provides portfolio management and investment consultancy services that promote environmental and social characteristics, in which pre-contractual information is described:

  • how sustainability risks are integrated into the product selection and portfolio construction processes; and
  • the exclusion criteria and detailed analysis of products where identified sustainability risks may compromise their performance.

Detailed information on the disclosure of non-financial information according to SFDR is available on Millennium bcp's website Institutional/Sustainability/ Non-financial information.

ESG Ecosystem

COMMITMENTS REFERENCE FRAMEWORK GOVERNMENT MODEL CORPORATE REPORT
International Commitments Corporate Policies Administrative Council Reports
BU Global Compact
UN Principles for Responsible
Banking
Science Based Targets
· Women's Empowerment Principles of ·
the UN G. Compact
International Declarations
Sustainability Policy
Environmental Policy
Social Impact Policy
Human Rights Policy
Health and Security Policy Work
Diversity and Equal Opportunities Policy Sustainability policies
Anti-Corruption and Anti-Bribery Policy
Body responsible for approving the
Sustainability strategy
Ethics, Deontology and Sustainability
Committee
Follow-up and monitoring of
Executive Comission
Report and Accounts
Sustainability Report (includes
report on the United Nations SDGs and
on Climate / TCFD)
Mbcp Foundation Report
UN Global Compact
Communication on Progress
Statement from Business Leaders for
Renewed Global Cooperation - UN
Corporate Volunteering Policy
Positions
Body responsible for executing the
Sustainability strategy
G. Compact
· Guide to Human Rights (WBCSD)
National Commitments
Principles of Millennium bcp in tax
matters
Climate change
CEO
Responsible for implementing
Sustainability policies, initiatives and
Letter of Commitment for List of conditioned sectors
Code of Conduct and
commitments
Sustainability Committee
Sustainable Financing (MAAC)
BCSD Portugal Charter of Principles
Gender Equality Plan
PMEL - Urban Mobility
Code of Conduct Equality, Harassment
and Non-Discrimination
· Communication of Irregularities
Definition and monitoring of initiatives
to ensure the implementation of the
Sustainability Master Plan (PDS)
Lisbon Capital Verde 2020
National Declarations (most recent)
Manifesto "Towards COP27" (BCSD
BC & FT Risk Management Policy
Conflict of Interests Policy
Suppliers
Risk Committee
Definition of the global risk
management framework
PD
Manifesto " For a deal for Nature at
COP15" (BCSD PT)
Sustainability Guiding Principles for
Suppliers
Sector guidelines
Strategy and Objectives
2024 Strategic Plan
Sustainability Master Plan
APCADEC Code of Ethics DESC - Sustainability Areas

Relation with Stakeholders

2022 SUSTAINABILITY REPORT

Relation with Stakeholders

BCP Group defines strategies and pursues dynamic policies adjusted to the new challenges imposed by the interested parties with which it relates, materializing a business model based on an ongoing and transparent dialogue enabling to interpret, understand and integrate the expectations of its Stakeholders.

Material issue: STAKEHOLDERS MANAGEMENT

Stakeholders involvement and materiality analysis

The most recent 2022/2023 Stakeholder consultation process involved, through a representative sampling, the main interested parties, namely: (i) Shareholders; (ii) Customers; (iii) Employees; (iv) Community; (v) Suppliers and (vi) Media, in an exercise that allowed understanding their perception of the significance of the Bank's impacts, but also their main needs and expectations regarding the organisation's performance in terms of sustainability. The consultation contributed to the (re)definition of material issues for the Bank, reflected in the new Materiality Matrix and the Sustainability Master Plan.

The strategy of Millennium bcp in terms of Sustainability is translated in the Sustainability Master Plan (SMP), a plan of commitments that aggregates a number of actions to be carried out by the Bank. The guidelines and definition of the initiatives that make up the SMP result from the balancing and juxtaposition of the relevant material issues, the available resources and the regulatory, economic and market framework.

After having defined in 2009, for the 2010/2012 three-year period (later extended to 2013), the first SMP of Banco de Portugal, in 2013 a new SMP was drawn up and approved for the 2014/ 2015 three-year period, which meanwhile was considered appropriate to extend until 2018. In 2019, the 2019/2021 SMP was developed and approved, whose identification process of material topics included: Stakeholders' consultation; consultation and analysis of studies - financial sector trends; most relevant and frequent issues - Analysts; inheritance of the previous SMP; and consultation with the organic units with direct intervention in the topics included in the perimeter of the Sustainability policies and which saw its deepening ensured by the 2022 SMP.

Also in 2022, based on a new consultation with Stakeholders, benchmark analysis, interpretation of external analysts' recommendations and evolution of the regulatory framework, the new SMP was defined and approved, which will guide us in 2023.

The Sustainability Master Plan (SMP) translates the sustainability strategy and the main action areas of Millennium bcp in this dimension

Materiality Matrix

Thematic materiality analysis is the regular process through which the Bank determines which issues are most relevant from the point of view of sustainability, guiding not only the information it disseminates on these aspects, but also the development of strategies and action plans. The Bank's 2022/2023 materiality analysis responds to the new regulatory guidelines, arising from the Corporate Sustainability Reporting Directive (CSRD), regarding double materiality.

The materiality analysis process is structured in four main phases, summarised in the diagram below:

The materiality analysis was conducted according to a double materiality perspective, as referred to above, crossing two perspectives of equal importance:

  • Impact of Millennium bcp (Impact Materiality) measured by consulting Stakeholders who gave their opinion on their perception of the significance of the Bank's impacts.
  • Impact on Millennium bcp's ability to create value (Financial Materiality) measured by consulting members of top management, who gave their opinion on the significance of the impacts on the Bank and its ability to create value.

This exercise resulted, among the 22 subjects under assessment, in a list of 12 material subjects (11 governance subjects and 1 social subject), reviewed and approved by the Executive Committee of Millennium bcp, which helps to delimit the contents presented in this Report, but also to guide the development of plans and strategies with an impact on the Bank's future action.

Materiality Matrix of Millennium bcp

Size Subjects Upstream
Subject with
impacts up
stream of the
Bank
Bank
Subject with
impacts on
the Bank
Downstream
Subject with
impacts down
stream of the
Bank
Financial Ma
teriality
Impact Mate
riality
Governance Cyber-security, pri
vacy and infor
mation protection
Governance Innovation and digi
talisation
Governance Ethics, conduct and
compliance
Governance Anti-corruption and
anti-money launder
ing
Governance Transparency of the
information pro
vided to customers
on products and ser
vices
Governance Sustainability Gov
ernance
Governance Resilience of the
business model
Governance Risk management
Governance Satisfaction and cus
tomer experience
Governance Brand management
and reputation
Governance Economic perfor
mance
Social Attracting, develop
ing and retaining tal
ent

The identification and continuous monitoring of the subjects considered material - as was done in 2019 and now in 2022 - has made it possible to identify the areas of action that should be recognised as a priority for the Bank in the field of Sustainability and has also made it possible to quickly identify and characterise opportunities for improvement, making a strong contribution to adapting the Sustainability strategy to new realities, challenges and requirements.

The SMP, an integrating instrument which, through a transparent, close and consistent relationship, seeks to respond to the expectations identified in the regular consultation of the Bank's main Stakeholders, foresees, in its different aspects, dimensions and lines of action that are presented below.

Material issue:

BUSINESS MODEL RESILIENCE

2022 SUSTAINABILITY MASTER PLAN (SMP)

Size Actions lines
Sustainability Governance Model
and Corporate Policies
- Redefine the governance model of the Sustainability Areas that allows multidisciplinary and trans
versal action to the organization, including, whenever justified, the international operations
- Review and update the Groups corporate policies
- 2023 Sustainability Master Plan
- Develop comprehensive internal policies, in accordance with the Target Operating Model
Brand management and reputa
tion
- Strengthen Millennium bcp's positioning in sustainability indexes
- Join sustainability principles and commitments
- Reinforce communication and dissemination of Microcredit
Service quality and customer sat
isfaction
- Optimise satisfaction levels
Responsible management of sup
pliers
- Formalise compliance with social and environmental requirements in the relationship established
with Suppliers
Compliance with requirements
and reporting best practices
- Improve the reporting on sustainability, ensuring the alignment with relevant requirements and
references
Responsible supplier manage
ment
- Formalise compliance with social and environmental requirements in the relationship established
with Suppliers
Policies and regulation of
sustainable financing
- Monitor the development of the Action Plan for Sustainable Finances of the European Commission
- Monitor the business strategy in line with climate and environmental risks
Raising awareness and informing
customers on products and ser
vices
- Integrate aspects of sustainability of the proposed investments into communication with customers
Risk management - Ensure skills to manage ESG risks
- Ensure the integration of environmental and social risks in the process of risk analysis
Offering inclusive and sustainable
products
- Develop an ESG product offer that promotes the transition of the economy towards a sustainable
model
Attracting and retaining talent - Support the adoption of healthy lifestyles
- Improve the mechanisms ensuring a greater proximity between Employees and senior management
- Development of the balance between work - family
Volunteer Actions - Volunteer programme
Human Rights - Analyse and communicate positions on human rights risk management
Financial literacy - Financial literacy programme
Investing in the community - Develop campaigns together with NGO/IPSS (charitable institutions) in the scope of sustainable
development
- Reinforce the role of the Foundation as a Social Action Vehicle
Climate change, energy efficiency
and alternative energies
- Contribute to limiting global warming in line with the Paris Agreement

We shall present, in the following chapters, the most relevant initiatives carried out during 2022 together with the results obtained and the performance reached by the Bank in the several material issues identified in the materiality matrix. The 2022 Annual Report presents the performance of the BCP Group in the following issues: Governance Model, Risk Management and Shareholding Structure in the respective sections – Governance (and Corporate Governance Report), Risk Management and BCP Share.

The Sustainability Report, together with the Annual Report, both annual, ensures therefore the disclosure of the most relevant information on the BCP Group's performance in the material issues identified by its main stakeholders.

MAP SHOWING THE EVOLUTION OF SOCIAL PERFORMANCE BY LOCATION

Economic and governance responsibility

Economic and governance responsibility

BCP Group has been developing its activity in a responsible manner towards Employees, Customers, Shareholders, Suppliers and remaining Stakeholders, always guiding its performance by the compliance with internal principles of rigour, the applicable legislation and the regulations issued by the supervision and regulatory authorities:

SDG Our goals Our contribution in 2022
Developing employees'
personal and profes
sional skills
Stimulate training actions and skills development
Initiatives:

Millennium Banking Academy - development and training programmes with the aim of
supporting the Bank in its mission and in the development of the defined strategic plan.

Rúbrica DigitalMente - project developed with the objective of increasing the digital lit
eracy of employees through the sharing of 30-minute videos on the Bank's technological
projects and on what's new in the digital market.
Results:

10,176 training sessions

716 thousand training hours

45 training hours per employee
Strengthen the Bank's
position with regard to
the promotion of gender
equality and non-dis
crimination
Promoting gender equality
Initiatives:

Stimulate discussion and reflection cycles aimed at women.

Signatory to the Commitment Agreement of the Organisations Forum for Equality (Igen).

Subscription of the WEPs (Women's Empowerment Principles) of the Global Compact UN
Results:

55% women employees

35% women on the Board of Directors

25% of women in Management positions (Executive Committee/Senior Management and
Management):
o
23% in Portugal
o
58% in Poland
o
29% in Mozambique
Promote financial inclu
sion products that sup
port productive activi
ties, the creation of jobs
and entrepreneurship
85 jobs generated in Portugal in 2022 by offering microcredit
Initiatives:

SAF packs (Financial Advisory Service) - contemplates solutions for restructuring and con
solidation of credits, with the purpose of preserving the financial stability of private cus
tomers.

Microinvest Line and Invest+ Line - to finance projects that enable unemployed people to
start-up businesses.
Results:

63 entrepreneurs supported under the support lines for business start-up projects by the
unemployed.
Protecting labour rights
and promoting safe and
secure work environ
ments for all employees
Promotion of a safe and secure workplace
Initiatives:

Medical units and a dedicated medical staff on the premises.

Special Support Fund for Employees in case of coronavirus infection.
Results:

182 visits by occupational safety and health officers to the premises

Millennium Network

Millennium bcp is a Bank with a decision centre in Portugal and is the largest private Portuguese bank, counting in 2022 around 6.5 million active Customers served by a network of 1,239 branches. The international activity of Group Millennium is carried out by banking operations headquartered in affinity markets and in countries with a recognized growth potential – Poland and Mozambique - where it operates, under the Millennium brand, with 832 agencies.

Active Customers: First holders with, at least, 1 product with a balance > 50 cents, in absolute value and with card transactions in the last 90 days or with financial assets ≥ 100 euros.

Moreover, Group BCP also ensures a presence in the five continents by means of representation offices, branches, business protocols and business promoters.

In 2022, Millennium bcp registered 6.4 million active customers, of which 2.6 million in Portugal

Accessibilities

BCP Group is constantly seeking to be near its Customers by means of diversified distribution channels – Branches, Internet, Call Centre, Mobile Banking, ATM and POS – to adequately respond to the contact needs between the Customer and the Bank.

REMOTE CHANNELS AND SELF-BANKING (active users)

Internet Call Centre Mobile Banking ATM (*) POS (**)
Portugal 516 889 251 863 1 211 432 1 915 86 121
Poland 2 233 149 225 133 2 291 524 509 2 828
Mozambique 12 647 2 269 790 881 519 8 469
TOTAL INTERNATIONAL 2 245 796 227 402 3 082 405 1 028 11 297
TOTAL FOR THE GROUP 2 762 685 479 265 4 293 837 2 943 97 418

Note: Those that use internet, the call centre or mobile banking at least once in the last 90 days are considered active Users. Does not include Customers from Activo-Bank.

(*) Automated Teller Machines

(**) Point of Sales (SIBS information)

As part of its social commitment, it promotes accessibility for people with special needs to the Bank's various contact channels: i) branches with access for people with reduced mobility; in Portugal, as well as in the Group's other operations, there is a policy of priority service in the entire branch network; ii) Internet with features that respect the recommendations issued by the Web Accessibility Initiative (WAI); in Poland, Bank Millennium was the first Bank to receive the certificate "Internet site without barriers" and iii) ATM, through the placement of equipment with facilities available for the blind, such as headphone connections and keys with programming for issuing vocal instructions. The Call Centre, available 24 hours per day in several languages and Mobile Banking, for the rapid and easy access that they represent, are also privileged access channels for disabled or blind persons.

In Poland, the programme "Banking without Barriers" continues to be one of the main social programmes carried out by Bank Millennium. The idea of a bank without barriers, with products and services accessible to all, without exception, is not only a Corporate Social Responsibility programme, but also a philosophy of the organisation and an important component of the Bank's business strategy. It is with this reference framework and the use of innovative technological solutions that Bank Millennium has tried to eliminate infrastructural, digital and physical barriers, in access to financial and non-financial services.

In most recent years Bank Millennium has won the "Wrocław without barriers" award in the Corporate Social Responsibility category. This Certificate was awarded to Bank Millennium for solutions that enable the use of digital banking, for the implementation of functions aimed at people with disabilities and for conducting training actions on serving people with special needs. Organisers also appreciated the Bank's efforts to build a socially responsible brand.

Bank Millennium is not only a financial services centre for Customers. It is also the first integrated access channel to other services, such as the mobile application, a solution where it is possible to buy municipal transport tickets, pay for parking or drive on the motorway without having to stop at toll gates. Electronic banking also allows customers to use their digital identity to establish remote contacts with government agencies.

Following the outbreak of war in Ukraine, a dedicated area was launched on the Bank's Ukrainian-language website containing important information on how to open an account and on the rules of using the Bank's services. Ukrainianspeaking customers can also complete applications for more than 500 benefits in their language and receive communications on important issues, for example cyber security.

Mobile banking solutions, which in the whole of the BCP Group already have more than 4.2 million users (3.7 in 2021), substantially reinforced their role as the preferred channel for access to products, services and financial transactions.

The Branches continue to represent a relevant contact channel for many Customers. In this context, BCP Group diversifies its opening hours in the different countries where it operates, responding to Customers' accessibility needs and requirements. Within this scope, we highlight the Branches that give access to disabled individuals, which correspond to 87% of the total network in Portugal and to 56% in the remaining countries. In Portugal also, 145 branches have differentiated office hours going from 8.30 a.m. to 7.00 p.m. In Poland, the number is 84 branches and in Mozambique 28. We must also mention the opening of Branches on Saturday, extended working hours that, abroad, can be found at a total of 158 branches (4 less than in 2021) representing in the case of Mozambique more than 39% of total.

Branches accessibilities (Number of branches)

In Portugal, Millennium bcp continues to revolutionize its branch network. The Customer Branch Experience 2.0 of Millennium bcp is an innovative approach focused on the customer, made through a cultural change, the re-design of products and processes and the integration of digital channels.

In this new generation of Branches, paper continues to no longer be used and the formalization documentary of agreements is replaced by digital signatures through tablets; the treasury activity is available 24 hours a day with the new smart transaction machines, the first to allow the automatic payment of cheques at any time, as well as withdrawals and deposits of coins. This equipment can also be used without a Multibanco card. The Customer only has to use the multichannel code provided by the Bank.

Apart from the technological innovation, the Branches also offer spaces especially devoted to Customers, with lounge areas, free wi-fi, wireless chargers and areas providing digital experiences with access to the Bank's apps. The communication with Customers is also innovative, with a digital price list and electronic advertising panels.

Within this context, the Bank already has 39 branches with this new layout in the entire country, a process that, within the context of the global renewal and modernization of the Branch Network, will be pursued during the next few years.

Innovation

Material theme:

INNOVATION AND DIGITALIZATION

The relationship between Customers and their Bank, and with Banking in general, has been changing significantly. This change has several origins and explanations, of which technology and the appearance of new players that open up new possibilities and options for Banking Customers stand out.

The opportunity cost of not being part of this evolutionary movement, serving customers in different segments with different needs, is still perceived as too high to be ignored by banks.

At Millennium bcp, the mobilisation of talent and the Bank's digital transformation, fundamental pillars of the strategic plan defined for 2021-2024, have made it possible to empower the Bank with tools, knowledge and new working methods that, combined, contribute to our ability to act and respond quickly and effectively to the challenges we face on a daily basis.

2022 was a year during which we continued to improve the digital experience focused on mobile. We have invested in increasingly efficient and innovative digital journeys, provided new functionalities and added-value services that simplify the Customer's daily life and reinforced the communication strategy, which is increasingly customised and targeted. The consistent bet that has been made on the App has enabled the consolidation of this channel as the central platform for the Customer's banking relationship. The materialisation of this strategy is reflected in the recurring leadership in the evaluation of the banking Apps (IOS and Android), in which the Millennium App registers 4.8, on a scale of 0 to 5, in both stores.

In Individual Customers, we kept the growth trend of the Digital Assets base, with a variation of 13% compared to the same period of the previous year, to which the 18% growth in App channel users contributed decisively, representing already about 83% of all Digital Customers.

This vision of the Bank's digital transformation includes different priorities, worthy of note in 2022:

  • Account Opening: we recreated the video call journey and it became possible to open an account with a digital mobile key;
  • Digital Mobile Key: i) The possibility for customers to request access codes through the Millennium App via Digital Mobile Key or Telephone Call was implemented; ii) the telephone call flow uses this resource to prove the users' identity, while Digital Mobile Key does this authentication immediately;
  • Cards: We entered the world of "Buy Now, Pay Later" and started to allow fractionated payments for purchases made with Millennium bcp credit cards after the purchase, and at the moment of purchase with 3D Secure and MB Way at the sales point and e-commerce.
  • Home Loans: i) Tracking of Home Loans: Includes progress of the credit application that the customer has in progress (what stage it is at and what the next steps are), and the possibility of viewing the entire history associated with the credit process, from application to contracting; ii) Digital approval letter: With this new development we implemented the flow of the approval letter that will allow the Customer to issue and accept the approval letter in the digital channels, without having to go to the branch. This way, it will be possible to access the flow through the home loan tracking functionality, when the process reaches the "Awaiting signature of the letter" stage in the "Final Conditions" phase.
  • Personal Credit & Insurance: i) Availability of a renewable energies personal credit journey in the Millennium App whose purpose is to finance the acquisition of equipment that produces or stores renewable energy (e.g. photovoltaic panels, batteries, heat pumps). With an end-to-end digital journey, the customer simply requests the credit, receives the decision on the spot and then uploads proof of purchase (order form or proforma invoice) to formalise the operation on the spot. Funding is made available after the Bank validates the documentation uploaded by the Customer; ii) Availability of PPP (Payment Protection Plan) Insurance: We improved the security offer for those who make a consumer credit online by providing the possibility of subscribing to payment protection insurance.
  • Investments: i) Journey of ETFs with social and environmental considerations: includes the possibility of consulting extensive information on these ETFs and transmitting buy or sell orders; ii) Journey of PPR (Retirement Savings Plan) subscription: Includes information and portfolio consultation, simulation and subscription; iii) Investment Hub: New investment area with financial literacy articles, with the provision of new features and where customers now have the possibility to consult their investment portfolio and access the products available to trade.
  • Launch of the "ESG Data Platform" project aimed at developing a platform to aggregate the data underlying the reporting needs of the ESG (e.g., Green Asset Ratio) and also to support business needs in the sustainability area. The ESG Data Platform is based on an architecture that guarantees the correct updating and centralisation of data and will have a component for automatic generation of reports, avoiding, whenever possible, manual intervention in the ESG reporting process.
  • Re-engineering of processes with new workflow solutions that allowed most of the requests addressed to the Millennium Operations Centre to be made through the service catalogue workflow, instead of using email and telephone, saving resources and reworking and promoting marked improvements in Customer Service levels.
  • Use of Robotic Process Automation (RPA) technologies for the main credit operations.
  • Reduction of local printing and digitalisation of incoming processes, with opening of operations directly in the systems and applications, avoiding the physical circulation of documents.
  • Support to the business of all Commercial Networks, through a more comprehensive model of contact management via chat - chatbot MAX -, for more effective responses on a 1st contact. MAX was a pioneer in the Bank for being the 1st Chatbot to use artificial intelligence, allowing the recognition of human conversation and providing an appropriate response to its users' doubts;
  • Multidisciplinarity and new skills in the Teams, as well as the implementation of telework and differentiated schedules to better serve Customers.

In Poland, Bank Millennium is one of the leaders in innovation. Customers can choose between several payment methods without a card or wallet. They can use HCE contactless payments, Apple Pay, BLIK, pay for online purchases with a BLIK code and withdraw cash from an ATM with a code. In 2022, Bank Millennium was the first bank on the market to launch a pilot of a new deferred payment service: the BLIK Płacę Później aligned with the Polish payment standard. Customers using an Apple Watch can pair their watch with the app and use, among others, a BLIK code or mobile authorisation.

Bank Millennium has been the most versatile organisation in the Polish financial market in implementing open banking solutions The Bank offers the option to add accounts and request transfers from other banks; it also uses open banking in sales and acquisition processes (opening of individual and corporate accounts).

In 2022, two new banks were added to the open banking services, currently the 11 largest Polish banks are available on Finance 360º, Bank Millennium's account aggregation service. The transfer form presented to a customer with aggregated accounts presents a list of the most recent transfer beneficiaries, which include beneficiaries of transfers ordered at other banks. When the customer selects a beneficiary from this list, the system automatically fills in the transfer form with the beneficiary's details, even if the transfer was made at an external bank.

The Bank uses open banking in its campaigns targeting customers and in processes involving, among other things, creditworthiness analysis, also looking for new opportunities offered by the PSD2 directive.

Information Security

Material issue:

CYBERSECURITY, PRIVACY AND INFORMATION PROTECTION

The information security programme implemented at the Bank is oriented towards the protection of information, taking into account confidentiality, integrity and its availability in accordance with legal and regulatory requirements.

Information is protected in a manner that is consistent with its importance, value and sensitivity so as to increase the Group's resilience and ensure the protection of stakeholders, reputation and the activities for the creation of value.

The information security policy sets forth the guidelines for the implementation and maintenance of the information security program of Millennium bcp. It is based on a structured set of policies, rules of procedures and standards, aligned with international good practices, namely the regulation ISO/IEC 27001 - Information security management systems – Requirements and with the guidelines EBA/GL/2017/05–Guidelines on ICT Risk Assessment. The information security policies are approved by the Executive Committee and are revised every two years, or earlier if there are changes in the internal environment that justify it.

This information security programme is oriented towards information security risk management and is supported by a set of fundamental general principles aimed at information protection, namely information security governance, human resources security, information security awareness, classification, protection and handling of information systems and communication security, security in application development and maintenance, information system access control, information security incident monitoring and response, security assessment of external service providers, information security risk assessment, and recovery capability. In 2022, the information security risk management model was consolidated with the integration of the results of the annual exercise in the Bank's operational risk framework that is oriented to the Bank's business processes.

The Bank has an Operational Resilience Commission that meets every two months with the objective of analysing cybersecurity metrics and providing visibility on the main relevant issues in this context. Among the different subjects covered, cybersecurity metrics stand out, including the cybersecurity rating, the vulnerabilities identified, the attempted attacks contained, the results of the continuous penetration testing process and the monitoring of attacks suffered by the Bank's customers.

To prevent, detect and mitigate intrusion attempts, illegal acts and new threats, the Bank has invested heavily in 24x7x365 security monitoring with the implementation of a Security Operations Centre (SOC) and a Threat Intelligence service, in the information security incident response process and in continuous and regular risk assessment processes of the information systems that support the business. Despite the high number of security events that are detected daily, during 2022, 1 denial of service (DDoS) security incident with relevant impact was recorded, which affected the availability of the Bank's channels for 2 hours, with no sign of compromise of the information systems during 2022.

The Bank has a vulnerability management process that is supported in the execution of intrusion tests in continuous mode on sites and Apps exposed to the Internet and monthly vulnerability scans on the internal network, with the objective of

detecting weaknesses, classifying and correcting them in accordance with a plan that prioritises their correction with SLAs (Service Level Agreement) defined according to the risk level.

Considering that Information security is a responsibility of all, Millennium bcp promotes a regular process of information security awareness addressed to all employees and Customers of the Bank, covering a set of relevant items, namely the main information security policies and the risks and threats we are all subject to on a daily basis, within an approach based on practical examples of e-mail, Internet and phishing. In addition, simulated phishing and social engineering attacks are carried out aimed at employees and outsourcers, to assess and reinforce the maturity level in information security, in order to build a more resilient and secure organisation. All new employees are targeted by the regular information security awareness programme.

Also as a result of the macro-initiatives of the cybersecurity strategic plan, in 2022, Privileged Access Management (PAM) and Vulnerability Management solutions were implemented and existing solutions, such as Security Information Event Management (SIEM) & Security Orchestration, Automation and Response (SOAR), were renewed and reinforced.

Also during 2022, Millennium bcp continued the implementation of the 2019-2022 strategic cybersecurity plan, approved by the Executive Committee, with the goal of implementing the new security solutions that were identified and strengthening the current ones, to mitigate the existing risks, consisting of the following macro-initiatives - Cyber Risk, Strategy & Assets, Organization & People, Governance & Cybersecurity by Design, Cloud & Infrastructure, Application Security, Digital Identity, Data Privacy & Protection, Cyber Defense and, in this context, implemented the Integrated Cyber Defense Platform (ICDP) project which added a wide range of features that contributed to increasing the resilience of information security in the fields of information protection, protection against threats and information security management.

To reinforce the existing monitoring mechanisms, Millennium bcp joined the BitSight platform. This platform continuously collects and analyses data on the security behaviours and implementation of security policies of associated companies, identifying indicators of compromise ( for example, infected machines, inadequate configurations, incorrect user behaviour) to determine the BitSight security rating.

Companies are rated on a scale of 250 to 900, the ratings are updated daily and are available on the BitSight platform. The higher the classification is, more efficient is the company in the implementation of good practices in cybersecurity. The BitSight security rating enables obtaining an indication on global cyber security performance of the Bank and to compare it with the one from the Portuguese banking industry. During 2022, Millennium bcp consistently maintained one of the best cybersecurity ratings (810) of Portuguese banks.

The evolution of Millennium bcp's BitSight security rating over 2022 was as follows:

Additional reference must be made to the business continuity management system implemented at the Bank, through which it ensures the availability of the processes and systems supporting more critical business.

Initiatives, projects and training processes carried out in the field of Personal Data Protection in 2022:

  • ✓ Regular news was published on the Intranet on issues related to Privacy, Security and Data Protection;
  • ✓ Launch of the initiative with an educational component on the essential aspects of Data Protection "Learn to Win": 4 editions were launched with 684 participations and 12 winners;
  • ✓ 4 "Bom Dia Retalho" videos were produced and disclosed to raise awareness on Privacy and Data Protection issues;

  • ✓ Publication of 2 Newsletters with the disclosure of ongoing projects, opinion articles, testimonies of Organic Units involved, Tips and Good Practices, activities of the Office of Personal Data Protection and other related news;

  • ✓ Participation in 3 waves of the "Mystery Customer", to evaluate customer service behaviours in branches, within the scope of Privacy;
  • ✓ Launch of universal course on Data Protection, attended by 6,933 Employees and Outsourcers.

Shareholders

Millennium bcp provides a space to its shareholders, the "Shareholder's Club", through which it intends to be closer to those who own stakes of its share capital. Through the Millennium bcp's Shareholders Club, individuals holding Banco Comercial Português shares deposited in Portugal may establish a closer communication with the Bank where they invested. Apart from being able to subscribe available products and services at preferred conditions, they also gain access to benefits and discounts agreed between Millennium bcp and its partners.

In 2022, 328 discount vouchers were issued in the scope of the 166 established offers/ partnerships.

The access to the "Millennium bcp Shareholder" area has no cost and is hosted in a specific area of the millenniumbcp.pt website, allowing the access to highlighted information regarding events and activities of the BCP Group, as well as information directed to investors and a newsletter specially produced for the Shareholders.

Employees

In line with the Sustainable Development Goals (SDGs) of the United Nations.

Material issue:

ATTRACTING, DEVELOPING AND RETAINING TALENT GRI 405-1

Group BCP gives to all its employees a fair and equal treatment, with equal opportunities, promoting meritocracy in all stages of their professional careers, defining the remuneration of the employees in accordance with his/her category and degree of compliance with the established goals and the salary ratio of 1:1 between men and women with comparable functions, levels of responsibility and professional paths.

The general principles ruling the BCP Group contain values and performance guidelines applicable to all Employees resulting in an express orientation so that, regardless of their hierarchical level or responsibilities, all Employees act in a fair manner refusing any discrimination but also in the reaffirmation of the alignment with the ten Global Compact Principles of the United Nations - of which it is a Signatory -, according to which the Group recognises and supports the freedom

C

of association and the right to the collective negotiation of work contracts and rejects the existence of any form of forced and mandatory work and of child labour.

In the context of Human Rights, BCP Group prevents the risk of violation of these rights, among other mechanisms, through the mandatory compliance of its employees and partners with the Code of Conduct, in which this issue is regulated, also allowing the anonymous communication of violations in this regard. On the other hand, the relevance of this issue for the Group justifies its inclusion in the Organisation's Risk Management, namely in Operational Risk, in the categories of Employee Relations (R3), Breach of Health and Safety Regulations (R4) and Employee Discrimination (R5). In 2022, and as in previous

years, the results of the Operational Risk Self-Assessment show the low level of exposure to these risks (level 2 on a scale of 1 to 5) in its main geographies.

The commitments undertaken by the BCP Group within the scope of human rights, labour conditions and equal opportunities are also enshrined in the corporate policies, of which the policies on (i) Human Rights, (ii) Diversity and Equal Opportunities and (iii) Occupational Health and Safety are an example. These policies are available for consultation on the Bank's website, in the Sustainability area:

https://ind.millenniumbcp.pt/en/Institucional/sustentabilidade/Pages/cod\_internos.aspx

Within the scope of the gender diversity of the Board of Directors, in 2022 BCP had 35% women in its composition.

Age breakdown by gender

Within the scope of gender diversity in management functions (Executive Committee/Senior Management and Management) in 2022, globally, 44% of these functions were performed by women – 23% in Portugal, 58% in Poland and 29% in Mozambique. In commercial functions, this figure increases to 62% in the Group, i.e. 49% in Portugal, 74% in Poland and 60% in Mozambique.

The promotion and guarantee of equal opportunities, namely in what concerns gender parity, is present in all actions developed by the Bank and translates into a balanced flow of recruitment and comparable professional progression opportunities and is patent in both the Gender Equality Plan that the Bank has published annually and in the Strategic Plan "Superação 24".

Millennium bcp is also a signatory to the Commitment Agreement of the Organisations Forum for Equality (IGen). This Forum, promoted by the Commission for Equality in Labour and Employment (CITE), aims to encourage its members to implement concrete and tangible actions to ensure gender equality.

Whereas in Poland, Bank Millennium, reaffirming its commitment to respect and promote diversity among Customers and Employees, is one of the companies signing the Diversity Charter of the European Union, coordinated locally by the Responsible Business Forum, having integrated, in 2022, the "Europe's Diversity Leader 2023", a ranking prepared by the Financial Times and Statista.

In 2021, Millennium bcp joined the Women's Empowerment Principles (WEPs) of the United Nations Global Compact, an important international platform for promoting gender equality. The Bank is also a member of its Steering Committee in Portugal, promoted by the Portuguese Global Compact Network.

In 2019, Millennium bcp had already subscribed the "CEO Guide to Human Rights" an initiative from the World Business Council for Sustainable Development (WBCSD) and from the Business Council for Sustainable Development (BCSD Portugal).

In 2023, BCP was included, for the fourth consecutive time, in the Bloomberg Gender-Equality Index, joining the group of companies worldwide that stand out in the implementation of practices and policies of gender equality, diversity and inclusion.

Millennium bcp undertakes active social responsibility policies to comply with the legal provisions that promote equal opportunities and rights in terms of gender, sexual orientation, culture, ethnicity or religion, and also in terms of the positive inclusion of people with disabilities with a disability degree equal to or greater than 60%. Towards a more diverse and sustainable organisation, we continue to remove barriers to the recruitment of people with disabilities.

In Poland and Mozambique, in addition to the offer of products and services

directed at Women, initiatives are also developed, such as debates and reflection cycles, on the positioning of Women in society, in the economy and in companies.

As part of the strengthening of proximity mechanisms between Employees and senior management, in addition to visits by members of the Executive Committee to branches and central services, regional meetings were held with Employees.

Strategy followed in 2022 for managing and recruiting employees

Millennium bcp aspires to lead the digital transformation of the banking business in Portugal, through the best talent. Aware that the development of skills and renewal of talent are fundamental pillars for achieving the objectives and the desired prosperity, the Human Resources team's performance during 2022 reflected a constant concern and alignment with the initiatives of the 2021-24 strategic plan.

Attracting, recruiting, developing and retaining the best talent embodies, in an integrated way, the great challenge to which answers have been found in a complex and dynamic context, through the following key initiatives:

  • Hiring the skills of the future and redesigning partnerships with universities;
  • Developing skills in the current workforce and fostering a culture of continuous learning, through development programmes, the digital academy and leadership alignment;
  • Implementing new ways of working, adjusted to the growing demand for flexibility in the market;
  • Managing talent appropriately: investing in Employees onboarding as a distinctive experience, following up closely, providing attractive growth opportunities for high-potential young people and carrying out strategic succession planning at the same time;
  • Following the path of inclusion and the search for talent diversity, ensuring the right balance in recruitment and career progression opportunities, and promoting gender equality, including in leadership roles.

To meet the challenge of leading the digital transformation of the banking business in Portugal, through the best talent, the strategic plan covers the hiring of new skills in the fields of digital, technology and analytics. The Bank uses external recruitment only when a specific need cannot be filled internally.

In External Recruitment, the value proposition of Millennium bcp as an employer includes the integration of young talent in the inGenious programme, providing them with a unique development opportunity. This programme allows participants flexibility in choosing their technical training plan and also includes a behavioural training component, which promotes good integration and helps these young people to fully experience Millennium bcp's culture.

Whereas in Bank Millennium the recruitment processes are based on internal norms supported by specific IT systems, in order to guarantee quality, efficiency and transparency in recruitment and selection.

The Bank uses different solutions to select and recruit high potential candidates in the market. Most processes are carried out by the Human Resources Division based on passive and active recruitment methods. For special projects, the Bank relies on the support of external recruitment agencies.

In 2022, Bank Millennium continued its cooperation with renowned universities, including the Warsaw School of Economics and SWPSUniversity of Social Sciences and Humanities. As a member of the Partner Club of the Warsaw School of Economics, Bank employees actively participate in meetings with the Council of the WSE Partner Club, in which the university's strategy and the possibilities for training students in skills relevant to the labour market are assessed. The Bank, as a teaching partner of the computer science course at SWPS University of Social Sciences and Humanities, presents students with practical solutions in the field of User Experience. This cooperation enables the Bank to better prepare professionals for the job and attract talent. Through its presence and involvement in universities, the Bank strengthens its image and builds brand loyalty among students and graduates.

The Bank's employees regularly and actively participate in academic events such as job fairs, conferences, debates or workshops, where the Bank presents itself as a stable and modern organisation.

In spring this year, the Bank started participating in the Absolvent Talent Days job fair. The fair was organised in four locations: Kraków, Wrocław , Poznań and Warsaw. It was an opportunity to tell students directly about what it is like to work at the Bank, in which areas they can develop, what the recruitment process consists of and what the advantages of working at Bank Millennium are.

The Bank also became a partner in the "Career Days" programme of the Faculty of Management of the University of Warsaw. Representatives of the Recruitment and Development Team had the opportunity to present offers of summer internships at the University. Direct meetings with students allowed many contacts to be established and helped students to adapt their courses to the Bank's areas of professional specialisation.

The Bank has taken the role of partner and participant in several conferences, where young people can gain knowledge and find professional inspiration, such as:

  • the discussion on the future of ESG as part of the "Warsaw University Business Conference" organised by the Academic Club of Real Estate Law of the University of Warsaw, Academic Club of Economic Strategy of the University of Warsaw and Academic Club of Finance Students of the University of Warsaw;
  • the IT Azure Summit 2022 Conference dedicated to the Microsoft Azure cloud. The Bank representative spoke about the role of the Feature Store in the feature management process and its application in the Azure cloud. 538 participants attended the live presentation, which included a large group of students and graduates from several higher education institutions specialising in technology;
  • the Code Europe conference for IT experts. Our expert spoke about the software development approach as part of the panel discussion "Effective development execution: minimum value product".

Practice leads to perfection - is the title under which the new edition of the internship programme aimed at students and graduates of higher education institutions in Warsaw was launched. During the summer holidays, 23 programme participants carried out internship in such areas as: IT, HR, finance, risk, marketing, project management or e-banking. Besides receiving attractive remuneration and achieving individual development under the guidance of their supervisors, the interns were invited to attend training in soft skills and agile methodologies applied at Bank Millennium. Some of these people received job offers in the Bank after concluding their internship.

The Bank takes advantage of the communication opportunities offered by social networks such as LinkedIn and Goldenline and some fifteen image and recruitment portals to reach candidates efficiently with information as an employer and about job vacancies.

In Mozambique, in 2022, the Bank maintained its commitment to the recruitment of digital skills, with the launch of the 2nd edition of the Digital Marathon, a programme to attract and develop young IT talent, which attracted two hundred candidates with IT qualifications. This programme was awarded to support the attraction of young talent in the IT and technological area and thus consolidate the Millennium bim brand as an innovative and digital bank.

The onboarding process is one of the crucial strategies for retaining new Employees in the organisation. In this sense, and in order to reinforce the monitoring process of this public, new actions were implemented, besides the integration training, highlighting the active role of the Patron, who in programmed moments of conversation and mentoring with the employees ensures a close monitoring of their trajectory, especially in the 1st year.

Another measure implemented in Mozambique was the extension of the integration period to 1 year, as a way of not only facilitating adaptation, but also ensuring that they have all the necessary tools and knowledge to carry out their activities, including regular feedback on the challenges faced by the employee, thus enabling timely support action.

Millennium bim is committed to boosting employability through collaboration with the education ecosystem and to this end has promoted programmes and initiatives where students can put their acquired knowledge into practice within Millennium bim by offering summer curricular and professional internships for students and recent graduates.

BCP Group aspires to lead the digital transformation of the banking business, through the (best) talent

Training

The development of the personal and professional competences of the Employees is one of the Bank's priorities considering the need the ensure its ongoing alignment with the strategic goals defined by the organization. Seeking to promote excellence in the relations established with Customers, the Bank recognises the importance of ongoing training to ensure business sustainability and endeavours to provide its Employees with the tools necessary for the execution of their activities.

In overall terms, in the Group, 10,176 training actions were ministered, corresponding to over 710 hours of training, with an average of 45 training hours per Employee. During 2022, the training effort kept its focus not only on the commercial areas, but also on technical, operational and compliance areas and on team management.

In Portugal, the Millennium Banking Academy continued its development and training programmes with the intention of supporting the Bank in its mission and in the progress of the defined strategic plan.

The total number of training hours given to headcount Employees was 327,700 (-21.1% compared to 2021), with special focus on Leadership Training Programmes, Integration Programmes and Development of internal talent. We also continued to emphasise the technical areas of Compliance and Auditing, Legal and Regulatory due to the demanding regulatory environment of the sector.

To this end, we supported leaders in the digital transformation areas to manage teams, strengthen social and emotional skills to ensure effective collaboration and develop resilience in Employees to enable the organisation to thrive. In the fourth quarter we began a transversal training Programme on Good Leadership Practices, which allows the reinforcement and standardisation of best practices on the subject.

Through the Digital Academy, launched in October 2019 with the purpose of achieving digital leadership in the market, we aimed to expand the ability of Employees to work in a digital environment and develop cognitive skills, such as problem solving and critical thinking, and also technical skills that ensure response to the need to redesign processes and innovate.

Adjusting demand and supply to the distinct groups in the Bank's universe of employees: the Tech - from the development, architecture, cloud, security and data areas -; the Business - from the areas that develop new business solutions -; the Ingenious - young people from technical areas - and the Millenniums - all Employees -, we continue to invest in behavioural and technical training appropriate to the different needs, and, (i) to increase digital literacy (learning for all), we launched the DigitalMente line (30-minute videos on the Bank's technological projects and on what's new in the digital market), new eLearning and webinars on how to use and maximise the current digital tools (Smartphones and Office 365) and (ii) to increase technical skills and expertise in core and technological topics, we started a partnership with UDEMY - an online learning platform with a wide range of courses in different technological and behavioural areas - everything so that our Employees are even more able to respond to current and future challenges.

In Portugal, in 2022, as part of the adaptation to the hybrid work regime applicable to most of the Bank's employees, the training effort channelled to web live training actions was reduced to 20,326 hours (35,390 in 2021) and to 6,865 trainees (10,199 in 2021), not allowing the 5% increase proposed for this period to be achieved.

In 2023, pursuing a strategy that always ensures more and better training, but also that accompanies the Bank's digital transformation, we aim to increase the strengthening of skills on digital topics (more than 5 hours of training per Employee).

Thus, in 2022, 17,446 hours were invested in training in the digital area and 8,571 in Health and Safety at Work, with a total of 6,114 participants in training initiatives, mostly in weblive and e-learning format.

2022 2021 2020 VAR.% 22/21
NUMBER OF PARTICIPANTS (1)
In-person 53,453 (M 70,9%, H 29,1%) 38,878 18,231 37.6%
E-learning 409,711 (M 68,6%, H 31,4%) 482,801 376,977 -10.8%
Remote 47,545 (M 46,8%, H 53,2%) 59,882 61,648 20.6%
NUMBER OF HOURS
In-person 176,784 (M 67,5%; H 32,5%) 124,408 128,153 42.1%
E-learning 366,785 (M 58,3%, H 41,7%) 447,928 421,190 -18.1%
Remote 117,053 (M 45,8%, H 54,2%) 154,061 136,504 -24.0%
PER EMPLOYEE 45 (M 56%, H 44%) 45 40 0.0%

TRAINING

(1) The same Employee may have attended several trainings.

Talent management

Managing individuals is one of the strategic pillars of the competitiveness of the BCP Group. Simultaneously with the valuing of general and specific skills, it is crucial, in an organisational enhancement perspective, to identify Employees with potential and talent, so that in future they can perform duties of higher complexity and responsibility.

The development programmes that have been carried out in the different geographic areas of the BCP Group are therefore a concrete response to Employees with high performance and potential, allowing: i) newly recruited Employees to obtain a transversal vision of the business and the best practices of the organisation; and ii) experienced Employees, the opportunity to acquire additional skills so that, in the future, they can take on positions of greater responsibility.

DEVELOPMENT PROGRAMMES

Power On

In partnership with Nova Business School, we started the Power On training addressed to central areas between March and October 2022.

The Training Programme was designed to empower managers from Central Areas to deal with the challenges arising from the new work paradigm in an effective and natural way. It was intended to provide the right energy in an always On world. An entirely online programme that demystifies the new work reality and addresses the main challenges, solutions, tools and strategies to lead and motivate teams in the current and future work paradigm context. The Programme lasted 10 hours for First Lines; 17.5 hours for Second and Third Lines and 5 hours for Teams. In 2022, 2,121 Employees participated in this Programme, totalling 13,902 hours of training.

The thematic areas worked in the training were: 1. The fundamentals of the World of Work; 2. Balance, Emotions and Technostress; 3. Learning Culture and Technological Skills; 4. Change, Performance, Meetings and Feedback and 5. Diversity and Inclusion. The programme combines asynchronous sessions (short 5 to 10-minute video presentations), practical exercises (where each participant reflects and asks questions about their reality) and synchronous sessions (classes with the teacher to discuss the participants' real-life situations).

After the training, a Good Practice Guide was prepared with the participation of the trainees with a summary of the contents and examples of implementation of the concepts learned in the Training Programme.

The Programme was appreciated by the participants for the contents covered, the methodology used and the performance of the teachers/trainers.

Líder Millennium Programme

The Millennium Leader Programme was launched in November 2022 with the aim of continuing to prepare the Bank's future leadership. This programme is aimed at all the Bank's hierarchies (Commercial Network and Central Areas), with the objective ofsupporting the Leaders in their function, developing the necessary new leadership skills, and strengthening and standardising good practices that help to make a difference with their Teams. The Programme is composed of an e-learning course with videos on seven themes on Good Leadership Practices (Giving Feedback; Having Conversations with Two; Motivating; Delegating Effectively; Being Accountable; Recognising and Managing my time between people and business); monthly

webinars (MLíder Talks): monthly live sessions with external experts and leadership workshops - one-day training sessions, to be held after diagnosis of training needs (to work in class on the themes they would like to see developed) that will be developed in 2023.

inGenious Programme (Trainees Academy)

The 4th edition of the inGenious Programme took place in 2022, in which 46 young talents from the Bank's analytics, technology, investment and financial areas, in a 9-month journey, 1 week per month, had the opportunity to get to know the Bank (its people and different business realities), develop their behavioural skills and

reinforce their technical skills (with access to certification), enabling them to respond to the high technical demands of the areas they work in. The programme keeps the concern to strengthen the involvement of these young talents with the institution and to integrate them in the development of projects of high interest for the digital transformation process and for the future of the Bank, readjusting the subjects to their needs, developing critical thinking, effective communication, collaboration and teamwork.

Each participant in this Programme carried out an average of 135 Hours of training in 2022.

Digital Academy

One of the great priorities of our academy is to support the bank in its cultural and technological transformation, with a focus on Millennium's global objective of achieving digital leadership in the market. In this sense, in 2019 we launched the Digital Academy to meet the training needs with a view to reskilling and upskilling our Employees, adapting the demand and supply of training to the distinct groups in the universe of Bank Employees: the Tech - from the development, architecture, cloud, security and data areas -; the Business - from the areas that develop new business solutions -; the Ingenious - young people from the technical areas - and the Millenniums - all Employees -. So in 2022 we continue to invest in behavioural and technical training appropriate to the different needs, to increase digital literacy (learning for all) and to increase technical skills and expertise in core and technological subjects.

We held (i) new webinars, under the DigitalMente rubric, on the Bank's technological projects and on what's new in the digital market, (ii) we acquired more licenses for UDEMY Business - an online learning platform with a wide range of courses in different technological and behavioural areas - and we continued to contract ad hoc training, namely certifications in the areas of data science, all so that our Employees are even more capable of responding to current and future challenges.

In 2022, 17,446 hours were invested in training in the digital area, with a total of 4,528 participantsin training initiatives, mostly in weblive and e-Learning format.

Digital Journeys

With the objective of continuing to provide Employees with tools to support the digital transition underway, an e-learning course was created with the videos of the digital journeys - investment, credit, insurance, cards and others - currently on the App, to allow the end user's vision to be experienced and encourage more and more operations to be carried out through the App.

This course was made available to the entire commercial network and was the subject of extensive communication from the Retail Business Journal - one video per day throughout the month of December.

Izibizi

IziBizi is a new digital service, where micro-companies can manage their business, issue and receive invoices, access all Banks and do Accounting. It was launched in October 2022 and to support the training of the commercial network, Teams Training Sessions were developed, provided by the Business Marketing Division and by Cloudware (partner company in the creation of the solution), which were aimed at all employees of the Business network, Business Specialists and Mass Market Branch Managers, involving 587 Eployees and totalling 920 hours of training. IziBizi was distinguished in December 2022 at the Portugal Digital Awards 2022 as "Best Digital Transformation Project" and this training was crucial for the entire network to get to know and promote this new service to Customers.

SUSTAINABILITY

Training within the scope of Inclusion

In 2022 Millennium bcp held Winning in the World of Work Training sessions for two more classes, continuing the contribution to the community that arose under the Inclusive Community Forum (ICF), promoted by NOVA SBE.

This training aims to promote key concepts that improve the social skills and employability potential of people with disabilities. In these sessions we train good practices with exercises that contribute to personal and professional success of the trainees. The training is given two people: people with disabilities and the technicians who accompany them. The associations Novamente, Somos Nós, Pais em Rede and, for the first time, the Casa de São Francisco de Assis (former Casa do Gaiato de Lisboa) were represented in the two classes. A total of 29 trainees were covered (18 PWD and 11 Technicians). Between and after the training sessions, workbooks were sent to the participants, in order to facilitate the assimilation of the concepts worked in the virtual room. In addition to videos and exercises, the training includes a practical section on preparing for a job interview.

The training had a very positive impact on the participants, who actively participated during the sessions and completed the workbook with their answers.

Webinars Mlíder Talks

As part of the Good Leadership Practices Programme, we held two Webinars on "Stress: how to recognise and manage it" and "Emotional Intelligence - what do I want you for?" with the aim of stimulating themes that allow reflection on fundamental skills in team management.

Training Happiness

As part of the Ingenious training programme, we continued to work on the Happiness module with a positive impact on the participants.

The subject has raised more and more interest in the organisation because it allows strengthening the social and emotional skills of employees, reflecting on the teams well-being and performance.

In 2022, the B#1 Prestige Programme included a two-hour module on Happiness for all Branch Managers, Customer Managers and Assistants. Everyone participated actively in the session, having valued the action, its dynamics and the sharing among the working groups.

594 Employees participated in the Happiness Training sessions, totalling 1,243 hours of training.

LEGAL CERTIFICATIONS

MiFID II Certification Annual Renewal

CMVM Regulation 3/2018 establishes in Article 2 - Qualifications, in its item 3, that the financial intermediary (Bank) ensures the continuous training of its Employees through the attendance of annual training actions with a duration of no less than 30 hours, in the case of those who provide investment advisory services or portfolio management services on behalf of others, or 20 hours, in the case of those who provide information to investors.

In 2022, the renewal of MiFID II certification was carried out during the second half of the year, in the two areas, information provision and advice (investment advice), safeguarding respectively the minimum hours of training in each area.

In the case of the annual renewal of the MiFID II Certification - Provision of Information, it corresponded to the courses on ethics and conduct in the trading of financial instruments, the taxation of financial instruments and the main financial market instruments and products, with an estimated time of 20 hours of training.

As for the annual renewal of the MiFID II - Advisory (Investment Advisory) Certification, it corresponded to the courses on ethics and conduct in the trading of financial instruments, taxation of financial instruments, the main financial market instruments and products and, finally, investment strategies - creation of portfolios based on investment funds and ETFs, with an estimated training time of 32 hours.

The total number of headcount Employees involved in the MIFID II Certification and Annual Renewal processes was 3,695, which corresponded to 90,915 hours of training.

Credit Certification

Certifications in Mortgage Loans and Credit Intermediation are mandatory training for the entire financial system, in accordance with DL No. 74-A/2017 of 23 June and DL No. 81-C/2017 of 7 July, respectively, covering all Employees involved in the preparation, sale and conclusion of credit agreements and the associated services usually offered.

1,735 hours of training were given as part of the Mortgage Loans Marketing and Credit Intermediation certification to 77 Headcount Employees.

Insurance Certification

In compliance with Regulatory Standard 6/2019 of 3 September and the requirements in terms of Insurance Certification, we continued our efforts to ensure the certification and updating of the knowledge on insurance matters of all Employees with PDEAD-People Directly Involved in the Activity of Insurance and Pension Fund Distribution.

In this connection, 57,664 hours of training were given. In this regard, 58,613 hours of training were provided to 3,613 Headcount Employees.

Euro Banknote and Coins Knowledge Course

Millenniumbcp provides e-learning training on the euro banknote and coins and their security features for employees who operate with cash.

In order to qualify professionals for the activity of recycling euro banknotes and coins, Banco de Portugal provides two elearning training courses on the same topics. The courses fully meet the requirements and objectives of the training required by Banco de Portugal, thus ensuring the full certification of employees working with cash, with a view to carrying out the activity of recycling banknotes and coins. To obtain certification, the trainee is submitted to a test at the end of each course, and must achieve a classification equal to or greater than 80%.

The course on euro banknotes has a 6-hour duration and includes the following modules: Characteristics of banknotes; Genuineity checks; Fitness checks and damaged banknotes.

The training course on euro coin knowledge has an average duration of 2 hours with the following modules: Characteristics of coins; Checking genuineness; Unfit coins for return to circulation.

ONBOARDING PROGRAMMES

Leadership Onboarding

Millennium bcp invests in the development of the behavioural and technical skills necessary for the hierarchy function. When the Leader takes up his/her new position, he/she has access to a training programme that includes an e-learning course on Good Leadership Practices, a day dedicated to the MBTI (Myers-Briggs Type Indicator) tool as a facilitator of personal interactions and workshops to work on leadership issues and to align the new Leader's behaviour with the Bank's values, always

based on the sharing of experiences.

In 2022, 28 Employees attended MBTI training, one of the modules provided, which was highly valued as a contribution to the new function by providing a better understanding of themselves and the team.

Branch Managers Onboarding

If the new hierarchy is part of the commercial Network, he/she is included in the two-day programme for Branch Managers, which in November brought together the Managers appointed in 2022. The contents are divided between behavioural, rigour, commercial systematics, Customer experience and risk analysis topics.

There were 11 trainees present and they valued the relevance and practical applicability of the topics covered, as well as the exchange of experiences and the creation of a networking network.

Prestige Onboarding

The curriculum of the B#1 Prestige Programme, covering all the courses, has been made available to the new Prestige Managers since the 2nd semester, ensuring from the outset a formative contact with the different themes and responding to the objective that those who arrive in the new function can immediately develop the new technical and behavioural skills needed.

The remaining Prestige Onboarding training, namely the behavioural training related to the Prestige #1 Customer Experience, takes place separately.

Business Onboarding

Training programme aimed at strengthening the behavioural and technical skills necessary for those arriving in the Business segment - Managers and Branch Managers. The programme has a specific technical training component for the segment on specialised credit products, digital offer and Customer risk analysis and a behavioural component. The behavioural training focuses on customer experience and sales techniques and ends with an individual certification role play to apply the knowledge acquired.

New Employees Onboarding

Integrated in the Onboarding process of new Employees (permanent or trainees) we created specific training moments from the 3rd quarter of 2022 onwards:

The new e-learning 'We're TOGETHER', available on the day of joining the Bank, with the presentation of core areas - Communication, Digital, Retail and ActivoBank - to allow from the first moment a better knowledge of the organisation;

  • A quarterly Welcome Session where all new Employees are invited to learn more about the strategic vision and values of the Bank, and challenged to some group activities that are highly valued for the interaction and exchange of experiences they provide. After a pilot session in June, hybrid format sessions were held in September and November, involving 148 new Employees and Trainees and a total of 370 hours of training;

  • A specific training for Employees that integrate the Retail and ActivoBank Commercial Network teams on: 1. Customer Service and Sales; 2. Phone Sales; 3. IT Applications, with the aim of providing them with technical and behavioural skills for interaction with the Customer. This training is being carried out whenever there is a justified number of new Employees.

OTHER PROGRAMMES

CUSTOMER EXPERIENCE - B#1 Prestige

Continuing with the B#1 training programmes aimed at developing skills and behavioural techniques with a focus on the Customer, B#1 Prestige took place in 2022, aimed at the entire Prestige segment.

In a first phase, we identified the training topics of interest for the segment, grouped by major areas: 1. Offer, 2. Digital, 3. Systematics and 4. Communication, and each trainee, by filling out a survey, could choose the courses they wanted to enrol in

according to their specific needs.

The availability of the different courses, in e-learning or weblive format, began in April and has been phased in throughout the year. All the contents were prepared in close collaboration with the Customer and segment experience area, which allowed the adjustment to the reality of the Prestige and contributed greatly to the enhancement and impact of the training.

The current balance is very positive, and the trainees' comments highlight the impact of the topics covered on the business.

Effective Written Communication

Responding to needs identified by different areas of the Bank, in November 2022 we developed a training programme on Effective Written Communication, in a face-to-face format, with the Portuguese Linguistics expert Sandra Duarte Tavares.

We identified 3 sub-themes: 1. Writing to Influence, aimed at Employees who write the news for the internal Portal; 2. Writing with Clarity and Objectivity, aimed at employees in the legal support, compliance and audit areas; 3. Writing with Empathy and Assertiveness, designed for the areas that deal with Customer complaints.

In all, five 4-hour training sessions were held, involving 95 trainees. The overall assessment of the training was excellent and the adjustment of the sessions to the audience was highly valued and enriched the training.

FEP (Faculdade de Economia do Porto) Training - Economy for Non-Economists

Continuing the collaboration provided for in the annual protocol with the Faculty of Economics of OPorto (FEP), two training courses were held in 2022 on the theme "Economics for non-economists" for employees of the commercial network who, having management or customer management functions, do not have higher education in the area of economics.

The objective is a theoretical approach, appealing to the participation of trainees, for discussion and practical application of concepts related to Macroeconomics and Microeconomics.

In total the programme had 28 hours of training, divided into two groups - May and September - and involved 37 participants and 518 hours of training, the opportunity and importance of the topic being recognised, as well as its applicability in day-today life.

European Funds

During the next decade Portugal will receive the largest package of measures ever funded by the European Union budget - 51 billion euros for the recovery and growth of the national economy.

Accordingly, together with E&Y - Ernst & Young Portugal, we have prepared a training course aimed at strengthening and updating the knowledge of Employees of the Business, Companies, Corporate and Large Corporates networks for the business opportunities of the present (Recovery and Resilience Plan) and the future (Portugal 2030).

This programme corresponded to 1,434 hours of training, distributed over 15 face-to-face and remote sessions, attended by 446 Employees.

Language Training

During the 2021/2022 academic year, we continued to provide English language training for Bank staff, with a total of 45 students from the Central and Retail Areas, with classroom and team-based training. The training is valued by the participants and meets their need to use the English language in their professional activities.

In addition, we held a 30-hour English course involving 35 employees from Private and Retail, and another French course aimed at the same areas, which lasted 20 hours and involved 21 employees.

M Desenvolvimento

M Desenvolvimento has as one of its objectives the definition of a skills development programme adjusted to each Employee.

In 2022 Employees identified 123 training needs, 67 of which have already been met by the Millennium Banking Academy. The remaining 56 requests are being scheduled for actions that will take place throughout 2023.

Higher Education Incentive Programme

As part of the incentive to the permanent development of the Employees' skills, Millennium bcp provides, in certain situations and where the relevance to the functions performed by the Employee is demonstrated, the payment of external training or co-funding of academic qualification actions.

In 2022, 54 Employees participated in this programme.

In Poland, the growing investment in the training of Employees also continued, with the objective of developing technical and behavioural skills that are reflected in the improvement of the quality and efficiency of the work developed and in the fulfilment of Bank Millennium's objectives, always in line with its corporate values.

It is within this context that the Employees participate, every year, in external and internal training actions on specific issues, as well as in congresses and conferences.

Bank Millennium continues to organise training and coaching programmes that cover all Employees, with actions focused preferentially on addressing internal or external regulatory requirements, such as Health and Hygiene in the Workplace, data protection or information security, as well as promoting training programmes on management, leadership and several conferences.

Most relevant trainings held in 2022:

Integration training for new Bank Millennium Group employees - this training took place remotely using MS Teams software due to the pandemic.

Millennium Campus - a programme for the development of knowledge and skills with the objective of supporting the growth of innovation throughout the organisation. The participation offer in this programme is aimed at all employees, allowing them to look at many issues from a different perspective. The lectures are hosted online, while recordings and assistance are made available on the training platform and intranet at Mundo do Milénio. In September 2022, we started a series of lectures related to widely understood security.

Development Fridays - The programme aims to enable the exchange of knowledge and experience among Bank employees. The speakers include experts who share their knowledge and experience through lectures.

The participation offer in this programme is aimed at all the Bank's employees. The lectures are hosted online, while recordings and assistance are made available on the training platform and intranet at Mundo do Milénio.

External training platforms - Employees have access to the Legimi platform, which offers literature and fiction on business. The Legimi platform makes it possible to enjoy an offer of more than 75,000 e-books and audiobooks. The platform is available to employees on mobile devices (tablets, e-book readers, smartphones) and private computers. The books can be read or listened to online or offline and can be used without limitation.

The Bank started training in Professional Agile Leadership - Essentials PAL-E and in Professional Scrum Product Owner for IT managers. In addition, employees working in technology-related areas now have access to various training courses and new features on the Pluralsight platform.

DataCamp - In the last few years, Bank Millennium has put on the market a set of new analytical solutions based on Python and R programming languages and open source tools (e.g. Jupiter Notebook, mlflow, Feast). In 2022, analysts may start using Power BI solution. These are currently the most popular languages and tools used to analyse data and build learning solutions linked to artificial intelligence. The latest and most effective solutions in this field are changing rapidly.

Employees of the Customer Intelligence Division use the DataCamp training platform to improve their skills in data analysis and machine learning and their knowledge of Python, R or SQL programming languages and PowerBI tools.

In 2022 several training actions were also carried out for employees of the Branch Network, Account Managers of Corporate Banking and for employees who sell insurance.

Managers' Certification - training programme for the managers of the sales outlets in the Bank's own network. The following stages are part of this programme: ABC of the manager, Objectives, Development, Motivation and Team Building.

The programme's objective is to improve practical management skills, communication and control of goals, building the team's commitment to its active performance and management of the sales team.

In 2022, Bank Millennium provided 337,094 hours of training, equally distributed in face-to-face sessions and e-learning, having trained 13,295 employees (8,663 Women and 4,632 Men). Most of the training courses focused on topics related to the sale of products and services and Compliance, with a focus on anti-corruption policies and procedures.

In Mozambique, the year was marked by the 5th year of activity of the Millennium bim Academia (MBA). This corporate training academy, the first of a Bank in Mozambique, has the mission of developing, in an environment of continuous learning and sharing of knowledge, professionals with an ethical sense, with a technique of excellence and rigour in action.

Based on three essential pillars: i) development of training paths, by function, for the Network's Employees; ii) diverse and consistent training that supports the Employee's main needs and iii) creation and availability of a training Curriculum for each Employee.

In 2022, the training offer complied with the structuring themes in order to ensure proper alignment with the Business, namely technical training in operations, taxation, auditing and compliance, and behavioural and leadership training, having been given 45,682 hours of training (48% to women).

The rigor theme was among the training priorities at Millennium bim, with the start of a process to strengthen knowledge of the Bank's norms and procedures with a focus on the launch of training on the Code of Conduct, which will continue throughout the first half of 2023.

Training in Anti-Money Laundering and Counter-terrorism Financing, which has been held annually, resumed in the 4th quarter, after adjusting its content to the new legislation in force. This training started with the training of the 1st and 2nd lines, as well as the direct support areas to the commercial network, and its conclusion is scheduled for the 1st Half of 2023.

In 2022, in order to create the necessary conditions for digital transformation, the Digital Academy was launched. In this sense, and in order to allow the creation of an agile learning model, adjusted to the development needs of this group of Employees in the IT areas, several courses were made available through the UDEMY platform.

Assess and recognize

GRI 404-3

In the BCP Group, the individual performance assessment models, based on a process of counselling and guidance for the development of competencies, provide opportunities for dialogue between hierarchies and their Employees, allowing a culture of personal responsibility for the development of the respective careers to deepen.

The performance evaluation cycle ("MDesempenho"), which ended in 2022 in Portugal, in addition to recording execution rates close to 100%, continues to be well appreciated by the vast majority of those involved, evaluators and evaluated, as is evident in the satisfaction rates with the process.

Assessors Assessees
Total of Answers 767 3721
Very satisfied 34,81% 28,68%
Satisfied 50,07% 51,38%

In Portugal, in addition to performance evaluation, the MDesenvolvimento, which has already had 5 editions, continues to be a fundamental tool for employees to express their professional wishes and aspirations and to actively contribute to their development. They are given the opportunity to express their needs for training or development of specific skills, according to the professional evolution that they foresee. Sharing their wishes for change or evolution, allows promoting a more efficient management of employees' expectations.

Together with a permanent attitude of incentive towards the development of the Employees and the adoption of practices of excellence, BCP Group maintains a policy of recognition of merit and commitment shown by each Employee by means of: i) an incentive system applied throughout the Bank; ii) a plan of professional development due to merit; and iii) specific awards attributed to Employees that were excellent in the exercise of their functions.

The identification of the performances to be rewarded is based on the performance evaluation or on commercial objectives of general knowledge, following transparent rules that promote alignment with the Bank's strategy.

Promotions (Number of Employees)

A meritocratic culture is one of the pillars of people management at Millennium bcp and we know that the path to success lies in having Employees willing to give their best every day. The performance evaluation system, which measures the annual performance of the Employee in relation to the defined objectives, is the basis that makes it possible to show the performance level of each individual and identify, with rigour, the eligibility for merit-based promotions.

The identification of the performances to be rewarded is based on the performance evaluation or on commercial objectives of general knowledge, following transparent rules that promote alignment with the Bank's strategy.

The commercial incentives system is intended for Employees of the Commercial Networks (Retail, Private, Companies, Corporate, Large Corporate and Ativobank) as well as Employees of other Divisions of the Bank who meet the indicated criteria (Investment Banking, Treasury Markets & International, Credit Recovery, Specialised Recovery, Real Estate Business and Specialised Monitoring) and consists in assigning a variable remuneration based on the contribution above expectations for the results.

In addition, and alongside the incentive systems of the commercial networks associated to business results, there is also the annual variable remuneration component, applicable to the support areas.

In Millennium bim, in Mozambique, the evaluation process occurs annually and allows a continuous, systematic and objective assessment of the performance of the employees, contributing to their professional development and allowing the necessary information to be obtained for effective coaching.

The implementation of continuous improvements in the performance assessment and management process was one of the talent management priorities implemented in 2022 through a project that involved several areas, thus promoting the involvement of all in the improvement process.

As part of strengthening the culture and cohesion of the teams, the cycle of ritualisation of Millennium bim values was launched in 2018, with several actions, dynamics and workshops that contributed to the dissemination and involvement of Employees with the Bank's values. Based on the ritualisation of one of the five values each year, 2022 was the year of closure of the cycle with the ritualisation of the "Excellence" value, with various dynamics and dissemination activities, with emphasis on the testimony of its success story by the Employees who were recognised with the excellence award.

In Poland, in turn, the 6th edition of the IMPakt Programme was organised, an innovative initiative in which employees nominate and vote for their peers and 51 more Employees were recognised for their performance and example in the following categories: for their commitment, quality improvement, innovative solutions and accepting challenges to inspire others.

The programme's gala and awards ceremony was attended by around 120 people and was broadcast to all employees.

In this operation, 12 Employees were also recognized with a distinction awarded by the Chairman of the Board of Directors for their participation in key projects.

Bank Millennium has defined and published "Instructions on how to conduct employee evaluations in Bank Millennium S.A.", which contains guidelines on the preparation of rules for employee evaluations, in particular the evaluation of work performance or competencies. Evaluations are conducted based on objective and previously communicated criteria. The rules for evaluating employees are aligned with the nature of the work and relate to attitudes of cooperation, commitment, quality and effectiveness.

The BCP Group continues to bet on the ongoing improvement, believing in the value that can be generated by the innovation processes, stimulating creativity and the sharing of experiences by all Employees.

The internal programmes for the generation of ideas – Mil Ideias ,– a call in Portugal, - Call 2 Action -, in Poland and the recent programme – Ideias que Contam– Ideas that Matter in Mozambique are based on the recognition that the Employees are a creative force that generates ideas of value, representing a means to value and increase their individual abilities through the direct participation with an idea and indirect through comments or votes.

In Portugal, the Programme is being reformulated, which explains the small number of ideas submitted (7).

In Mozambique, with the "Forum - Ideas that Count", a space for sharing and discussing ideas, which throughout the year involved 294 Employees, who were responsible for 493 ideas or their comments, with 21 ideas being implemented and 138 under analysis.

These programmes, which are still being re-evaluated in all countries, have the potential to support the improvement of the organisation's internal processes, the increase in the value proposal in the offer of products and services to Customers and the capacity to quickly adapt to new realities, namely functional realities, but they also create a context that favours the identification of good practices that can be extended to the whole organisation.

Workforce evolution

In 2022, the number of employees of the BCP Group decreased by 1.7% (273 fewer Employees) compared to the previous year. Around 60% of the Group's employees worked in international activities.

EMPLOYEES

2022 2021 2020 Var. % 22/21
TOTAL IN PORTUGAL 6,252 6,289 7,013 -0.6%
Poland 6,987 7,079 7,645 -1.3%
Mozambique 2,504 2,648 2,591 - 5.4%
TOTAL INTERNATIONAL 9,491 9,727 10,318 -2.4%
TOTAL FOR THE GROUP 15,743 16,016 17,331 -1.7%

Note: does not include Employees of Millennium bcp Bank & Trust

In Portugal, the reduction in the workforce compared to 2021 is not significant, with a decrease of 37 employees. The reason with the greatest weight in the total number of departures was resignations, due to the greater dynamism of the labour market.

The evolution of the staff reflects the Bank's strategy in terms of the sustainability of its business model, with a strong focus on recruiting Candidates with distinctive and agile skills, namely in the areas of digital, technology and analytics, but also in the area of risk control and

auditing, with respect for the Bank's values and the primacy of the Customer, which allow us to maintain a level of service of rigour and a high level of ethics and excellence.

In Poland, the number of Employees was reduced by approximately 1.3% (92 fewer Employees than in 2021) to 6,987, most of whom are women, who represent 66% of the bank's total Employees.

Millennium bim ended 2022 with 2,504 Employees, with 205 new Employees having been admitted (139 to fill positions in the commercial area and 69 in central services), of whom 89 were female and 116 male.

As a result of the recruitment policy implemented over recent years, the percentage of graduate employees continued to rise in 2022, currently representing 56% of the workforce.

Employees Turnover and Mobility

(Numeber of Employees)

The BCP Group sees mobility as an opportunity for the Employees to develop their professional careers and their skills, and therefore fosters their contact with different realities of the Bank whenever possible. In this sense, the internal mobility processes of Employees are of strategic importance for Millennium, as they enable the strengthening of critical thinking and the search for new opportunities for improvement, contributing to the strengthening of more collaborative models.

In 2022, 14.7% of the Group's Employees were involved in internal mobility processes, notably in Portugal and Mozambique where 20.3% and 28.8%, respectively, of the Employees changed areas/ divisions.

Suppliers

GRI 204-1

At the BCP Group, the process for selecting suppliers mainly obeys criteria of global competence of the company, functionality, quality and flexibility of the specific solutions to acquire and continuous capacity of providing the service. In all the Group's operations, it is given preference to purchasing from Suppliers of the respective country, with 90.5% in payments to local suppliers.

The Bank's main suppliers are companies that publish their economic, environmental and social performance, assuring a responsible purchase of goods and services.

Since 2007, the BCP Group, namely in Poland and Portugal, includes, as an attachment to the agreements it establishes with suppliers, the Principles for Suppliers which include several aspects, such as compliance with the law, good environmental and labour practices, including human rights and the application of those principles in the engagement of third parties.

In 2020, in Portugal, the Bank revised the Suppliers Sustainability Guidelines, which are now part of all the contracts for the purchase of goods and provision of services signed by Millennium bcp. This document includes aspects such as compliance with the law, environmental and labour good practices, but also human rights and the application of these principles in the contracting of third parties.

At the same time, in 2021, we started sending the Supplier Sustainability Questionnaire to the largest suppliers (contracts over 50,000 Eur), which aims to assess the alignment of supplier companies with sustainable development and evaluate compliance with the Sustainability Guiding Principles for Suppliers defined by the Bank.

In 2023, we subscribed to the Code of Ethics of APCADEC - Associação Portuguesa de Compras e Aprovisionamento (Portuguese Procurement and Supply Association), which brings together a set of values, principles and behaviours that Procurement professionals must follow, thus enabling the strengthening of a posture of professionalism and transparency, leading to a reduction of financial, operational and reputational risks for organisations.

BCP conducts assessments of its suppliers, through the application of a performance questionnaire which includes parameters related to the level of compliance with the Supplier Principles. In 2022, 514 suppliers were evaluated and the average score was 4.39 (in a scale from 0 to 5).

Within the scope of the monitoring, Millennium bcp's suppliers are subject to a permanent evaluation process, based on: i) the relationship they maintain with Technical Competence Centres; ii) performance assessment actions and the identification of areas for improvement; and iii) on existing decision-making processes to execute investments and renew contracts.

In Portugal, Millennium bcp participates in the Commitment to make Timely Payments from ACEGE, an initiative that intends to encourage the timely payment to suppliers, being an ethical exercise which contributes not only for the entrepreneurial success but also to enhance the economy's competitiveness. The ratio payment/deadline agreed in Group BCP is 1.

Millennium bcp is also a subscriber of the Charter of Principles from BCSD Portugal – Council for Sustainable Development. This document establishes the principles that are the guidelines for good corporate management, enabling the subscribing companies to be recognized by their customers, suppliers and by the society in general for the adoption of solid sustainability commitments. The Charter encourages subscribers to go beyond legal compliance, adopting rulings and practices recognized and in line with management, ethical, social, environmental and quality standards in any context of global economy.

Ethics and professional conduct

Material issue:

ETHICS, CONDUCT AND COMPLIANCE

The BCP Group considers that the respect for its defined mission and values and also the compliance with its strategy depends, first and foremost, on each Employee and therefore it fosters a culture of rigour and responsibility, based on permanent information disclosure, training and monitoring mechanisms able to ensure strict compliance with the established rules of conduct.

Compliance Office

Material issue:

PREVENTION OF CORRUPTION AND ANTI-MONEY LAUNDERING

The Compliance Office's mission is to assure that all the management bodies, the functional structures and all the Group's employees comply with the legislation, rules and requirements that guide the activities carried out by the Bank and its subsidiary companies in order to avoid the risk of the institution incurring in legal or regulatory sanctions, financial losses or negative effects in terms of reputation, resulting from non-compliance with the laws, codes of conduct and good business practices and duties that bind the company.

Main Compliance actions regarding the prevention of money laundering and financing of terrorism

Within the scope of the AML/CTF, the COFF's actions, based on a risk-based approach, focused on compliance with the following duties

  • Of identification and diligence for proper pre-validation, substantive and formal, of opening and maintaining entities and accounts and credit operations, in a context of increased risk, highlighting the effect of the war in Ukraine;
  • Examination of operations, in particular the process of filtering operations, an essential process for compliance with the systems of sanctions and embargoes decreed by the competent national and supranational authorities, and their monitoring, with a view to detecting and preventing potentially irregular situations;

  • Control, with the improvement of the IT systems and monitoring mechanisms, adapting them to the new regulatory requirements and new risk factors, contributing to the effectiveness of the AML/CFT risk management model;
  • Communication, by adapting governance and processes so as to timely inform the competent authorities whenever there is suspicion or sufficient reason to suspect that certain funds or other assets, regardless of the amount or value involved, come from criminal activities or are related to financing, in a context of growing risk factors in this area;
  • Training, through compliance with a training and communication plan.

This functional perimeter, based on dedicated technological solutions, also foresees the definition and a management of risk models according to the evolution of the various competing variables to establish scorings to be applied to operations. Also noteworthy is the development of new, more effective and efficient solutions, based on automation processes for analysing the risk factors inherent in new account openings and in screening transactions, and the effort to update internal rules in order to align them with recent changes in the legislative environment. Of the various initiatives undertaken in 2022, we point out the following:

  • The implementation of automatic transaction filtering processes to ensure permanent and timely compliance with the sanctions and embargoes decreed by the various international bodies, in a more demanding international context resulting from the war in Ukraine;
  • The strengthening of AML/CFT risk control in the field of Customer onboarding, over the segments and jurisdictions involved in the business relationships, which was also affected by the war in Ukraine;
  • Optimisation of the alarm system and monitoring of business relations with the aim of increasing the efficiency of the alerts generated;
  • The implementation of a new technological platform and a process that promotes the updating of Customers' information and supporting documentation in the Bank, in compliance with the regulations related to AML/CFT;
  • The implementation of a new technological platform and a process that promotes the updating of customer documentation information at the Bank, in compliance with the regulations related to AML/CTF;
  • The strengthening of controls on the Correspondent Banks, ensuring a more frequent and timely periodic review of their AML/CTF practices and policies according to their risk, whose assessment began to include a set of new risk factors, in compliance with recent regulatory changes;
  • The continued strengthening, training and specialisation of the Compliance Office teams within the scope of AML/CTF, in its various dimensions.

With regard to the updating of internal regulations, of note is the Policy on Preventing and Fighting Money Laundering and the Financing of Terrorism, mainly with the aim of accommodating, in light of Notice no. 1/2022 of the Bank of Portugal and the EBA Guidelines on policies and procedures in relation to compliance management, the new powers attributed to the Bank's Management and Supervisory Bodies, as well as to the Compliance Officer.

Anti-corruption measures, prevention measures, reporting of irregularities

During 2022, the BCP Group reinforced its regulatory framework regarding the prevention of corruption, which is now included individually in the Code of Conduct, as required by Decree-Law 109-E/2021, of 9 December.

The Anti-corruption and Anti-bribery Policy falls within the scope of the set of policies related to sustainability, and defines that any act of corruption and bribery is illegal, unacceptable and contrary to the values and principles of ethics, integrity and transparency of the Group, which completely rejects, regardless of the circumstances, any form of corruption and bribery. It is in this context that the BCP Group recognises the importance of developing its activity founded on compliance values and rules and of ensuring business integrity. The BCP Group's approach to any indication or manifestation of corruption and bribery is one of zero tolerance, requiring its Employees to refrain completely from such acts.

The BCP Group's activities are conducted around fundamental principles of compliance with the law and the internal regulations in force, as well as the highest standards of ethics, responsibility, transparency, rigour and professionalism.

The BCP Group ensures that its business, in the various countries where it operates, is conducted not only in compliance with the legal requirements imposed on combating corruption and bribery, but also following the best practices applied in this field, ensuring that the values that guide the Group are put into practice by Employees in the performance of their duties. As a signatory to the 10 Principles of the Global Compact proposed by the United Nations, the Group undertakes to comply with the principles established, including the fight against corruption in all its forms, namely bribery, extortion and facilitation payments (Principle no. 10). The Anti-corruption and Antibribery Policy complements the principles and rules of conduct set out by the Bank in its Code of Conduct, internal rules on which all Employees receive regular training, regardless of their position or place of work.

This Policy is also aligned with the principles of other internal regulations of the Bank, namely the regulations on the Identification of Related Parties, the Policy for the Prevention and Management of Conflicts of Interest and the Sustainability Guiding Principles for

Suppliers.

Regarding the reporting of irregularities, the Anti-corruption and Anti-bribery Policy, in its own context, defines that any practice of corruption and/or bribery, potential or real, or very strong suspicions must be immediately communicated to the Audit Committee through the system of communication of irregularities defined in the Regulation on the Communication of Irregularities, so that this Committee can determine the appropriate measures to be applied.

Irregularities may be reported by Employees, lawyers, agents, or any other persons who provide services to them, either on a permanent or occasional basis, in any entity of the Group, shareholders and any other persons. The insufficiency of information, evidence or proof does not exempt an Employee from the duty of reporting. The Audit Committee is responsible for managing the system for reporting irregularities and ensuring the confidentiality of communications.

Collaboration with Authorities

The communication and interaction with the competent authorities is ensured with regard to the communication of transactions and the response to requests for information, obtaining the necessary authorisations from third parties, where applicable. It should be noted that, in the context of the war in Ukraine, this collaboration was important to enable compliance with sanctions and embargoes to sanctioned jurisdictions, decreed by international bodies.

Internal mechanisms for dissemination and training of Employees

In 2022 the promotion of the compliance culture was one of the Bank's important initiatives, both through the normal development of the Training Plan and through outreach communication programmes to all areas of the Bank, in particular the commercial networks. The "100% Compliance", the "Compliance Alert" and the "Better prevention" are the most visible aspects of the transformation that began in 2019, where, through weekly headings aimed at all Employees and the Bank's commercial structures, we seek to inform, clarify and support Employees with regard to the most important aspects to be taken into account, both in terms of the risk of financial crime and in other compliance and regulatory risks, using simple but informative and training language. Innovative solutions were also used, which included the regular participation of Employees from the Bank's 1st line of defence on a broad spectrum of compliance and conduct risks and complementing communication actions with training sessions on PBC/FT issues, through the "2 Keep in Mind" rubric, which sought to simplify and summarise the three main ideas to be retained from each training session.

In these various headings, topics related to PBC/FT (KYC - Know Yor Customes, beneficial owners, Gold Visas, virtual assets, among others), code of conduct, sustainability and compliance (Greenwashing, for example), sanctions and embargoes, internal control and conflict of interest were profusely addressed. At the same time, the compliance Newsletter continued to be published on a monthly basis, with a modern and appealing image that addresses practical and current topics related to compliance risk management and the rules of good conduct.

The most important training actions include:

  • On-site training on Notice 3/2020, covering members of the Bank's Management and Supervisory Bodies, Employees of the 3 internal control functions and various other functions whose responsibilities have an impact on compliance with the provisions of the Notice;
  • Training, by telematic means, to the Bank's Commercial Networks on the importance of the Know Your Customer document and the need to know the effective beneficiaries (UBO);
  • Set of trainings that ensure the necessary certifications in the Markets in Financial Instruments Directive (MiFID II);
  • Training, through electronic means, on the risk arising from the application of funds in crypto-assets;
  • On-site training for the commercial network on the requirements for opening a digital account;
  • Telematic training session for employees in the communication and marketing areas, dedicated to compliance with advertising campaigns;
  • Specific training sessions for Compliance Office Employees:
    • ✓ internal and external training, both classroom-based and distance learning, to ensure and update regulatory, legislative and internal knowledge on topics inherent to the functions performed, including Advanced Training in Compliance, Prevention of ML/FT and Notice 3/2020, trade finance, among others;
    • ✓ training, by telematic means, on the new BC/FT risk classification model for customers;
    • ✓ training, through electronic means, on the risk arising from the application of funds in crypto-assets.
  • Integration training and InGenius programme in compliance matters: participation in the training programme for new Employees.

TRAINED EMPLOYEES (1)

AML/CTF, Market Abuse, Internal Control, Monitoring of Transactions and Legal Issues

GRI 406-1

2022 2021 2020 VAR.% 22/21
Activity in Portugal 18,866 45,816 25,828 -58, 8%
International Activity 45,816 30,299 28,507 51.2%
TOTAL 64,682 76,115 54,335 -15.0%

(1) Attendance in training sessions.

Within the scope of internal communication, there is also the application of Notice nº3/2020, of Banco de Portugal, which regulates the governance and internal control systems and defines the minimum standards on which the organisational culture of the entities subject to supervision by Banco de Portugal must be based, and in compliance with article 63 on the systematisation of information, the Compliance Office ensured the provision, in an integrated and updated manner, of information concerning the matters provided for in the Annex to that Notice, in a format that is available to all employees. This information is structured to cover the following topics:

  • Shareholder structure, organisation and governance;
  • Internal control system;
  • Key function holders;
  • Description of the Group's business;
  • Code of conduct;
  • Remuneration policies;
  • Subcontracted activities.

Monitoring of conduct and control on the commercial activity

The Compliance Office maintained its role in the governance of the new product development process, namely in the validation of compliance with the requirements of the internal rules regulating the process of sending proposals for the creation, change, reintroduction and elimination of products/services.

In 2022, the internal regulations for the approval of new products were changed, now including the concept of "Products not allowed": those that include characteristics that do not satisfy the risk or business strategies of the Group or legal/regulatory requirements and that, therefore, they cannot form part of the Group's offer.

It is worth highlighting that the Bank promoted the strengthening of the monitoring process of compliance with regulatory requirements in relation to advertising campaigns and other behavioural matters of the Bank, which included a training session, through electronic means, aimed at Employees in the communication and marketing areas, dedicated to compliance with advertising campaigns.

Actions or activities developed for the international alignment (of all operations of the Group)

In the pursuit of the alignment of strategies and priorities in the risk management of the Group's Operations, efforts continued to update the group's policies, also applicable to International Operations. In addition, the Compliance Office reinforced its monitoring of the Compliance function's activity in those operations, implementing a series of initiatives, of which the following are of particular note:

  • Reinforcement of the Compliance Office Team, in Portugal, that follows the International Operations, sizing it, adapting its response capacity to the challenges that Compliance and regulatory issues have been presenting;
  • Operationalization of the process to obtain the consent of Customers of their operations abroad, or of the respective Supervisors, to have access to data of Customers and operations, allowing their analysis by BCP, whether in the establishment of new business relationships or in the subscription of products of increased risk, which was complemented with access to ML/FT systems and applications at units located in third countries;
  • Issuance of monthly reports on the assessment made to the use of high-risk accounts and of high-risk customer transactions for the higher-risk operations;
  • Issuance of Self-Assessment Reports on the adequacy and effectiveness of the organisational culture and governance and internal control systems of the Group's various operations, within the scope of the requirements defined in Notice 3/2020 of Banco de Portugal;
  • Improvement of the AML/CTF risk assessment model for international operations, including new risk factors and assessment metrics, in compliance with regulations related to AML/CTF;
  • Issuance of Self-Assessment Reports on the adequacy and effectiveness of the organisational culture and governance and internal control systems of the Group's various operations, within the scope of the requirements defined in Notice 3/2020 of Banco de Portugal;

Involvement in working groups of Regulators, associations or other entities for the promotion/dissemination and reinforcement of compliance and the fight against financial crime, corruption and fraud.

In 2022 the Bank joined several working groups within the Portuguese Banking Association (APB), in which it contributed to the identification and development of several initiatives and actions aimed at strengthening the ML/Tf prevention system and internal control of the Portuguese banking market

Although lobbying is not yet regulated in the Portuguese legal framework, there are only draft laws in the Portuguese Parliament, BCP makes no provision for this practice in its internal regulations, and it is forbidden to Bank Employees.

This position does not imply that participation in bodies representing the banking industry is not allowed, as mentioned in the previous paragraph, or the participation in regulatory public consultation processes to be issued.

As for contributions to Political Entities, the BCP Group does not grant any type of monetary or financial donations to political parties or related entities, under the terms of the Portuguese law in force (Law 19/2003 of 20 June - Financing of political parties and electoral campaigns, article 8 - Financing Prohibited), in the context of the Anti-corruption and Anti-bribery Policy approved by BCP in 2021.

In 2022, the Bank updated the Group's Code of Conduct and we underline the following changes:

  • Inclusion of principles and guidance derived from the EBA Guidance on Internal Governance (EBA/GL/2021/05);
  • Inclusion of an article specifically on the prevention of corruption, as required by Decree-law 109-E/2021, of December 9;
  • Introduction of changes in article 17 deriving from the need to fully align this Policy with Notice 3/2020, on the conditions of admissibility or prohibition of gifts.

Two additional clauses were introduced: i) duty of diligence related to the obligation of an Employee to always seek to be up-to-date through training or reading the information made available by the Bank; and ii) the prohibition of any practices typified by law whose purpose is to distort or restrict competition in a significant manner.

Relations of cooperation and loyalty have also been maintained with the judicial authorities and with national and international conduct supervision authorities. Within this scope and by its own initiative, it made a total of 1,650 communications to local Judicial Entities and replied to 1,684 requests.

COMUNICATIONS TO LOCAL JUDICIAL ENTITIES

2022 2021 2020 VAR.% 22/21
OWN INITIATIVE
Activity in Portugal 427 339 338 26.0%
International Activity 1 223 1.444 1.587 -15.3%
RESPONSE TO REQUESTS
Activity in Portugal 200 174 241 14.9%
International Activity 1 484 2.073 2.883 -28.4%
TOTAL 3 334 4.030 5.049 -17.3%

Policies for the fair design and sale of financial products and services

In its code of conduct (GR0021), there is Article 24 on the protection of Customers' assets, which stipulates that the Group must ensure, through all legal and regulatory instruments at its disposal, the protection of

GRI FS-15

the assets whose management or custody has been entrusted to it and that the instructions received from and requested by Customers must be executed with respect for the safeguarding of their assets, within the constraints imposed on the exercise of financial intermediation activities, and executed with diligence, rigour and transparency.

Product and service design policies

The " Policy for the Approval of New Products" (GR0033), applicable to all the countries where BCP Group operates, determines the principles and guidelines on the risks associated with the launching of new products and changes in the characteristics of products being sold, as well as the need to identify, cancel or mitigate these risks in a clear and targeted manner, determining also the products whose trading is prohibited.

This PANP - Process for the Approval of New Products has the following main objectives:

  • I. Promote the best risk management and control practices associated with the launching and trading of new products and services by the Bank , ensuring that the process is made effective with adequate assessments, evaluations, operational procedures and that the products and services trade have their risks duly identified, annulled or mitigated;
  • II. Promote a culture of compliance with the duties of satisfying the Client's needs ensuring that the new developed and traded products are appropriate to the financial needs, knowledge and profiles of the segments target of the new products;
  • III. To promote adequate efficiency levels when launching new products or altering existing products, namely when decreasing their time-to-market, adequately and securely in terms of risk.

Thereon, the PANP encompasses the process of preparing, approving and launching new products and significantly altering products being sold, and mainly attempts to ensure that:

  • I. The various risks are duly analysed and managed considering the Bank' goals and strategy and the risk appetite set forth by the Bank's management body;
  • II. comply with the rulings and recommendations of supervision authorities and regulators;
  • III. Meet, in terms of features and information, the Customers' needs and rights;
  • IV. The premises in what regards the Bank, the Customer, the market or the regulation that approved the product remain unaltered, while sold.

This process of development of products and services, formalised in a specific service order (OSO027), should be subject to the Policy for Approval of New Products. This service order (applicable in Portugal) establishes the approval circuit for launching new products and services and changing the characteristics of products being offered for sale (creation, change, reintroduction or elimination of the offer), guaranteeing:

  • I. Customer protection ensuring that customers have access to transparent, clear and complete information that identifies the characteristics and risks of the different types of services/products made available, so that the customer is able to make an informed decision;
  • II. Preservation of the Bank's solidity ensuring that the sales/subscription processes do not allow any failures of conduct that may affect the Bank's reputation and the customers' confidence;
  • III. Mitigation of situations of possible conflicts of interest ensure strict control of the incentives given to commercial areas and ensure the introduction of mandatory disclaimers in the documentation of products/services that alert to the situations identified (e.g. sale/subscription of products/services from related parties), in order to protect the reputation of the Bank and the confidence of its customers.

The internal regulations (OSO027) were updated to include the ERSCD (Economic Research, Sustainability and Cryptoassets Division) as a stakeholder, highlighting the ESG (Environmental, Social and Governance) factors in the process of developing products and services, complying with the policies and principles related to Sustainability (GR0046).

Credit Risk Policies

The principles and guidelines relating to the credit activity undertaken by the financial institutions of the Banco Comercial Português Group are formalised in a Group code applicable to all geographies (GR0005). It is established that the Group's entities must guarantee the adaptation of their activities to the risk that the business presents to the parties involved, as well as to the legally admissible exposure. Risk management in the BCP Group is based on a strong credit risk culture, reflected in the overall attitudes and behaviour of all employees involved in credit risk management, with a view to ensuring that credit is granted to borrowers who meet the criteria defined in this code, guaranteeing proper capital management, aligned with profitability and sustainability goals, where environmental, social and governance factors are included. It should be pointed out that transactions with related parties are regulated in accordance with the provisions of the applicable regulations (in particular Notice no. 3/2020 of Banco de Portugal and the Legal Framework for Credit Institutions and Financial Institutions), which require a specific approval procedure and within the legally defined limits.

Aiming to comply with the applicable regulatory requirements and guidelines issued by national and European institutions, the service order "Credit granting, monitoring and recovery" (OS0016) establishes the guiding principles, rules and decision-making powers for the process of granting, monitoring and recovering credit in the BCP Group, in its activity in Portugal and Macao. As a result, the requirements and procedures specifically applicable to each loan granting are created according to the level of risk associated with it, the type of counterparty and whether it is classified as a Bank Related Party or not. Additionally, the document determines the procedures applicable to loan recovery.

This internal regulation establishes the principle of the adequacy of the pricing to the Customer's risk, determining that the pricing of credit operations should always be defined according to the risk associated to them, measured by combining the Customer's level of risk (or, where appropriate, that of its guarantee or guarantor) with the level of protection acknowledged in each operation.

Policies on Conflicts of Interests

In the Code of Conduct, the issue of conflicts of interest involving Customers is addressed in Article 27, in which it is defined that:

  • I. The Group organises itself in a way that enables it to identity potential conflicts of interest and act in a manner so as to avoid or reduce as much as possible their occurrence.
  • II. In case conflicts of interests occur, the Group must act in a way that guarantees that the client is provided equitable and transparent treatment, giving prevalence, in accordance with the applicable legal and regulatory provisos, to the client's interests under the terms of the conflicts of interests policy approved().

It is through the "Policy for the Prevention and Management of Conflicts of Interest" (GR0038) that the principles, governance model and fundamental processes adopted for the identification and management of situations of conflict of interest that occur within Banco Comercial Português, S.A. or any entity directly or indirectly controlled by it, integrating the Banco Comercial Português Group, are defined. This Group Code implements in Banco Comercial Português Group the guidelines issued by the European Banking Authority on Governance and other regulations in force, formalizing the governance principles applicable within the scope of the provision of investment services and activities and ancillary services provided for in the Securities Code. Moreover, it identifies the control process to allow for an effective and prudent management of conflicts of interest at an institutional or personal level, including segregation of functions, information barriers and the specific process of deciding on transactions with "Related Parties", in order to defend the interests of the stakeholders and of the Bank and of the Group. In addition, it specifies the internal responsibilities regarding the management of conflicts of interest, the involvement and responsibilities of the internal control functions and the regular reporting model.

This regulation is complemented by the " Policy on Related Parties" (OS0155), which is based on the International Financial Reporting Standards (IFRS)/International Accounting Standards (IAS), namely IAS 24 - "Related Party Disclosures", complemented by national legislation, in particular by the Legal Framework for Credit Institutions and Financial Institutions, as well as by Notice no. 3/2020 of Banco de Portugal, which establishes the minimum mandatory content of a Related Party Policy. The standard ensures the disclosure by the Group's subsidiaries of the necessary information to comply with the reporting obligations resulting from IAS 24, fulfilling the obligations arising from transactions, directly or indirectly, with Related Parties in which any entity of the Group participates, namely restrictions on the granting of credit, as well as the acquisition of goods/contracting of services, related to the management and supervisory bodies of the Group's credit institutions or holders of a qualifying stake equal or above 5% of the share capital of BCP, or entities related to them, as well as other entitieslegally qualified as such. The decision-making process is outlined by the standard, identifying the powers assigned to each division as well as the necessary interactions to ensure adequate regulatory compliance.

Personal conduct policies

The Code of Conduct establishes the fundamental principles and rules to be observed in the exercise of the activity developed by the entities that form Group Banco Comercial Português underlying the conduct, good practices and observance of the institutional values by the universe of people that form the Group. The entities of the BCP Group, the members of its management and supervisory bodies, as well as its Employees, guide their actions by principles of respect for the rights of people, for the preservation of social and environmental sustainability, and for institutional culture and values, committing to adopt behaviours of integrity and honesty in all relations that they establish with each other, with their Customers, or any other person or entity with whom they have a relationship. Relevant topics are developed, such as Inside Information, Communication of Transactions, Conflict of Interests (including with Customers), Gifts, Loyalty, Reputation, Duties to Customers, Asset Protection or Customer Claims.

Internal Audit

Internal auditing is an independent, permanent, assurance and consulting activity designed to add value and improve the operations of Group Banco Comercial Português. For that purpose, it provides assistance to the Group in achieving its objectives, through a systematic and disciplined approach, oriented towards the assessment and strengthening of the effectiveness of risk management processes and governance and internal control systems.

The Audit Division plays the role of the 3rd line of defence of the internal control system of Banco Comercial Português, whose main mission is to assess, as a whole, and report to its stakeholders - in particular, the Audit Committee and the Board of Directors - the suitability and effectiveness of the organizational culture, risk management process, internal control system and governance models. The Audit Division issues recommendations based on the results of the audits made, focused on the strengthening of the internal control system and on the accomplishment of the Group's strategic interests. The exercise of the internal audit function is governed by the guidelines of the Institute of Internal Auditors (IIA), including the Definition of Internal Auditing, the Code of Ethics, the International Standards for the Professional Practice of Internal Auditing and the principles of internal auditing defined by the IIA, of which the following stand out: integrity and professional competence, confidentiality, independence and objectivity.

The function of the Internal Audit carries out integrated audits to the risks and controls of the processes defined at the Bank, in an endto-end perspective. The audit programmes include the assessment of behavioural issues, the compliance with the legislation and with all the remaining rules and codes of conduct, the proper use of the delegated competences and the respect for the performance principles in force in what concerns the relations established with the Clients, internal and external.

Throughout 2022, as part of the execution of its Activities Plan, the Audit Division also assessed the issues related with the management of environmental and social practices resulting from or related with the object of each audit in particular. In this context, it carried out an audit focused on the management of environmental and social risk factors (ESG) at Banco Comercial Português, to assess the adequacy, completeness, implementation and monitoring of the Master Plan for Sustainability, its connection with the Plano Estratégico Superação 24 (Strategic Plan Overcoming 24) and the adequacy of the ESG risk factor management model, considering the supervisor's expectations and the respective regulations. Especially in what concerns the audit programs addressed to networks, we must point out the procedures for the prevention and detection of practices eventually showing signs of money laundering.

The prevention and mitigation of the risk of fraud as well as the detection and investigation of internal fraud attempts or situations and the execution and monitoring of the consequent eventual disciplinary or judicial proceedings are also a priority in the distribution of resources allocated to the Audit Division. Furthermore, all the claims, complaints or denouncement of situations that show socially inappropriate behaviours by the Employees, either among themselves or relating to Customers, are also assessed and investigated and will originate disciplinary proceedings whenever deemed justified.

In 2022, the preventive controls carried out and the subsequent individual assessments of potentially irregular situations as well as of situations reported by other organic units of the Bank originated 104 preliminary investigation proceedings. That same year, 19 disciplinary proceedings brought against Employees of the Bank in Portugal were completed. By the end of the year there were 3 proceedings underway. None of the cases involved situations of corruption.

DISCIPLINARY PROCEEDINGS FOR BREACH OF RULES

GRI 419-1
2022 2021 2020 VAR.% 22/21
Activity in Portugal
Internal Rules 19 24 27 -21%
External Rules 0 0 0 0%
TOTAL 19 24 27 -21%

The Coordinating-Manager of the Audit Division is also the individual in charge for coordinating the internal audit function in all the subsidiary companies of Group Banco Comercial Português, namely with its own internal audit team, within which he participates in the respective Audit Commissions, assesses its proposals for a Strategic Plan and Activity Plan and regularly monitors their execution and the implementation of the recommendations issued based on the audits carried out, promoting the harmonization of analysis procedures and criteria and the sharing of knowledge, namely by collaborating in the preparation and execution of audits relating to matters of common interest to the various institutions..

The standardization of the practices in force in the internal audits of the several operations of the Group increased throughout the years either by the adoption of joint approach methods, safeguarding eventual differences due to local regulations or by the setting up of audit teams, at Group level, responsible for the execution of audits relating to specific issues in any of the countries where the Group operates

In this context, in 2022, the Bank's Audit Division carried out audits in all those subsidiaries, selecting its scope based on the issues and risks most relevant to the Group, for which it usually relies on joint teams of auditors from the Bank's structures and subsidiaries.

At the end of 2022, the Audit Division had a staff of 54, including the Coordinating Manager.

Products and Services

Material issue:

TRANSPARENCY OF THE INFORMATION PROVIDED TO CLIENTS ON PRODUCTS AND SERVICES GRI FS7, FS8

The BCP Group offers a complete and broad range of financial products and services, and continues, under the development of its business lines, responsible for offering an increasing number of products and services which incorporate social principles and respect for the environment and nature.

BCP Group is also aware that the implementation of social and environmental criteria and standards in the commercial offer is reflected in more efficient risk management, reputation value and higher quality of the products and services offered to customers, meeting the needs and ambitions of a market increasingly related with sustainability.

Microcredit

In line with the Sustainable Development Goals (SDGs) of the United Nations.

In Portugal, Millennium bcp continues to reinforce its commitment to Microcredit activity, with its value proposition still being recognised in the Portuguese market as an alternative for the funding, encouragement and achievement of entrepreneurial action, comprising an effective instrument in the fight against unemployment, poverty and social exclusion.

Despite the number of new companies created in Portugal in 2022 (#48.404) grew 14% Versus 2021 (#41.656), pre-pandemic entrepreneurial figures have not yet been resumed (#49,175 in 2019). The economic situation in Portugal, as well as the State measures to protect employment, preserved many jobs, preventing a substantial increase in the number of unemployed people, the main recipients of this credit instrument, consequently

4 400

reduced the demand for instruments to support the creation of new businesses, such as Microcredit.

Within this context, it was possible for Millennium bcp to fund 59 new microcredit operations during 2022. These operations totalled 1.060 thousand euros of credit and contributed for the creation of 85 new jobs.

The work of disseminating Microcredit is based on a relationship with institutional partners that, spread across the country, have direct contact with the target audience of this instrument (unemployed, immigrants, young people in the end of training, etc.). In 2022, the Bank re-established the relation with these partners and, this way, carried out the following initiatives for the promotion of entrepreneurship and disclosure of microcredit: 7 attendances in Seminars - initiatives promoted by institutional partners.

The alteration of the structure of microcredit in 2018 with the migration of the operation into the Bank's Network, paved the way for a clear approximation of the instrument to its recipients, thus reinforcing the commitment of Millennium

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bcp towards micro credit as an opportunity to help those with an entrepreneurial mind and a feasible business idea, encouraging them to use this solution to develop their business and create his/her own job. This alteration placed Micro credit near the surrounding community.

Millennium bcp's Microcredit, created in 2005, is recognised as a comprehensive service providing permanent support to the Customer throughout the duration of the funding contract. This being a service of social responsibility it translates a permanent focus on the reality and needs of our Customers. Since 2005, 7,410 jobs were created resulting from projects funded by Millennium bcp's Microcredit.

Despite this adverse context, as a result of the work carried out, Millennium bcp's Microcredit approved the financing of 59 new operations, which resulted in a total of 1.060 million euros of approved credit and the creation of 85 new jobs (versus 161 in 2021 The volume of active credit granted to the 433 operations in the portfolio, on 31 December 2022, totalled 4.199 million Euros.

(Thousand euros)

Since 2005, 7,410 jobs were created resulting from projects funded by Millennium bcp's Microcredit, of which 82 in 2022

Financial Advisory Service

Millennium bcp, with the objective of continuing to support Customers in financial difficulties and preventing and avoiding situations of default, maintained the provision of SAF packages (Financial Monitoring Service), which includes solutions for restructuring and consolidating credits, and which aims to preserve the financial stability of our Private Customers with ongoing liabilities. The Bank's concern continues to be proposing to Customers the solution more adequate to their available budget, so that they can keep meeting their liabilities by reducing costs with the credit payments.

In this context, 2,584 contractual amendments were made during 2022 (1,155 mortgage loans and 3,569 consumer credit), with a restructuring value of 89 million Euros (77 mortgage loans and 13 consumer loans), comprising 2,231 Clients (866 mortgage loans and 1.365 consumer loans).

During 2022, some developments were also carried out with a view to making it possible to formalize remote credit restructurings (through the Millennium App).

Companies Support Solutions

In the course of 2022, the Bank remained focused on the needs of economic agents in the post-pandemic context, having stood out as (i) Leader Bank – being recognized as the Best Corporate Bank; (ii) Partner Bank – reinforce the position of the Partner Bank, with solutions adapted to Companies and with commercial proximity; (iii) Banco Inovador – for having differentiating and relevant digital solutions; (iv) Sustainable Bank – to be the ESG Bank, namely in terms of Sustainability, Decarbonization and Digital Transition.

Portugal

Credit Lines and Guarantees

Of the solutions provided, we highlight the Guarantee Lines with the European Investment Fund (FEI) and the European Investment Bank (EIB), under the Community Program EGF – European Guarantee Fund.

  • The operation with the EIF was the largest European operation for a total portfolio of 2,614 million euros, and in 2022 alone, 8,941 operations were financed, with a total credit of 1,593 million euros.
  • With the EIB, we had a guarantee available for working capital and investment operations, for Midcaps and Large Corporate companies, which provided the constitution of a credit portfolio of 400 million euros.
  • Within the scope of protocols established with Banco Português de Fomento (BPF) and the Mutual Guaranty Companies (SGM), the Bank launched several credit lines in the form of Tourism Support Lines 2021, Treasury Line, Production Support Line and Support Line for Increased Production Costs.
  • Regarding the support to investment projects aimed at the creation of companies by the unemployed with subsidized financing conditions, within the scope of the protocol signed with the Institute of Employment and Professional Training (IEFP) and with the Mutual Guarantee Companies (SGM), the Bank financed, in 2022, through credit lines: i) Microinvest Line: 70 entrepreneurs, for a total of 0.5 million euros and ii) Invest+ Line: 22 entrepreneurs, for a total of 0.9 million euros.
  • Within the scope of the Capitalizar Mais Line in support of SI Inovação, a protocol signed between Millennium bcp, the Financial Development Institution (IFD) and the Mutual Guarantee Societies (SGM), aimed at supporting projects to be implemented in mainland Portugal and in Autonomous Region of the Azores that contribute to strengthening the business capacity of SMEs for the development of goods and services or that are innovative in terms of processes, products, organization or marketing, in 2022 89 operations were financed, with a total value of credit of 40.5 million euros..
  • With regard to support for the Agriculture and Fisheries Sector, the Bank maintained the possibility of financing under a set of protocols signed with the Institute for the Financing of Agriculture and Fisheries (IFAP), through the Credit Lines – IFAP Short Term, Support for Fisheries, Flowers 2020, Weather 2020, Agricultural and Forestry Sector and the General Protocol signed with Agrogarante. In 2022 a new protocol, denominated Treasury Line, was signed. The Bank carried out 198 operations, in a total value exceeding 16 million Euros.
  • For the tourism sector and under the protocol established Millennium bcp and Turismo de Portugal, the Bank continued to provide the credit line that enables companies to benefit from a credit line for projects aimed at the re-qualification of tourism undertakings and at the creation of new ones, of restaurants and leisure activities. The bank financed 35 entrepreneurs, for a total of 12 million euros.

• Following the contracting of Mutually Guaranteed Economy Support Lines with the possibility of converting loans into nonrefundable amounts, namely under the COVID 19 Economy Support Line – Industry and Tourism Export Companies, the Economy Support Line COVID 19 - Event Setup Companies, Investe RAM Credit Line COVID 19 and Linha Apoiar Madeira 2020, the Bank repaid, in accordance with the instructions received by the Management Entities of the Lines involved, 772 operations for a total amount of 25.2 million euros.

Trade Finance

The process of opening documentary operations on the corporate website (initiated in 2014) provided a significant contribution to the sustainability of this business area through the increasing digitization of operations, which has translated into an increase in the level of service for Customers and reducing the administrative burden for Customers and the Bank.

The solution SAFe, (Strong Authentication System) that we attached to this process (in 2016), provided an important growth, with the dematerialization of the opening of Documentary Import Credits and the Discount of Allowances.At the end of 2022, Millennium bcp presents around 80% of the total operations carried out through digitalization.

4 types of operations are included in this process: sending on collection and discounting export documentary shipments, opening import documentary credits and discounting allowances, the latter two being completely dematerialized.

Factoring

The Online contracting process for Factoring and Confirming operations on the companies website, initiated in 2018, has allowed the growing digitization in contracting this type of operations from an end-to-end perspective, namely in the market segments of ENIs and Small Companies, contributing in a relevant and sustainable way to the dematerialisation of this type of product through a reduction in physical visits to Branches, an increase in the level of service for Customers, as well as a reduction in the administrative burden for Customers and for the Bank..

At the same time, the transactionality associated with Factoring & Confirming operations is carried out mainly through the use of automatic channels, namely the company portal, contributing to the significant dematerialisation and simplification of processes. Currently, transactions and/or instructions such as sending Confirming Remittance files, Factoring credit assignments and requests for revenue anticipation, in both products, are carried out through the companies portal in percentages greater than 85%.

In December 2022, a new process came into force for sending notifications to Factoring Debtors by email, which made it possible to contribute to a more sustainable process, supported by a paperless perspective with a significant reduction in charges for sending by postal mail, which implied consumption of energy resources, combined with greater efficiency and improvement in the level of service provided to all entities involved in this business.

Leasing and LTR

Specifically referring to leasing, we point out the accounting advantages for Companies provided by this product, in the purchase of productive goods. During 2022, with the reinforcement of the EIF and EIB guarantees, it was possible to mitigate the credit risk and the financial conditions for Customers.

Car pollution through the emission of CO2 and other polluting gases is one of the main causes of pollution emitted into the atmosphere and which has serious consequences. It is within this context that the Leasing and Renting sectors assume a significant importance in the paramount commitment of reaching carbon neutrality in 2050.

At a time when the pertinence of rethinking new forms of mobility, which are more efficient, economical and, above all, more environmentally friendly, is reinforced, the Bank has prepared "Green Leasing and ALD", a specific product that distinguishes vehicles:

  • 100% electric (0% emissions)
  • and hybrid vehicles with CO2 emissions of up to 50g/km

We ended the year with around 9,500 light passenger and goods and mixed vehicles in portfolio

We closed the year leading the leasing global market with 25.8% of share, improving 4.6 p.p. versus 2021. In a year in which the movable leasing market fell by 8%, Millennium bcp grew by 1.2% compared to 2021, achieving a market share of 14.2%..

Poland

In Poland, Group Bank Millennium,in line with its 2022-24 strategy, actively supports corporate clients in their decarbonisation efforts and will provide PLN 2 billion in financing over the next three years to Bank clients for sustainable and transformational projects.

At the same time, the Group Bank Millennium does not fund new coal mines and coal-fired power generation projects, except for new projects related to pollution abatement. These issue are detailed in the section denominated "Environmental Policy of Group Bank Millennium".

The Bank continues to launch new products that help to finance environmental projects, of which we point out:

The Biznesmax Guarantee Program, within a partnership established with Bank Gospodarstwa Krajowego (BGK). The program aims at guaranteeing loans granted to finance innovative undertakings by the SMEs, beimg particularly focused on eco-efficient companies. The client may take advantage of the "ecological path" that the Biznesmax Guarantee Program intends to foster to finance projects involving at least one environmental category, such as electric mobility, renewable sources of energy, including solar energy plants, technologies to reduce the consumption of energy or to produce alternative fuels, circular economy, installations for the recovery of raw-materials from productive processes, among other;

In the area of investments for the generation of energy from renewable sources, the Bank offers the Loan for Photovoltaic System. This loan is intended for companies that intend to use energy generated from renewable sources for their own needs and where surplus energy can be sold. The product can be used to finance the construction of photovoltaic installations and power plants worth up to PLN 20 million, while in the option up to PLN 2 million the financing can be granted without guarantees. For larger installations, the product can also be used to finance energy storage and an energy management system. The product meets current market needs, allowing companies that consume large amounts of energy in production processes to reduce energy costs and build their own independent source of electricity.

The Bank actively increases the knowledge of its employees on the financing of ecologically efficient projects. It regularly organizes training on how to implement environmentally friendly investments using EU funds, or on how to implement them within the framework of "green products" available at Bank Millennium, such as EIF financing, which supports the financing of green investments in the area of protection biodiversity, circular economy, pollution prevention, investments in low carbon technologies and renewable energy.

The Millennium Leasing is consistently involved in the financing of investment projects on energy saving, in compliance with the Environmental Policy of Group Bank Millennium and industrial policy. For such purpose, it uses programs organised by the EBRD (European Bank for Reconstruction and Development) in which it reimburses customers for part of the costs of financing machinery and equipment on the LEME list. This list contains machines and equipment evaluated by engineers that help to reduce CO2 emissions and energy efficiency, achieving energy savings of at least 20%.. Millennium Leasing also upholds the financing of equipment to generate energy from renewable sources.

Since 2019, the Bank is particularly active in the development of MilleSun– a program for the financing of investments in solar energy. The rental of solar panels is a solution for entrepreneurs who like to change and are aware that the environment needs to be protected. In the area of leasing of photovoltaic panels, Millennium Leasing had been cooperating with the market leading suppliers, offering financing under preferential conditions for these premises. In 2022, the Company extended its offer by adding a new product, the heat pumps. To continuously develop the MilleSun Program, Millennium Leasing plans to add energy storage to its offer.

In 2022 Millennium Leasing joined Mój Programa Elektryk implemented by Banco Ochrony Środowiska, which guarantees co-payments from the National Fund for Environmental Protection and Water Management for the rental of electric vehicles, and co-payments from the National Fund for Environmental Protection and Water Management for the initial payment in electric vehicle rental contracts. Copayments are up to PLN 27,000 for passenger vehicles (M1) and up to PLN 70,000 for commercial vehicles up to 3.5 tonnes, respectively. The program's objective is to reduce air pollution emissions by co-financing companies to reduce the consumption of emission-generating fuels; The co-financing constitutes a support and an incentive for the purchase/lease of vehicles with zero emissions.

In 2023, the Company plans to launch the Preferential Program to finance ecologically efficient assets.

The economic transition and the implementation of sustainable development policies by customers will, in the future, be a growing source of demand for financing offered by Millennium Leasing. We estimate that this growth will have an impact on:

  • investments in energy-saving machinery and equipment to reduce the amount and cost of electricity used per unit of product;
  • low-emission means of transport supporting the reduction of CO2 emissions in the transport of people and cargo;
  • Technologies for the generation and storage of energy from renewable sources.

Mozambique

In Mozambique, Millennium bim made available the Credit line AIMO (Industrial Association of Mozambique) aimed at supporting the development of industrial investment projects, treasury, and support to the imports of small and medium-sized companies, part of AIMO;

Credit line FECOP Calamities - created within the scope of the cooperation established between the Government of the Portuguese

Republic, the Government of the Mozambican and the Mozambican Banking Asssociation. It is aimed at financing investment projects and provide treasury support operations for Mozambican micro, small and medium-sized companies in the regions that the Government decreed as the most affected by the natural disasters. This tranche comprises all the operations affected by the impact of the Covid19 pandemic.

KFW credit line – made available in partnership with the German Development Bank, this fund is intended for Micro, Small and Mediumsized Enterprises (MSMEs), however it comes in two forms, generic and specific for the agricultural sector. Generic fund – made available with the aim of financing investments to improve its productivity and competitiveness and to generate employment. Specifically for the Agriculture sector – aimed at financing investments to improve the sector's productivity.

Individuals Support Solutions

The BCP Group provides products and services that, while meeting the needs and expectations of individual customers, also incorporate social benefits. Among these, we underline the following:

Portugal

  • University Loans– for students who decided to pursue their academic career, the Bank concluded, in 2022, within the University Credit Line, 36 new loans totalling 330 thousand euros. The volume of active credit granted to the 444 operations in the portfolio is 2.537 million Euros.
  • University Loans with mutual guarantee the Bank makes available to university students, a line with mutual guarantee. In 2022, 249 new loans were attributed, in a total amount of around 2.9 million euros. The volume of active credit granted to the 2,237 operations in the portfolio is 17.2 million Euros.

Aiming at encouraging the use of renewable energies, and protecting and improving environmental quality, in 2021, the Bank continued to offer the following credit lines:

  • Renewable Energy Personal Credit, product intended to finance the acquisition of equipment for the production of renewable energy. 41 operations were financed, in a total of 405 thousand euros;
  • Car leasing for new 100% electric vehicles with exemption from set-up fee. 34 operations were financed, in a total of 1,831 thousand euros;
  • At the beginning of the year, we launched the concept of Green Mortgage Credit which translates into the reimbursement, after contracting a Mortgage Credit for the Acquisition or Construction of properties with energy class A+, A or B, of part of the value corresponding to the Dossier and Formalization Fees. This offer is also applicable to financing for work on properties that already have an A+ or A energy class, or that obtain an improvement in their 2-level energy certification as a result of carrying out the works, benefiting Customers, in these cases, from a credit worth equivalent to the Dossier Fee and the cost of the Energy Certificate. 1,349 operations were financed, in a total of 297 thousand euros.
  • The Bank also launched in 2022 was a new fully digital contracting day for the Energias Renováveis Personal Credit on the App, in order to promote the use of renewable energies and the protection and improvement of environmental quality among digital Customers.

Mozambique

  • IZI Microcredit short-term financing (up to 45 days), currently available to Customers with salary domiciled at the Bank who meet a set of eligibility criteria, in order to meet small daily expenses. This product has no interest rate, and a fee of 4% is applied to the amount to be financed and is presented in amounts brackets ranging from 500 to 5,000 MZN. In 2022, credit recorded a significant increase compared to the previous year, having disbursed over the year, just over 3.7 billion MZN in 1.4 million operations.
  • Salary credit (In its pilot phase) short-term financing (up to 4 months), available through the Mobile Banking platform based on the percentage of the Customer's salary, in amounts ranging from MZN 5,000 to MZN 100,000, refundable in monthly instalments and which allows eligible Customers to meet specific needs without the need to go to a branch, immediately and completely digitally. In this pilot phase that has been in effect for 3 months, this product is accessible to 2,500 Customers, 5.2 Million MZN have already been disbursed in 252 operations, proving to be a product of great potential and adherence.
  • Millennium IZI the Bank's most transactional and accessible Mobile Banking platform, made available in 2013 through the USSD session (*181#) of national mobile operators, continues to stand out for its use with more than 788 thousand active users and an average 14.3 million transactions per month. With no access costs for the Customer, it offers a wide range of functionalities, with responses on the telephone screen and/or via SMS, in particular: checking balances and transactions, transfers, purchasing top-ups, Credelec, functionalities for using cards, and much more. In 2022, new tools were made available, such as: Transfers to m-kesh, the banking platform that is integrated with the three electronic money operators (Mpesa, e-Mola and M-kesh), adherence to the Bank's transactional Customer Line and purchase of personalized top-ups adequate to the Client's resources.
  • Smart IZI the 2nd most transactional mobile banking platform, with more than 177 thousand users, suitable for smartphones and tablets with android and ios operating systems, available to private customers from all segments. With a focus on digital, new functionalities of great value for the Customer were made available, among which we highlight: Western Union transfers, travel insurance, salary credit (still in the pilot phase), term deposits exclusive to the channel (DP Smart and DP Boas Vindas new Customer), obtaining proof of bank details, requesting and cancelling debit cards and subscribing to Mtop and Mtop+ transactional packages.
  • Mtop and Mtop+ transactional packages constitutes a set of products and services available to Private Customers, which allows adjusting Customer profiles to a more adequate offer of products and services marketed at the Bank, providing a better service at a more accessible cost. The MTop and MTop+ transactional packages comprise a Debit Card with exemption from annual fees, free withdrawals at ATM Bim, free monthly combined statement, exemption from the commission for intrabank transfers in Mobile Banking, personal accident insurance with a capital of 20,000, 00 MZN and immediate access to digital channels (Mobile, Internet Banking and the transactional Millennium bim Line), all for a monthly commission of 150 MZN and 250 MZN, respectively. In addition, the Mtop+ package gives the subscriber access to a TOP credit card, its attribution depends on the Customer's credit capacity. It currently has around 28.7 thousand subscribed Customers.
  • TD Boas-Vindas welcome term deposit for new Customers, whose account was opened less than 90 days ago, available in the Smart IZI App in a fully digital way. This product, besides competitive rates, provides the application user with flexibility in managing their savings, allowing the constitution to be fully digital and also ensures a fixed monthly income throughout its maturity.
  • TD Smart term deposit in national currency, available to individual Customers through Smart IZI, in a fully digital way, with competitive interest rates. With a maturity of 180 days, this term deposit has an incentive for subscribing Customers, who, by subscribing, qualify to win monetary prizes of up to MZN 30,000, through a draw held at the end of the year, where 3 (three) Customers became winners.
  • TD Milhão product intended for new resources, made up of MZN 100,000, with subsidized interest rates depending on the amount invested, associated with a campaign with prizes of up to MZN 1,000,000. At the end of the campaign, 3 (three) Customers were awarded with prizes between MZN 100,000 and MZN 1,000,000.
  • Credit line Mulher Empreendedora credit to support individual businesses, small and medium– companies managed by Women. This product intends to promote the development of projects related with the entrepreneurial spirit of women in Mozambique and boost the growth and appreciation of the Mozambican women through her involvement in activities that contribute for the growth of the economy.
  • As is usual worldwide, the last Friday of November is marked by product and service promotions in almost all sectors, it is the famous Black Friday. 2022 was not different, the Bank prepared 3 (three) initiatives, the first for attracting and retaining Customers, and, when opening a Demand deposit account and purchasing top-up in mobile banking on that date, the Customer would receive the top-up value back. The second was linked to credit, where Customers who applied for a personal loan on that date gained a 2% reduction in the interest rate and exemption from the financing setting-up fee. The third initiative linked to the use of bim bank cards, when making payments with bim cards at a Bim POS on that date, Customers received back 1% of the amount spent, with a maximum of 100 MZN per transaction.

Poland

The Bank's aim is to offer convenient solutions that really make life easier for customers and help them achieve their financial goals. This approach is illustrated by Millennium 360 ° – a new account offered by the bank since April 2022. The Millennium 360° Account offer is universal and designed to meet the needs of different groups of customers, regardless of age and income.

The Polish people is increasingly using online banking services on a daily basis. Research shows that 81% of the Polish people use mobile banking services regularly, while almost half of customers have not visited a branch for more than six months. For 41% of the Polish people, the convenient online bank is one of the main criteria used to select an account, together with the exemption of account maintenance fee. That is why, in response to changing customer expectations, the Bank launched Millennium 360° – a new free account combined with a wide range of personalized services in a mobile super-application.

With the new account, the Bank continues its strategy of developing customer-inspired services, developing the mobile superapplication that supports customers in various aspects of their daily lives and implementing hyper personalisation. All elements of this new offer were created based on extensive research into customer needs and key trends.

In addition to the Millennium360° account being completely free, after a simple condition is met (5 payments via card or BLIK, or 1 payment for people aged 18 to 26), debit card and BLIK contactless payments are also free and no commission is charged for withdrawals from ATMs in Poland and abroad. This means that customers with mobility issues (elderly or disabled) can use ATMs in convenient locations, without paying fees. Always unconditionally free are domestic transfers in PLN, standing orders and direct debits and BLIK transfers to a phone number.

Customers seem to appreciate the "Very Helpful" Package, offered in conjunction with the 360° Account, under which they can take advantage of home repair services, medical or computer assistance. Customers whose finances are not sufficient to pay practitioners to make home visits can benefit from these in case they or their children become ill. This package also includes the assistance of a plumber or electrician or the repair of equipment such as household appliances, radio and television equipment, smartphones and tablets. By selecting an account with the package "Very Helpful" the customers may benefit from 7 interventions per year. The package is free of charge for 3 months after the opening of the account.

Currency exchange is an important new element of the account – it features a currency limit, under which the customer can pay in any currency without being charged the bank's margin for currency conversion of up to PLN 1,000, at an attractive rate from payment organization. The Currency Package, which the customer can conveniently activate on the mobile app at a price of PLN 9.90 per week, includes unlimited currency transactions at an exchange rate, with no additional bank margin for currency exchange.

With younger customers in mind, the Bank's offer also includes the 360° Junior Account for customers who have not yet turned 18. Seeking to help them take their first steps in the world of finance, the Bank does not charge commissions for operating an account, while the debit card and ATM withdrawals are free as long as they carry out at least one transaction per month with a card or payment by BLIK. Children aged 7 to 12 can use a mobile app and payment card for the Junior 360° Account designed to meet the needs of younger users. These modern tools help introduce children to the world of finance and teach them how to use technology safely.

Debt repayment assistance – Bank Millennium provides a debt consolidation loan, with the option of incorporating the debt to other banks, to customers looking for an opportunity to reduce the costs of servicing in their current liabilities. In addition, Customers can take advantage of the deferred payment of an instalment of a cash or consolidation loan, which represents an important help in the event that the funds allocated for an instalment in a given month are used for other purposes.

Millennium Bank also provides mortgage loans for the renovation or modernization of buildings, under which Customers can use the funds to replace the roof or the central heating system.

The BCP Group promotes the transparency of remuneration policies with regard to integration of sustainability criteria

Social Inclusion

In line with the Sustainable Development Goals (SDGs) of the United Nations.

In Portugal, within the scope of Entities that incorporate the social industry, Millennium bcp keeps available the Non-Profit Association Account, a current account with special conditions that does not require minimum deposit to open and has no maintenance and overdraft fees. 338 accounts with these features were opened in 2022, corresponding to a total of 5,145 accounts in the Bank's portfolio.

So as to ease the inclusion of institutions from the third sector in the financial system, in 2013, a protocol was signed with Instituto de Emprego e Formação Profissional, Cooperativa António Sérgio para a Economia Social and the Mutual Guarantee Societies, defining a credit line – Social Investe – to support social economy. In 2022, the Bank maintained 2 operations in portfolio, with a total value of 20 thousand Euros.

Regarding the support to enterprise creation investment projects by unemployed persons, through the following credit lines: i) Microinvest Line - which financed 41 entrepreneurs to a total of 516 thousand Euros; and ii) Invest+ Line which supported 22 entrepreneurs, to a total value of 952 thousand Euros.

Within the scope of the inclusion of individual Clients (resident and non-resident) with low incomes in the financial system, the Bank was one of the banking institutions that voluntarily provided the current account – Minimum Banking Services–, without associated costs, this account can be used with a debit card and through online banking. In 2022, 6,283 accounts were opened, presently accruing to 21,574 accounts.

Charitable Cards

In Portugal, the credit cards issued by Millennium bcp continue to promote solidarity:

Loyalty Programme – encourages Customers to exchange the points on the card into donations to charitable institutions. Within this scope, the cards from the network Visa/Mastercard (Catalogue of Points) delivered 237 donations in a total amount of around 3,070 euros to institutions such as Liga Portuguesa contra o Cancro, Ajuda de Berço, AMI and Associação Portuguesa de Bombeiros Voluntários;

We highlight the launch for the first time in Portugal of a biodegradable plastic card, produced from cereals, which contains zero plastic and has zero impact on CO2 levels, the GO! Changer. The card GO! The Changer also supports the cleaning and decontamination of the beaches, with a contribution of €1 for each card sold, and with 0.1% of the value of purchases on the VISA network, for the Brigada do Mar Association. The Associação Brigada do Mar, as a Non-Governmental Organization for Development, it entered into a partnership with Millennium bcp within the scope of the SDG (Sustainable Development Goal) – Protect marine life, and specifically in the development of actions aimed at protecting biodiversity and environmental intervention.

Especially addressed to customers aged between 18 and 30 years old, the GO! Changer intends to grow awareness, involve and influence the younger generations for the importance of sustainability. The GO! Changer reinforces our positioning and commitment to sustainability, promoting a culture of environmental and ecological responsibility, with a positive impact on our customers. It is a limited edition of 10. 000 cards and 10 000 customers that, on a daily basis, are, with their payments contributing to finance environment protection activities. The objective in the near future is to be able to guarantee a commercial offer of cards that, in its entirety, respects and contributes to environmental sustainability by reducing or reusing plastic produced from non-renewable sources. In 2022 were delivered €5.573,50 to Brigada do Mar, under this partnership, for the development of actions to protect biodiversity and environmental intervention.

Dematerialization, with solutions that allow the normal use of your payment cards, without their physical presence, continues to be a priority for Millennium bcp. The national solution MB WAY leads in digital payments, with more than 1,5M customers paying, transferring and also making withdrawals in ATM, only using the mobile phone.

With a universal in scope, although on a different scale, many of our Customers already pay with their mobile device, using Apple Pay and Google Pay services, anywhere in the world. The year of 2022 was marked by the launching of the service Google Pay and the consolidation of the remaining ones.

In Poland, Bank Millennium extended its strategic partnership with the WWF (Worldwide Fund for Nature), centred on education activities for nature conservation. The partnership continues under the motto: Take care of the forest! Home for animals, breath for people and climate protection. As part of the cooperation with WWF, Bank Millennium will provide financial support for the organization's statutory activities to protect forest ecosystems. The cooperation involves, among others, the issuance of the WWF Millennium Mastercard credit card, which allows committed customers to support nature conservation efforts. Bank Millennium donates 50 PLN to the organization for each WWF Millennium Mastercard issued. The card is made from 85% recycled plastic and offers deferred reimbursement of up to 51 days, attractive exchange rates for transactions in any currency and the possibility of making payments in instalments.

Thanks to its virtual form, the goodie eCard is a convenient and environmentally friendly way to give a gift. The card can be set up in just a few moments on the goodie mobile app. In addition, the goodie app provides access to electronic versions of store flyers from various commercial networks, reducing paper consumption.

In Mozambique, the Bank provides the debit card "Woman", for the female segment, which offers, besides discounts on a set of business establishments and access to several online channels, a health insurance that covers treatment expenses for breast and uterine cancer and childbirth health care. This card includes the "Woman Package", a set of financial products and services thought out to meet the specific needs of Women.

SRI Funds (Socially Responsible Investment)

GRI FS11

The BCP Group meets the needs of Investors that consider it relevant to cover, in their investments, social and environmental risk factors, placing Responsible Investment Funds at their disposal for subscription:

In Portugal, SRI funds are available for sale on the online and physical platforms of Millennium bcp and ActivoBank, with the decision being made in 2022 to classify this type of product under the SFDR (Sustainable Finance Disclosure Regulation), in accordance with your contribution/promotion to environmental and/or social sustainability:

  • Article 8 Light Green: investments associated with the product promote environmental and/or social sustainability.
  • Article 9 DarkGreen: the goal of the investment is exclusively sustainable

Millennium bcp had 272 Sustainable Investment Funds on sale at the end of 2022 (255 Artº 8 and 17 Artº 9) which represented an accumulated portfolio amount of 5,632.2 billion euros (99% of which Artº 8). At the end of the year, the total amount invested in these Funds represented around 71% of the bank's total investment fund portfolio.

ActivoBank had 215 funds with subscribed UPs (197 Art. 8 and 18 Art. 9), in the amount of 97.863 million euros (91.6% of which Art.8). At the end of the year, the total amount invested in these Funds represented around 71% of the bank's total investment fund portfolio.

In Poland, Bank Millennium integrated ESG factors in the asset selection processes in investment portfolios, in order to respond to the growing concerns of investors with sustainability criteria in their investment decisions. Bank Millennium had 27 funds with subscribed PUs (22 Art. 8 and 5 Art. 9), which represented a total amount of 1,081.7 million euros invested. Bank Millennium SRI funds are available for sale either at branches or through electronic channels (homebanking and APP).

Service Quality

Material issue:

CUSTOMER SATISFACTION AND EXPERIENCE

In Millennium bcp the quality of service is ensured by the ongoing implementation of initiatives that contribute to achieve an enhanced rigour and control of execution, ensuring that the operational and business processes function in an efficient and reliable manner, being continuously monitored and perfected, thus contributing to a progressive increase of customer satisfaction.

Satisfaction Surveys

GRI 102-43, 102-44

In Portugal, Millennium bcp continues to focus on the model of "Assessment of Customer experiences". In the 24 hours after interaction with the Bank, the Customer is invited to answer a brief questionnaire to assess Customer satisfaction with his/her experience with the Bank and the corresponding level of recommendation.

The year 2022 was characterized by being a year in which, in general, Banking in Portugal made downward adjustments in the distribution network, in the number of Employees

at Branches and in continuing the migration of Customers to automatic channels. These factors,combined with strong market pressure, had an impact on Customer Experience and Satisfaction

The NPS (Net Promoter Score) indicator - the difference between the percentage of Promoter Customers (who rate 8 or 9 on a scale of 0 to 9) and the percentage of Detractor Customers (who rate between 0 and 5 on the same scale) -, which reflects the level of recommendation with the Bank, registered, in 2022:

  • In Prestige Customers a slight decrease to 64,0 points NPS, less 0.9 points than in 2021. This value includes "Physical" Network Prestige Customers, who recorded a slight drop to 65.7 NPS points, 1.1 points less than in 2021, and "Direct" Prestige Customers (remote monitoring), in which saw an increase to 58.2 NPS points, 1.1 more points than in 2021;

  • Also in the Mass Market Customer segment, there was a decrease in NPS translated into a decrease of 1.5 points, to 73.6 NPS points.

  • The same trend was seen in the NPS of the Business Customers which also decreased, moving down to 65.5 NPS points, less 1.8 points versus 2021.

Based on these results by segment, the overall NPS of Millennium bcp is 70.9 NPS points, an indicator that had been evolving positively since the evaluation process began in 2013, reaching this year the highest value ever (72.5 points)., having recorded this year a slight deceleration.

Another issue dealt with was the recommendation of the service provided by the Employee / Account Manager. This indicator, after reaching the best value ever in all segments and, consequently, in the NPS Global Attendance in 2021, again recorded a very high NPS value in 2022, 84.1 NPS points (-0.3 points compared to to 2021), continuing to position itself at a level of excellence.

The Bank assessed over 125,000 experiences of Clients who visited Branches of Millennium bcp or were contacted by Client Managers.

In addition to the experiences of Customers with Branches and Customer Managers, on which the aforementioned indicators are based, Millennium bcp recurrently evaluates other experiences of Customers, namely (i) Opening Accounts for Individuals, Companies and Portuguese Diaspora, (ii) Complaint Management, (iii) interaction with the Contact Center, (iv) Portuguese Diaspora Customer Service, (v) Mortgage Credit in its various aspects, (vi) the moment of Account Closing in order to determine the reasons for abandonment by Customers, (vii) the use of the Millennium Transaction Machines (MTM) and (viii) the 1st Anniversary of the Integrated Solution.

Overall, in 2022, 35 surveys were carried out, using different methodologies, to monitor Customer satisfaction with the various Direct Channels and Business Networks, translating into more than 229,000 experiences with Millennium bcp evaluated by Customers.

The remote channels satisfaction levels remained high. An example of this are the 86% of the user clients who replied that they are happy or very happy with the Internet Banking - Companies, of which the 79% of Mobile Banking Companies are an example.

Millennium bcp's Quality and Satisfaction Models Department maintains a policy of simplifying and optimizing processes, opting, whenever possible, for more efficient and sustainable channels for conducting surveys.

Accordingly, some processes of Evaluation of Experiences, which had exclusively human intervention through telephone contact, have been migrated to automatic channels, which allow not only a more robust process due to the increase in the number of responses, but also, more sustainable in terms of terms of costs and resources. An example are the Evaluation of Experiences for Microbusiness Customers and the Evaluation of Experiences for Complaint Management.

Throughout 2022, we conducted 4 Mystery Customer actions, totalling 1,422 visits to Millennium bcp Mass Market branches and 583 visits to branches of other banking institutions. The purpose of these actions is to assess customer servicing to be able to continuously improve the experience of our customers when they visit our Branches. We obtained a global score of 81.6%, which compares with the average global score of 68.2% of the other institutions, and is above that obtained in 2021 (78%). These results prove the continuous investment in improving Customer service and the positioning of Millennium bcp in the use of the best practices.

We continued to reinforce the skills of our Employees in order to improve our Customers' experience and, in this sense, the B#1 Prestige program was launched in May 2022, comprising a catalog of 14 training modules on various topics, which will end on March 31, 2023. From these, we shall extend two of them to all Retail:

(i) "Propósito e Felicidade" will be extended to all Retail platforms. So far, 21 two-hour sessions have been held between the 14th and 25th of November, with the presence of 100 Branch Directors and 369 Customer Managers. The evaluation of the trainees was very positive, having reached a score of 4.6 on a scale of 1 to 5 (by the MBA); (ii) "Jornadas Digitais na App" we have distributed 16 videos on the e-learning platform demonstrating the main days on the Millennium bcp App and we have another 5 in production. This is to say that this will be the main Focus in 2023 so that Employees and Customers get to know our App, become fans and promoters of it.

We continued with the "Momento #1" project, promoting weekly videos on product features, use of tools and best practices in customer service. We continued the process of Employee Certification on Personalized Management Platforms.

Since Employees constitute one of the strategic pillars of the BCP Group, their level of satisfaction with the service provided by the different internal areas - with direct relation and reflection on the quality of the guaranteed Customer service - is an important endogenous indicator to assess the Bank's effectiveness and perceived efficiency.

The opinion surveys were maintained regarding the satisfaction with the internal service among Employees who interact with other areas to perform their duties, in order to, as part of a continuous improvement policy, identify opportunities for improvement and optimisation of the processes, operational procedures, technological solutions and procedures in force. In Portugal, this research is performed annually, and the global value obtained in the 2022 study, 78.5 index points (i.p.), is slightly below that recorded in the previous year (79.0 i.p.), although remaining at a very positive level.

In the first half of 2022, we continued the surveys of Employees related to the pandemic, maintaining the Bank's focus and concern with the health of Customers and Employees.

Throughout the year, a total of 22 Employee surveys were carried out, essentially aimed at the continuous improvement component of operating processes and the COVID-19 Contingency Plan.

With the objective of enhancing the measurement of the satisfaction and loyalty of the several Customer segments, Millennium bcp continued to follow-up several external market studies made by specialized companies so as to get indicators enabling to position the Bank in the sector and assess, in an ongoing manner, the market's perception in what concerns the quality of the service provided, the Bank's image and the products and services it trades.

One of these studies is the CSI Banca, carried out by Marktest. It is a reference study for the banking sector, based on an econometric model that aims measuring the satisfaction and loyalty of the Customer and its perception of the quality of the products and services pursuant to a benchmarking rationale.

Millennium bcp was positioned this year in 2nd place in the CSI Banca Index among the 5 largest Banks operating in Portugal, with a score of 77.1pts.

The CSI Banca index is a result of two indexes, one which intends to evaluate the satisfaction of the Clients which prefer to use the Banks' branches (Index CSI Branch) and another which intends the evaluate the satisfaction of the Clients who prefer to use internet banking solutions (CSI Internet Banking Index).

Another study monitored is BFin, conducted by DATA E, dedicated to the description of the banking sector in Portugal from the perspective of companies, regarding the products and services offered by banks.

In the 2022 survey, Millennium bcp was once more considered the Main Bank for companies in Portugal. It is also referred to as the " The Bank closest to corporate customers", the "Bank with the Most Suitable Products for Companies" and the "Globally Best Bank for Companies".

In the "Consumer Choice", a Consumer Choice study - Millennium bcp was once again distinguished in Portugal and in the "Big Banks" category, as "Consumer Choice" in 2023, with a final score of 83.41% and a score of satisfaction of 84.13%.. This is the third consecutive year that the Bank has received this distinction. In 11 editions of the Consumer Choice Award, Millennium has won 7 editions.

Consumer Choice aims to publicly promote the companies that have services and products with a high level of satisfaction and acceptability among consumers, helping them to make an informed purchase regarding a given product and service.

Also at the end of the year, Millennium bcp learned that it was the winner of the "2023 Five Star Award", with an overall rating of 78.40%, in the Large Banks category, a study to which it had applied, for the 1st time, this year from 2022. Consumers also gave victory to Millennium bcp in two other categories of these awards - "Banking Apps" and "Financial Planning Simulator".

The Five Stars Award is an evaluation system that annually measures the degree of satisfaction that products, services and

brands grant to their users, within the respective consumption category. Its evaluation criteria are the main variables that influence the purchase decision of consumers.

In 2022, Millennium bcp was once again recognized, within the scope of its digital channels, for the continuous commitment it has made to strengthening functionalities, providing innovative products and services, simplifying processes and on security issues.

Global Finance magazine distinguished us as the "Best Digital Bank" (Best Consumer Digital Bank) in Portugal for 2022, within the scope of the World's Best Digital Bank Awards 2022, and also in three other categories:

✓ The Best Information Security and Fraud Management in Western Europe for 2022 (Consumer);

✓ The Best in Social Media Marketing and Services in Western Europe for 2022 (Consumer) and;

✓ The Best Information Security and Fraud Management in Western Europe for 2022 (Corporate);

The Millennium App was distinguished, in the Product of the Year Portugal awards, with the "Product of the Year 2022" award and with the Five Star Award, in the "Banking Apps" category.

Millennium BCP was also distinguished in "Best Homebanking website in 2022", within the scope of the awards "leitor PC Guia 2022."

At the Portugal Digital Awards, iziBizi, the first Bank Account Invoicing and Management Program that merges the Cloudware Business invoicing and management software with the financial services and Open Banking API, won

the "Best Digital Transformation Project" in Portugal, the "Best Banking Project" and the "Best Future of Business Models Project".

Millennium bcp was once again elected as the "Best Digital Bank", in 2022 for the 5th consecutive year, with 64% of nominations in the total of Clients of the study Brand Score, another study that we follow, carried out by Scopen, whose primary objective is to assess the impact of the Brand and Communication in terms of notoriety, image, customer loyalty and attraction of new customers. In this study,

Millennium bcp is also recognised as the "Best Companies' Bank", also for the 4th consecutive year, with 49% of the nominations (+4pp compared to 2021).

As Quality KPI's (Key Performance Indicators), we adopted the Global Satisfaction (NPS) and Bank Recommendation (NPS) indicators from the BASEF Study by Marktest, having reached the 1st ranking position in 2022 in both KPI's, among the five largest banks operating in Portugal. For 2023, the KPIs are maintained, with the aim of positioning ourselves in the TOP2 among the TOP5 of the largest banks operating in Portugal.

All these results translate the Client's recognition of the ongoing effort made by Millennium bcp to provide a service of

excellence, focused on modernisation and simplification of products and services, the proximity with the Clients, swift operations and in the sustainability of its value proposal.

In 2022, 32 inquiries were sent to the Bank by DECO (26 in 2021), on the most diverse topics, with an average response time of 10 days (in 2011 it was 15 days).

Millennium bcp is committed to meeting the expectations of its customers with convenience and agility, in a personalized way and with high quality, with solutions supported by excellent human service and cutting-edge mobile and digital platforms, in order to continuously maintain its reputation as a bank - CUSTOMER CHARTER - Individual Customers.

In international activity, the overall Customer satisfaction index with the Bank deteriorated significantly, from 84.0 to 79.5 p.i., essentially due to Mozambique, where the value registered was 71 p.i. (-9 p.i. versus 2021), despite the Recommendation index recording 78 p.i. The reasons for this drop had to do with 1) Waiting time for service at the branches; ii) Manager's ability to suggest new products complementary to those used by the Customer; and iii) Submission of proposals suited to their needs.

For Mozambique in 2023, the goal is to reach an overall customer satisfaction index of 75 points".

In Mozambique various studies have been done with a view to knowing the opinion, needs and expectations of Customers, of which we highlight the following:

  • "Millennium bim Corporate Customer Satisfaction Study", an online and annual survey aimed at identifying the problems with the greatest impact on the business and the key factors for Customer loyalty. The overall satisfaction of corporate customers registered a decrease of 9 points, standing at 61 points. The intention to repurchase registered a significant decrease of 10 points, standing at 63 points. The Bank's recommendation level recorded the biggest drop in terms of global indicators, by 13 points, standing at 56 points;
  • "Survey on Customer Satisfaction of the Corporate Network", an annual online survey aimed at contributing to increasing cross-selling and financial relationships with Corporate Customers. The intention to repurchase registered a significant decrease of 2 points, standing at 67 points. The intention of repurchase and the level of recommendation maintained the thresholds reached in 2021, 69 and 65 points, respectively;
  • "Satisfaction Research for Prestige customers", an online survey with the purpose of identifying improvement opportunities in the quality of the services provided, increase cross-selling and enhance customer attraction and loyalty in Prestige customers. The intention to repurchase registered a decrease of 5 points, standing at 72 points. The levels of repurchase and recommendation also decreased, the most significant one in the repurchase intention with 8 points, standing currently at 72 points. The level of recommendation recorded a 5 points decrease, standing at 68 points. The satisfaction with the Client Manager stood at 78 points, a 7 points drop versus 2021;
  • "Study to the Satisfaction of Clients M-Top", a online survey with the purpose of assessing the quality of the services provided in the newly-created segment. Global satisfaction remained at 73 points. The level of repurchase stood at 75 points, while the level of recommendation stood at 70 points. The satisfaction with the Manager reached 72 points.

Concerning the remote channels that support sales, the "Study of the evolution of dormant IZI Customers (active and nonactive)" was carried out, a telephone survey conducted by Quality Division employees in order to assess (i) Customer satisfaction with the experience of using IZI and (ii) the reasons for not using the channel. The level of global satisfaction is 83 points, a 10 points reduction versus 2021. The level of recommendation of the Channel was 81 points.

With the purpose of supporting the dynamics of the Banking Agents business and identifying opportunities for improving the functioning of the JáJá POS's, the "Study on Banking Agents" was carried out for the first time, a survey that was made by telephone, with the calls being made by Employees of the Quality Department. Overall satisfaction and continuity of use of POS's JáJá stood at 72 points. The level of recommendation of the Channel stood at 73 points.

To assess the satisfaction of Individual Customers with the experience arising from the use of Internet Banking in the carrying out of different day-to-day banking transactions, a "Satisfaction Survey with the Internet Banking Service" was carried out. The overall satisfaction stood at 77 points, the level of recommendation of the channel stood at 73 points.

"Evaluation of the Satisfaction of Prestige Customers", a phone survey made to measure the satisfaction of the Customers with

the interactions they have with the Bank and the segment's degree of recommendation. The level of overall satisfaction was 67 points, a 20 points reduction versus 2021. The evaluated interaction moments were: (i) Account Opening; (ii) 6 months after the opening of the account ; (iii) Contact/Visit made by the Manager; (iv) Financing process (Refused and Granted); (v) Management of Claims; and (vi) 6 months after the transfer into the Prestige Segment.

In the "Assessment of the NPS (Net Promoter Score) of the Millennium bim Branches", carried out through USSD sessions, Customers are invited to respond on their level of recommendation of the Bank after: (i) carry out a transaction at the Branch; (ii) carry out an operation in Mobile Banking; (iii) Credit Card activation; (iv) Credit disbursement - CNV; (v) completion of a claim; (vi) contact with Linha bim; (vii) opening of a Current Account; and (viii) periodic assessment of Prestige Customers. In 2022, globally 455,836 Customers were interviewed and the overall NPS was +69, a 6 points reduction versus 2021.

To ensure a quality and consistent Customer service experience, Millennium bim continued to monitor Service Quality, through the Operational Quality Index, a management support instrument that measures the rigour in the execution of operations and the branches' compliance with Service Levels in 5 metrics: (i) Time spent in the sending of account opening processes, (ii) Number of account opening processes that are returned (iii) % of de reversions in cash operations , (iv) % mistakes in ATMs e (v) Loan processes not handled on the day they take place. The overall score in 2021 was 3.2 points (objective: 3 pts).

As regards Internal Customers, the following Surveys were carried out in 2022:

  • The Bank carried out the "Suppliers Satisfaction Survey" with the purpose of assessing the quality of the services provided by the outsourcing companies, that recorded a response rate of 50%, and enabled identifying improvement opportunities in the services provided.
  • In its 11th edition, the bank launched once again the "Internal Customers Satisfaction Survey" with the purpose of contributing for the improvement of internal service by identifying the main obstacles faced by the Employees that depend on other areas of the bank to perform their functions. This survey had a high participation rate, 83%. The overall level of satisfaction with the services provided by all the Millennium bim Divisions was 70 points, a variation of 1 point compared with 2021.
  • To evaluate the experiences of internal service provision by Employees of the Commercial Network, the "Experience Evaluation of Internal Customers" was carried out, where the following processes are evaluated (i) Account Opening; (ii) Issuance of Payment Order Issued; (iii) Credit Contracting; and (iv) contact with SOS Rede.

We also continued to monitor 15 central service operations areas using the Balanced Scorecard (Balanced Performance Indicators), a management support tool that measures performance indicators, through a simple and actionable "scorecard", which ranges from 1 to 5 (lowest to best performance). The KPIs of each Organic Unit (OU) are distributed into 6 categories: Efficiency, Financial, Risk, Service (NS), People and Strategy. In 2022 all the OUs evaluated showed positive results.

Continuing with the goal of measuring the levels of satisfaction and commitment of its Employees to the Bank's objectives, the online survey " Organisational Climate Questionnaire" was carried out, one of the main instruments of the Employee Satisfaction Management System, which had a participation rate of 91%.

In the Suggestion programme "Ideas that Count", which tries to ensure the involvement of Employees in the culture of innovation, 493 ideas were presented by 294 Employees.

In Poland, Bank Millennium also benefits from robust processes and instruments to assess the quality of the service rendered to customers. In 2022, with 88 p.i., of overall satisfaction. In 2022, it was considered the Best Digital Bank by the Friendly Bank from Newsweek!. Also branch servicing showed a very positive evolution, showing 93% of satisfaction. The objective for 2023 is to maintain the customer overall level of satisfaction above 85 points.

As in previous years, Bank Millennium conducted its annual satisfaction surveys in the Mass Market and Corporate Areas, and continued to inquire into the Small Business and Affluent segments, providing a holistic view of all the Bank's business segments. The main objective of these surveys is to monitor the levels of satisfaction and recommendation among our Customers in the main business lines and to identify the main points of difficulty and satisfaction that influence them. Beyond the general opinion on cooperation with the Bank, all points of contact between the Customer and the Bank are assessed: contact channels (branches, internet, telephone banking and mobile banking) and people (e.g. branch consultants).

In this operation, whose surveys are done using an external company, "Mystery Customer" actions, there was a maintenance in the satisfaction indexes, as attested by the results obtained: Retail (NPS of 50) and Companies (NPS of 46).

Bank Millennium, materializing an holistic approach and aware of the impact that the popularity of the new digital channels is having in the behaviour and needs of the clients - an impact which is not only seen in electronic banking but also in traditional channels, namely the branches, -, has been making evaluations which, with the use of innovative techniques, enabled to improve the service space and choreography.

The Actions carried out by Bank Millennium were recognised by one of the most prestigious service quality classifications - the survey carried out by Newsweek. Bank Millennium was ranked first in the Traditional Bank category and second in Remote Channels. Bank Millennium also occupied a place on the podium in the ranking of Gold Bank.

In 2022, Bank Millennium carried out quantitative and qualitative studies on market trends and specific assumptions of products and services. Projects that use the Service Design methodology, wherein the full understanding of the customer's needs is crucial. These projects contributed to improve the quality of the service and to develop the offer of products. As in previous years, this research was carried out from samples of retail, companies and affluent (Prestige) customers and micro-companies (Small Business).

The monitoring philosophy of Customer surveysin all business lines is based upon two pillars: moments of truth and closing of the cycle. Within this approach, i) we measured the Customer experience at carefully selected moments; ii) we follow the Customer, choosing the method and timing of the evaluation; iii) we focus on strengthening the relationship with the Customer; iv) we are looking for opportunities to improve processes, procedures and products.

In 2022, the BCP Group was confirmed its presence in "The Sustainability Yearbook", a reference publication in the area of Sustainability published by S&P

Claims

Concerning claims on products and services, one of the priorities of the BCP Group is to ensure the ongoing improvement of its management in the countries where it operates, either by optimizing, simplifying and accelerating the reply procedures or by the regular assessment and monitoring of the satisfaction of the claimants with the solution presented to them. The identification and assessment of the origin of the claims aiming at their correction are also part of an unequivocal orientation of the Bank for Client servicing.

2022 2021 2020 VAR.% 22/21
CLAIMS RECORDED
Activity in Portugal: 66 557 53 976 44 474 23.3%
International Activity 135 271 118 777 128 200 13.9%
CLAIMS SOLVED
Activity in Portugal: 53 821 42 859 3 245 25.6%
International Activity 132 323 118 450 128 123 11.7%

In Portugal, the claims are managed by the commercial areas and by the Customer Care Centre (CAC).

(1) Includes claims accepted regarding disrespect of Customer privacy in Poland (94) and in Mozambique (9) due to operational mistakes in the processing of personal data.

In this operation, the number of complaints increased compared to the previous year, with a total of 66,557 (53,976 in 2021), mainly explained by issues related to cards, namely the acquisition of products and services through digital channels, which represent around 80% of all complaints filed Despite this increase, we were able to maintain the average resolution period at 5 days, to which the bank's constant effort to resolve complaints submitted by Customers as quickly as possible contributed.

The Customers of Millennium bcp may also bring to the Client Ombudsman claims due to actions or omissions by the Bank's corporate bodies and Employees. All the claims addressed to the Ombudsman Office are firstly handled and managed by the Bank's concerned areas and the Ombudsman Office is exclusively responsible for analysing and issuing a final opinion to claims received in connection with prior claims presented by the Customers that obtained an unfavourable decision.

The Ombudsman's Office, regulated by its own Regulations, is a body independent from the Bank0's hierarchical structures, defending and upholding the rights, guarantees and legitimate interests of Millennium bcp's customers that address it.

Activity in Portugal: 2022 2021 2020 VAR.% % 22/21
RECORDED CLAIMS 2,918 2,788 2,670 2%
Claims 2,745 2,533 2,249 8%
Requests 93 255 364 -64%
NEW CLAIMS 80 57 64 25%
Concluded 78 61 56 22%
Upheld 11 7 20 57%
Not upheld 67 54 24 18%
Average Response Time (days) 4 12 12 -67%

CLIENT OMBUDSMAN'S OFFICE

Thus, and looking at the activity developed in 2022, the Ombudsman Office received 2,918 claims (2,852 em 2021), a figure representing, in accrued terms and year over year, a 2.3% increase versus 2021.

The Ombudsman Office analysed 2,745 Claims (2,533 in 2021), that were forwarded to the Customer Care Centre, the area responsible for ensuring the analysis and final response to the claimants; 93 Requests (255 in 2021), were forwarded to the respective services of the Bank which are responsible for ensuring the claims assessment and final response to the claimants and 80 Appeals (64 in 2021) which, for their nature, were analysed and replied by the Ombudsman Office.

The rate of decisions in favour of the Customer was 14%, which compares with 11% in 2021, and the average response time was 12 days, identical to 2021.

The issues - from a product or financial standpoint - that raised the greatest number of claims from the Customers, were those

related to "Current Accounts" (31% vs 37% in 2021) and "Cards" (17% vs 12% in 2021).

When one assesses the business areas with a greater number of claims, the one showing the highest number is Retail Banking, with 81% followed by Activobank with 13%.

In Mozambique, there was a very significant increase in the number of complaints, which amounted to 32,124 (17,904 in 2021), and the worsening of the respective average resolution period to 29 days, explained essentially by the migration of means of payment to the network SIMO (process still underway). This process is mandatory and it is expected that the same will completed until the end of the year.

Poland recorded 103.147 (+ 2,3% versus 2021) and a slight aggravation of the average term for resolution, which went from 6 to 7 days. The majority of claims come from home loans, current accounts and ATM´s.

Bank Millennium implemented a set of Actions with the aim of streamlining the process of handling complaints, reducing analysis time and increasing the level of customer satisfaction, of which we highlight:

  • Robotization was used to handle recurring operational tasks. In 2022, a robot to support the registration of customer letters received by mail was implemented.
  • In 2022, the Bank subcontracted the archiving process of the letters of complaint received to an external company responsible for the incoming mail.
  • The Bank continued to monitor customer satisfaction on a monthly basis with regard to the complaints handling process.. The survey results were analysed. And the findings of the analysis were used as a guideline for taking steps to improve customer satisfaction.
  • The project "Abrace o Problema" is underway. It aims to support employees directly involved in attending to and solving customer problems, alerting them to the most frequent cases and the need to accept reasoned and complete notifications.
  • Guides were developed for employees at Branches and Contact Centers, which show how to properly resolve customer problems and to which department a particular complaint should be directed.
  • In 2022, the Bank started to cooperate with Banco Hipotecário in the area of complaints handling.
  • In 2022, the process for handling company customer complaints was transferred to the MilleResolver2 application and continuity was given to the "Direction for Quality" project, whose premises are as follows:
    • ✓ Regular e-mail education for Customer Relations Department employees responsible for handling customer complaints;;
    • ✓ Conducting regular workshops on simple language;
    • ✓ The monthly qualitative assessment of responses to complaints.
  • In 2022, a tool for creating and editing responses to complaints was developed, which is constantly evolving and includes new content, which is evaluated by consultants in plain language.
  • In the area of complaints, a wide range of ratios are reported, with the effects of the entire process of handling complaints presented regularly at meetings of the Process and Operational Risk Commission and also at the meetings of the Audit Commission of the Board of Auditors.

Concerning the product or financial service, the subjects that raised the highest number of questionings to the Client Ombudsman were related with Current Accounts and Cards

Fiscal Policy GRI 207 - 1, 2 and 3

The social responsibility of the companies require an increasing adoption of behaviours and commitments with the communities of which we are part of, such as the protection of environment, of social well-being and the quality of governance of institutions. More recently, a conscious and fair fiscal behaviour by the companies is becoming increasingly paramount, playing a key role in the corporate social responsibility of the institutions. The companies face high tax burdens (taxes, charges and contributions), a fact that often leads to aggressive fiscal planning, able of jeopardizing the desired fiscal responsibility standards.

The payment of a fair amount of taxes by the companies is becoming one of the main challenges of the European Union (EU (2018) Action Plan for Fair and Efficient Corporate Taxation in the EU) and of the OECD in its recent Report BEPS – (Base Erosion Profit Shifting) , the action of which includes controlling tax avoidance behaviours. Within this context, the concept of tax governance appears as a paramount element of the company's social responsibility and these ones are required to adopt good tax governance policies, such as: (i) compliance and timely payment of its tax obligations; (ii) the management of tax risks and (iii) the good relationship with the Tax Authorities, shareholders, investors and other stakeholders.

The good practices of fiscal responsibility of the companies also comprise the promotion of principles such as fiscal transparency, the careful and transparent definition of fiscal strategies and the disclosure of tax governance practices. Aware of the relevance of this theme, BCP complies with the tax burden it is subject to and adopted a policy of fiscal transparency based on the good practice of disclosing the amount of its taxes and contributions, as stated in notes 6 to 31 of disclosure of the annex to the financial statements.

It is also through this relevant contribution that BCP assumes itself as an institution that provides a relevant contribution towards the development of a more inclusive, fair and sustainable society.

(Principles of Millennium bcp on Fiscal Matters)

It is worth noting that the activities of the BCP Group carried out in countries, territories and regions with clearly more favourable tax systems, as laid down in Ministerial Order no. 150/2004, of 13 February, are already residual:

The entities BCP Finance Company and Millennium bcp Bank & Trust,with registered office in the Cayman Islands were liquidated in the course of 2022;

As at 31 December 2021, BCP Finance Bank, headquartered in the Cayman Islands, has a liability of 311 thousand Euros arising from a bond loan issued in March 2004, maturing in March 2024.

Disclosure of tax information

GRI 207 - 4

The activities of the BCP Group are subject to several types of taxes, rates and financial contributions, which, when considered globally, establish the level of taxation to which the BCP Group is subject.

The BCP Group discloses quarterly in its Annual Reports the main characteristics of the tax systems applicable in the countries where it operates, such as nominal income tax rates, the framework of tax losses/benefits and the most relevant legislative changes. Moreover, the information publicly disclosed in this context includes an analysis of the reconciliation between the nominal and effective income tax rate applicable to the BCP Group on the individual and consolidated basis. Through this analysis, the BCP Group explains the weight in its results of the income tax accounted for, which includes, overall, the impact of current tax and the impact of deferred taxes associated with existing temporary differences. In light of the International Financial Reporting Standards (IFRS) that govern the preparation and disclosure of the financial statements of the BCP Group, the analysis presented does not represent the tax paid or received by the BCP Group in the period to which it relates.

The BCP Group, as a group of multinational companies, fully complies with the annual communication and reporting obligation, which translates into a financial and tax declaration per country, and which results from the transposition to Portuguese tax law (Article 121-A of the IRC/corporate tax Code) of the provisions of Action 13 of the OECD project on BEPS. This reporting obligation is fulfilled in Portugal by BCP, as the ultimate parent entity of a multinational group of companies, according to the established legal deadlines, respecting the last reporting period to the financial year of 2020.

Information included in the 2021 financial and tax return by country

Below we reproduce the financial and tax information by country reported by BCP to the Portuguese tax authorities, as the ultimate parent entity of a multinational group of companies, in respect of the 2021 financial year (amounts in thousands of Euros):

Tax
Jurisdiction
Unrelated
Party
Revenues
Related
Party
Total Profit
(Loss)
Before Income
Tax
Income
Tax Paid
(on cash basis)
Income Tax
Accrued – Current
Year
Specific taxes on
the banking sector
paid*
Stated capital Accumulated
earnings
Number of
Employees
Tangible Assets
other than Cash and
Cash Equivalents
Portugal 2 181 347 50 220 2 231 567 156 844 7 575 8 900 77 198 23 587 830 -17 300 509 6 263 335 288
China 10 811 32 148 42 959 6 525 982 1 783 0 0 13 076 20 3 953
France 2 206 0 2 206 2 159 263 176 0 0 25 619 0 0
Netherlands 0 0 0 -337 0 250 0 18 -43 740 0 0
Cayman Islands 210 21 871 22 081 5 295 0 0 0 600 264 130 452 4 22
Poland 3 361 490 -46 3 361 444 -219 394 43 419 43 548 99 430 264 647 1 133 376 7 079 119 939
Mozambique 264 026 104 264 130 104 890 1 633 26 696 0 61 728 435 721 2 496 77 895
Brazil 56 0 56 -776 0 0 0 9 902 -9 762 6 228
Ireland 3 918 0 3 918 -3 003 0 0 0 40 14 035 0 0
*The information on the Specific Taxes on Banking that have been paid is not reported to the tax authorities in the Financial Statement.

Below we reproduce the financial and tax information by country reported by BCP to the Portuguese tax authorities, as the ultimate parent entity of a multinational group of companies, in respect of the 2022 financial year (amounts in thousands of Euros):

Tax
Jurisdiction
Unrelated
Party
Revenues
Related
Party
Total Profit
(Loss)
Before Income
Tax
Income
Tax Paid
(on cash basis)
Income Tax
Accrued – Current
Year
Specific taxes on the
banking sector paid*
Stated capital Accumulated
earnings
Number of
Employees
Tangible Assets other
than Cash and Cash
Equivalents
Portugal 4 130 671 74 987 4 205 658 509 497 14 733 15 162 88 511 22 096 825 -15 373 539 6 222 301 632
China 33 403 8 245 41 648 18 554 1 787 1 947 0 18 646 23 3 713
France 0
0
0 0 0 0 0 25 619 0 0
Netherlands 82 913 0 82 913 87 509 0 75 18 43 694 0 0
Cayman Islands 64 6 310 6 374 5 041 0 0 230 882 55 433 1 0
Poland 4 829 260 254 4 829 514 -156 068 56 341 56 333 120 946 259 124 892 023 6 987 122 354
Mozambique 383 011 3 826 386 837 137 985 -1 36 115 65 997 390 815 2 504 83 868
Brazil 0
0
0 -1 066 0 0 12 425 -12 347 6 208
Ireland 6 165 0 6 165 462 0 0 40 14 498 0 0

*The information on the Specific Taxes on Banking that have been paid is not reported to the tax authorities in the Financial Statement. e fiscal por país.

We underline the following relevant aspects to justify effective income tax rates lower or higher than the nominal rates in force in the most relevant tax jurisdictions:

  • In addition to autonomous taxation on IRC (corporate tax) and State and Municipal Surcharges, the expenditure on income taxation of the BCP Group in Portugal in 2021 and 2022 translates mainly into expenditure on the reduction of Deferred Tax Assets as a result of deductible temporary differences recorded in previous years in terms of loan impairments, post-employment benefits and impairments relating to investment in subsidiaries. The expenses in question are also influenced by the non-tax deductibility of some taxes on the banking sector in Portugal.
  • In terms of the activity developed in Poland, the income tax values in 2021 and 2022 were strongly conditioned by the constitution of provisions related to legal risks associated with the home loan portfolio granted in foreign currency and by the taxes on the banking sector, partly non-deductible for tax purposes.
  • The results obtained in China, within the scope of the activity of the Macao Branch, are also taxed in Portugal at the income tax level. The positive results obtained in the Cayman Islands are attributed for tax purposes to Portugal and the Netherlands, and are taxed in those jurisdictions for income tax purposes.

Specific taxation on the banking sector

The specific taxation on the banking sector bears a significant weight within the BCP Group and, as a general rule, it is not related to the result of the economic activity developed, thus reducing part of the shareholder value. Poland and Portugal assume, in this context, for different reasons, as countries with a higher level of taxation.

In the case of Portugal, the significant level of taxation, is translated both in terms of the number of contributions and the amounts collected, even after the change and harmonisation of the regulatory framework of the resolution mechanisms and their financing within the European Union from 2015. In fact, since 2015, the two domestic resolution contributions and the contribution established by European Union law under the Single Resolution Mechanism have coexisted, with an additional solidarity levy on the banking sector since 2020, created under the pretext of the VAT exemption applicable to most banking operations but which in no way benefits banking institutions.

The values of taxes on the banking sector paid by the BCP Group in Portugal amounted to the following amounts:

(Euros)

Banco ActivoBank SA BCP
2022 2021 2022 2021
513 395 441 022 87 997 835 76 756 589
252 181 230 035 36 546 661 32 866 941
45 851 38 395 6 644 480 6 150 542
128 062 117 946 18 540 148 16 834 600
50 000 50 000 25 797 457 20 835 631
37 301 4 647 469 089 68 876

In the case of Poland, in 2022 there was an increase in mandatory contributions of around 26.5 million euros, mainly due to the contribution to the Polish institutional protection fund, which did not exist in 2021. The creation of this new contribution was partially offset by the reduction in amounts paid to the deposit guarantee fund (only the amounts relating to the first quarter of the year were paid) and by the suspension of payment of the special tax on the banking sector following the activation of the Polish subsidiary's Recovery Plan.

The values of taxes on the banking sector paid by the BCP Group in Poland amounted to the following amounts:

(Thousand Euros)
Millennium Bank
2022 2021
120 946 94 430
36 107 68 520
17 821 10 661
8 046 15 249
58 972

Other contributions borne by BCP

In 2021 and 2022, the banking activity developed by BCP Group in Portugal also supported the following taxes:

(Euros)
Banco ActivoBank SA BCP
2022 2021 2022 2021
Operating Costs (includes used provisions): 2 715 776 2 269 357 65 705 316 72 776 068
VAT borne 2 656 475 2 259 976 52 920 557 63 247 777
Stamp Tax 59 301 9 381 7 026 863 3 663 938
Municipal Property Tax (IMI) and Additional IMI - - 2 322 853 3 055 268
Payments to Regulators / Supervisors (ECB/BdP, CMVM) - 3 435 043 2 809 086

IRS/IRC withholding tax and stamp tax collected in the banking activity

With respect to taxes collected by the BCP Group in the banking activity carried out in Portugal and transferred to the Portuguese State (third party charges), their value exceeded 280 M€ in 2021 and 290 M€ in 2021, and it should be stressed that the activity of tax collection on behalf of the State absorbs significant resources:

(Euros)
Banco ActivoBank SA BCP
2022 2021 2022 2021
Taxes withheld / collected from third parties: 6 204 219 5 120 187 284 883 416 281 670 641
Income tax 2 394 131 2 045 580 139 058 650 145 725 787
IRC (corporate tax) 8 274 13 895 11 504 859 9 702 784
Stamp Tax 3 575 360 2 810 888 101 299 656 100 407 878
VAT (net amount collected) 226 454 249 824 33 020 252 25 834 192

Portugal is, within this context, the country with the highest level of taxation, even after the change and harmonisation of the regulatory framework of the resolution mechanisms and their financing within the European Union.

Social Responsibility

Social responsibility

The BCP Group's strategy aims at promoting a culture of social responsibility, developing actions for and with several groups of Stakeholders to, directly and indirectly, contribute to the social development of the countries where it operates.

Thus, it is within this context of proximity to the community that the Bank has been materialising its policy of social responsibility, giving priority to its intervention in cultural, educational and social initiatives.

SDG Our goals Our contribution in 2022
Promoting employment and
social innovation
through support to
social companies
Financing, support and products addressed to social enterprises
Initiatives:

Non-Profit Associations Account - a current account with special conditions.
Results:

Opening of 338 Non-Profit Associations accounts, corresponding to a total of 5,145
accounts in the Bank's portfolio.
Contribute to improving the
quality of life and reducing
poverty
Community donations and collaboration on community support initiatives
Initiatives:

Partnership between Fundação Millennium bcp, Millennium bcp and EPIS, with the
objective of bringing together a group of Employees/Volunteers of Millennium bcp
to give explanations to students from disadvantaged backgrounds.

Food collection campaign promoted by the Food Bank, with around 124 Volunteers
enrolled, including employees, family members and friends, distributed by the
Food Bank Warehouses.

#WelistenWEsupport – Bank Millennium program with activities that focus mainly
on financial education, cultural sponsorship, academic support and volunteering.

Project "Girl Move" – partnership with the association whose objective is to help
young Mozambicans to have access to more and better training, in order to break
the cycle of poverty and, in this way, build their own future and contribute to a bet
ter society.
Promote the financial liter
acy
of the population, contrib
uting to a
more informed management
of personal finances
and promoting entrepre
neurship
Promotion of financial literacy actions
Initiatives:

Program of Digital Literacy in a partnership with APB - training program on digital
banking, aimed at the senior population, who are not yet familiarized with the use
of banking.

Launching of a new website with financial literacy content – "Saber de Contas" –
aimed essentially at three target audiences: young people, bank customers and the
senior population.

Financial ABC Program, a financial literacy programme of Foundation Bank Millen
nium, whose object is to give basic financial concepts to pre-school children.

Banking Olympics - project whose main objective is to train young people in terms
of financial knowledge, allowing them to make responsible decisions in the man
agement of their savings.
Contribute for the
development of
entities in the social econ
omy sector by the provision
of training in management
Training for managers of social entities within the scope of the GOS Program (Management
of Social Organizations) by AESE
Results:

The 2022 edition had 53 participants.
SDG Our goals Our contribution in 2022
Ensure equal opportunities
at work and reduce and re
duce inequalities (internally)
Promotion of equal opportunities
Initiatives:

The award "Wrocław without barriers", was attributed to Bank Millennium for solu
tions that enable the use of digital banking, for the implementation of adaptations
aimed at people with disabilities and for conducting training actions on serving
people with special needs.

Participation in the Inclusion Labs within the scope of Inclusive Community Forum
(ICF)

Formation of two classes of the training session Succeed in the World, which aims
to boost key concepts that improve social skills and the employability potential of
disabled individuals.
Results:

56% of the training hours supplied is addressed to women

No. of employees with disability: 221

Participate and sharing

In 2022, with the easing of restrictions on the movement and gathering of people resulting from the pandemic context caused by Covid-19, Corporate Social Responsibility initiatives, in particular those that provided for Volunteering actions on the ground, were progressively resumed, albeit mitigated, considering the prevailing climate of uncertainty and fear in terms of public health, which lasted during the 1st half of the year in the different geographies of the BCP Group.

Donations allocated by intervention

area

Even so, in Portugal, the following face-to-face volunteer actions were carried out in communities:

Carrying out a Corporate Volunteering Action of an environmental nature - beach cleaning (meco beach, between Lagoa de Albufeira and Alfarim for a total of 2.5 km). The Action took place on October 6 and had the presence of 9 Volunteers from several areas of the Bank. The action was organized by the "Brigada do Mar", a Portuguese NGO (Non-Governmental

Organization for Development), whose main activity is the decontamination of the coastline, within the scope of the collaboration protocol established between the Bank and this Organization.

This initiative was developed within the framework of the new Corporate Volunteering Policy and the Program that materializes it, whose objective is to promote a culture of participatory corporate citizenship, with a view to contributing to the development of the communities in which the Bank is present and responding to the challenges that arise in the social, environmental and corporate governance axes, aligning its activities with the Group's Sustainability strategy.

We once again took part in the regular food collection campaigns promoted by the Food Bank, carried out in May and November, which were attended by 124 volunteers (49 in May and 76 in November), including Employees, family members and friends, spread over five of the warehouses in Portugal (Braga, Lisbon, Porto, Santarém and Setúbal), helping with the separation and packaging of donated food.

In 2022, we returned to face-to-face volunteering, with actions carried out in the main geographies of the BCP Group with the participation of 576 volunteers, which corresponded to 3,066 hours of volunteering. This aggregated value made it possible to exceed the target of a 2% increase in volunteer hours, based on the (pre-pandemic) year of 2019, in which we recorded a total of 2,939 hours.

In 2023, materializing a strong social commitment that allows us to be (always) closer to communities and People, we aim to increase by 4%, when compared to the same period, the total number of hours of Volunteering in the BCP Group.

Within the scope of the new Corporate Volunteering Policy and the Program that materializes it, a partnership was established between Fundação Millennium bcp, Millennium bcp and EPIS – Entrepreneurs for Social Inclusion, with the aim of bringing together a set of Employees / Volunteers of Millennium bcp with interest and availability to give explanations to students of the 2nd and 3rd cycles of schooling from disadvantaged backgrounds (with a greater risk of failure and dropping out of school), thus helping to promote their social inclusion through school . 11 employees volunteered to give explanations of various subjects, through digital means, until the end of the school year, for 1 hour/week.

EPIS is responsible for the largest civil society involvement program in promoting the social inclusion of young people through school success and professional insertion, which has allowed, since 2007, that around 65,000 students, from the 1st year of

schooling to secondary education, were analysed in relation to their risk profile of school failure and that around 30,000 students were monitored throughout the country and saw their academic success continuously increase. EPIS works in close partnership with the Ministry of Education, Regional Governments and Municipalities across the country.

Reference is also made to the "Vela Sem Limites" project, an initiative by the Clube Naval de Cascais that allows several dozen people with disabilities to practice sailing on a regular basis.

Within the framework of the BCP Group's Social Impact Policy, Millennium bim, in Mozambique, and Millennium bcp, in Portugal, carried out a joint Corporate Social Responsibility action. With the motto "A book is priceless (in a child's education)", we collect children's and youth books in Portuguese, giving them a "second life" and a new purpose. This solidarity action, which relied on the contribution, commitment and involvement of Employees from both institutions, resulted in a new success and opportunity to create social value, allowing the collection of 2,254 books.

In Mozambique, as part of the celebration of the 27th anniversary of Millennium bim, a cleaning action was carried out as part of the "a clean city for me" project. The main objective of this initiative was to alert Civil Society to the importance and conservation of public spaces and to raise awareness of society for the protection of the environment. The Action had the participation of 230 Employees.

In Poland, the social programs are essentially managed by the Bank Millennium Foundation and focus mainly on financial education, cultural sponsorship, academic support and volunteering. In 2021, the Bank reviewed

and updated its corporate volunteering practices, expanding the #słuchaMYwspeeraMY (#WElistenWEsupport) program in order to increase commitment to local communities.

Even so, in 2022, Bank Millennium provided support to 33 projects.. 147 volunteers, together with his/her families and friends participated in these activities. The solidarity work carried out within the scope of the initiatives proposed, designed and implemented by Bank Millennium Employees, after a careful assessment of the expected social impact and the surrounding circumstances, reached 8,252 beneficiaries - children accompanied by social assistance institutions, people with disabilities, children and young people at all educational levels, including those in special education classes, and senior citizens.

In Poland, the year 2022 was indelibly marked by the outbreak of war in Ukraine, with the Bank responding to the UN Global Compact's appeal to companies to support Ukrainian men and women who were forced to leave the country and found refuge in the country (more than two million Ukrainians sought refuge and safe haven in Poland).

The Bank has allocated a total of PLN 1 million in 2022 to subsidize non-governmental organizations providing support and assistance to refugees from Ukraine. In March, the Bank donated PLN 400 thousand to four organizations supporting and assisting refugees from Ukraine. Polish Red Cross (PCK), Caritas Polska, Polish Humanitarian Action (PAH) and "Ocalenie" Foundation each received PLN 100,000. The decision to donate Bank resources precisely to these entities was made based on proposals made by employees. In September, the Bank transferred an additional PLN 300,000 for long-term assistance to Ukraine, donating these funds to organizations nominated by the municipal offices in Warsaw, Gdańsk and Wrocław (cities where the bank's headquarters are located). The Foundation of Bank Millennium also donated PLN 250,000 to social initiatives developed by Bank employees in support of Ukrainian refugees.

In Mozambique, reference must be made to the Project "Girl Move" – partnership with the association whose objective is to help young Mozambicans to have access to more and better training, in order to break the cycle of poverty and, in this way, build their own future and contribute to a better society. Millennium bim ensured the complete training of 1 GirlMover, 2 Guides and 30 Muarussis (girls from the community).e). It is an advanced leadership and social entrepreneurship program for young university students across the country. Support is provided to these young women at the most diverse levels, namely in the field of education, making them role models for adolescent girls in their community.

When they improve a girl's life through education, health, security and enhance opportunities, these changes have a positive multiplier effect on society. The girl, by becoming a trained mother, an active citizen, a prepared professional, becomes the greatest asset in her community to break the cycle of poverty. The Girl Move project believes that by empowering Mozambican girls and women they can become the country's main development agents.

In 2022, Millennium bcp in Portugal, which is also part of the companies that support the "Girl Move" project from the outset, opened its doors to Maria Lourenço, a young woman who completed an internship at the Bank, in a fully face-to-face format, which took place from September 29th to October 27th and which involved several Departments, the participation of several management boards, a pioneering experience of intercultural connection with the young participants of the inGenious program and a moment with the CEO. In the words of the Girl Mover herself "my deepest Thank you for each and every one of the people who received me".

The Bank has also organized, encouraged and monitored, in what constitutes an important contribution to the materialization of its Social Responsibility policy in Portugal, internal solidarity actions that promote a culture of proximity and add social value. From amongst these initiatives, we must highlight:

• "Millennium Solidário – Christmas 2022": Within the scope of the traditional Christmas solidarity campaign, the Bank and Fundação Millennium bcp teamed up, this time, with three institutions that support people who find themselves in a highly vulnerable situation: the Association of Ukrainians in Portugal, CASA - Centro de Support for the Homeless and BIPP – Inclusion for Disability ("SEMEAR" Project). As part of this campaign, around 4,000 pieces of clothing were collected (Blankets, Duvets, Coats, Polar Sweatshirts, Pants, Gloves, Hats and Scarves), which were delivered to the Association of Ukrainians in Portugal. Additionally, donations of 10,000 Euros were

made by the Foundation to CASA, for the acquisition of equipment for its reception centres, and to SEMEAR, for the repair of equipment destroyed by the heavy weather that occurred at the end of the year. This initiative forms part of the Bank's corporate social responsibility programme, developed in partnership with the Millennium bcp Foundation.

• The Bank publicized and promoted, using its communication channels, various initiatives of the Oeiras Solidária Program (POS), an organization of which it is a member, but also of social sector entities, such as CERCI Oeiras or CERCICA. It was within this context that the Bank once again made its facilities available for the

annual sale of Magic Fireflies, within the framework of the campaign "We are together for whatever comes next", with the main objective of contributing to raising funds in favour of the CERCI's.

Millennium bcp, in Portugal, also carried out a number of supporting actions to institutions and initiatives able of generating social value, of which we highlight:

  • Regular support to institutions through the donation of IT equipment and office furniture that is no longer used, but is in condition to be reused. The Bank donated over 268 items of IT equipment and furniture to 12 institutions during 2022.
  • In Culture, the 14th edition of the Festival ao Largo Millennium bcp, an annual initiative with free access that took place, once again, at Largo do Teatro Nacional S. Carlos, this year without masks and safety conditions. Musical diversity, dances and the presentation of young talents were part of the event. This year, Millennium has also committed to be the main patron of the Programa Território, from Estúdios Victor Córdon, recognising the importance of supporting young talent from a wide range of national dance schools.
  • Millennium bcp participated once again in the campaign "Portugal Chama",a prevention campaign launched by the Portuguese State to avoid forest fires, protecting the people, the forest, rural ecosystem services and minimising the environmental, economic and social impact of fires;

In Mozambique, the Bank's social commitment is embodied in the "More Mozambique for Me" programme, one of the references of the BCP Group under Corporate Social Responsibility aimed at tightening relations with local communities, which, even under a pandemic context, continued to focus on projects in the area of health, education, culture and community development:

  • Millennium bim held the 11th edition of the Banking Olympics project. This project aims to contribute to the education and training of young Mozambicans through the introduction of banking concepts and personal finance management, which promote their financial inclusion in society. This initiative has already impacted the lives of over 4,000 students, 200 teachers in over 100 secondary schools in the city and province of Maputo and Gaza. This edition had, for the first time, the inclusion of topics such as: basic principles on money laundering and conservation of the environment. At the grand final the students presented innovative projects which are easy to be used in their schools or quarters. The big winner was Nelson Mandela Secondary School with the presentation of the "Penso Escola" Project, which aims to empower girls through the distribution of sustainable hygiene products and the dissemination of fact-based information on sexual and reproductive health and rights.
  • In response to the damage caused by the severe weather at the beginning of 2022, which seriously affected the central and northern areas of Mozambique, Millennium bim delivered basic baskets with food and clothing to more than 220 families who were victims of the floods in the province. from Nampula. This initiative was the result of a campaign promoted at national level by the Bank's Employees, to collect basic necessities with the objective of helping the affected communities.
  • As part of itssupport for the Gorongosa National Park, Millennium bim held the 5th edition of the Marathon in the Jungle, an event that included a Health Fair as a way of providing health services, education and basic practices for the benefit of individual health and familiar. The marathon took place on the 13th of August 2022 as a way to add the celebrations of two important days for environmental conservation, the World Lion Day, which is celebrated on the 10th of August and the World Elephant Day, on the 12th. of August. More than 2000 athletes completed the 12 km course on the trail leading to the Park..
  • Integrated care for cancer patients Reinforcement of the institutional capacity of the Maputo Central Hospital.

Running since 2014, this project In effect since 2014, this project contributes to the improvement of integrated care for cancer patients at the Maputo Central Hospital, through improved screening, diagnosis, treatment and registration of cancer diseases. Millennium bim, the Millennium BCP Foundation, the Calouste Gulbenkian Foundation, the Camões Institute-Institute for Cooperation and Language I.P. and the Ministry of Health, are partners in the project "Integrated Care for the Oncological Patient - Reinforcement of the institutional capacity of the Maputo Central Hospital".

Painting the Biodiversity Wall - Millennium bim signed a memorandum of understanding with recycling and Services

within the scope of the "Biodiversity Wall" project. This initiative aims to rehabilitate a degraded area of the airport through the painting of around 40 murals on Mozambican wildlife, marine and flora. The rehabilitated and painted murals will be located at the exit of the International Airport, and aim to transform the area into the first "postcard" of the beautiful city of Maputo and the country, with the main messages to visitors and residents being awareness of the fight against poaching in Mozambique, the promotion of Biodiversity conservation, the protection of marine and forest ecosystems and the environment in general.

  • World Environment Day June 5th is World Environment Day. This date has as its main objective to draw the attention of all spheres of the population to environmental problems and the importance of preserving natural resources. To celebrate this event, Millennium Bim supported an environmental awareness event that took place at the Maputo Zoo. As a way of marking this date, various activities were carried out, such as painting the garden walls, planting trees and reusing materials.
    • Savings Project Complying with the recommendation of Banco de Moçambique on saving habits, Millennium bim through its Social Responsibility program "More Mozambique for Me" developed a set of activities aimed at its Customers, of which the "Savings Project" is example. With the implementation of this project, the Bank sought to raise awareness and instil in young people an awareness of the importance of saving. In accordance with the "new normal" imposed by the pandemic, various activities were carried out on social networks, with emphasis on competitions on the various ways to save.

Xiluva Circuit - In celebration of the 7th of April, Mais Moçambique pra Mim, through its social responsibility program, financed the

Xiluva circuit. It is a four-square Mini basketball tournament, dominated by "O Circuito Xiluva" organized by the Mozambican Minibasketball Committee in partnership with centres and academies in the province and city of Maputo, where 48 children (female) aged between 9 and 11 will participate. of age and teachers preferably from schools or sports centres.

Millennium bim Minibasketball Tournament - The 15th edition of the "Millennium bim Minibasketball Tournament" which involved 9 cities in the country, had the participation of 720 young athletes, boys and girls, aged between 6 and 11 years old, coming from schools, clubs and neighbourhoods.. This event took place in the cities of Maputo, Matola, Beira, Chimoio, Tete, Quelimane, Nampula, Lichinga and Pemba. This year's partners were Seguradora Ímpar, which provided insurance to all athletes involved in the project. Sumol Compal, which offered juices to each participant in the tournament. Colgate Palmolive, which offers each participant a toothbrush and toothpaste; the Ministry of Health, responsible for promoting lectures on Oral Health; the Ministry of the Interior, responsible for lectures on Security, Recycling and services, responsible for lectures on environmental preservation.

Financial Literacy

In all its operations, the BCP Group assumes as one its strategic goal the increase of financial literacy. An example of that commitment are the actions that the Bank has been developing on an ongoing manner to increase the financial knowledge of the individuals, namely young people, always bearing in mind the importance of a generalized adoption of responsible banking behaviours and of a clear, balance and informed decision-making process. Within this context, the Group promoted a diversified group of initiatives throughout 2022, among which we highlight in Portugal:

Within the scope of the "Financial Education" Working Group of the Portuguese Association of Banks (APB), in which Millennium bcp participates, in 2022 the following initiatives stand out:

• The implementation of a Digital Literacy Program – "Everything you need to know about Online Banking" – aimed essentially at the senior population who are not yet familiar with the use of digital banking. The objective of this program, with 12 sessions in a digital format (from September 2021 to July 2022) is to transmit to the target audience a set of basic notions, allowing them to carry out some of the essential day-to-day banking operations, through online channels, such as making transfers, payments, learning to consult the bank account through computer or mobile phone, be alert and know how to protect yourself from possible fraud attempts, among other. The clarification sessions were free and open to the general public, and Fernanda Amorim, Coordinator of the Millennium bcp Digital Payments Team, facilitated one of the sessions - "How to use solutions such as MB WAY AND MB NET?", held on 24 March 2022

APB BERTUCULESA
Tudo o que Como aceder ao meu banco online? 23 secombro
precisa de saber
sobre banca
online
Que operações posso fazer
no meu banco online?
12 outubro
Como consultar a minha conta online? 25 novembro
Como executar uma transferencia online? 14 dezembro
Como fazer pagamentos ao
Estado, de serviços e carregamentos?
20 janeiro
PROGRAMA DE Como fazer pagamentos online
com cartão (Autenticação Forto)?
24 fevereiro
LITERACIA Como usar soluções como
o MB Way ou MB Net?
24 marco
DICTIAL Como constituir poupanças online? 21 abril
2021/22 Como pedir crédito online? 25 maio
Sessões online Como abrir uma conta online? 23 junho
10h - 12h Oue tipos de fraude podem existir
quando uso o meu banco online?
7 jul 10
Incrições abertas:
educacaohoanceira@anh of
Que cuidados e boas práticas
Acres and moder of 7
14 julho
  • Launching of a new website with financial literacy content "Saber de Contas" aimed essentially at three target audiences: young people, bank customers and the senior population. This project enabled the relaunch of the APB's Financial Education Program, which has existed since 2011, with a new name, image and new content – with articles on credit, savings, digital security, means of payment, among others; tips for better managing the family budget or personal finances and several videos in the form of tutorials to help navigate the digital world in a simpler and safer way, on the institutional website of instruments - Savings Centre, Finance Manager and Unforeseen Expenses Kit - which, although distinct and independent, have the common objective of supporting Customers in managing their budget. In the M Vídeos area of the website it is also possible to find tutorials and savings suggestions.
  • The holding of one more edition of the European Money Week, and of the European Money Quiz, which, in Portugal, are promoted by the APB and which took another 2 Portuguese students – this time from the School of Sobral de Monte Agraço, in Lisbon – to the European final, held in Brussels.

✓ The European Money Week, launched by the European Banking Federation (EBF), is an initiative to promote Financial Education that takes place every year, in March, and which has the participation of more than 20 countries at European level. During that week, the banking associations

✓ The European Money Quiz is a European competition, played online, to promote the financial literacy of young people and test their knowledge in matters such as savings, debt, family budget management, digital security, among others. The competition takes place in two stages. First, the national finals to determine the two winners for each country. Then the European final, where finalists from different countries will compete head-to-head in Brussels to try to become European champions of the EMQ.

Also in Portugal, with the aim of continuing to support and expand the dissemination of content on Sustainability topics, in particular on Sustainable Finance, the Bank maintained its support for the ECO Capital Verde project. Among the initiatives carried out and published materials, we highlight the presence in the ECO Sustainability Yearbook; in the Green Economy Forum, as the only Portuguese Bank in the Bloomberg Gender-Equality Index, as well as the dissemination of content on the theme "2021 Environmental Performance". Following this partnership, the Bank's products and services with a sustainable genesis were also promoted, such as, for example, the GO! card. Changer, Changer, a biodegradable debit card.

The Bank also joined, with the same objective, the project of the newspaper

Jornal de Negócios on Sustainability. Of the activity carried out in 2022, we highlight the participation of Millennium bcp in some of the conferences held in the Talks with the CEOs "Miguel Maya - Sustainability transforms the way of doing banking";

Attendance at the 3 Conferences: Environmental (Decarbonization, Circular Economy, Natural Capital Preservation); Social (Equality and Diversity, Wellbeing in Sustainable Cities); Governance (Sustainable Finance, Sustainability Communication and Digital Transformation in sustainability).

In Mozambique, in 2022, the Bank developed the following initiatives:

  • Protocol with ADPP Mozambique Millennium bim signed in Feb. 2022 a protocol with ADPP Mozambique for financial support for training more than 200 primary school teachers at the "Escola de Professores do Futuro" (EPF), in Chimoio, in the province of Manica. This support, which will be given for the next three years, aims to raise the quality of Primary Education in Mozambique, which forms the basis for solid formal education, essential for sustainable and truly inclusive development.
  • Banking Olympics project whose main objective is to train young people in terms of financial knowledge, allowing them to make responsible decisions in the management of their savings. Initiated in 2010, this initiative already impacted the lives of over 4,000 students, 200 teachers in over 100 secondary schools in the city and province of Maputo and Gaza.
  • Savings project In compliance with the decree of the Bank of Mozambique, Millennium bim, through its Social Responsibility program, raises awareness and instils in young people an awareness of the importance of saving. In accordance with the "new normal" imposed by the pandemic, various activities were carried out on our social networks, with emphasis on competitions on the various ways to save. We launched publications and offered various prizes to the winners of the events.
  • Distribution of comic books Within the scope of the actions that the bank develops with regard to financial literacy, 1000 comic books were printed and distributed, in the various Social Responsibility activities. Additionally, the books were disclosed on the institutional website of Millennium bim and on the intranet.

In Poland, in addition to the financial literacy initiatives carried out by the Bank Millennium Foundation, in particular the "Financial ABC" programme, a financial literacy program that aims to introduce basic financial concepts to pre-school children, in 2022 the bank supported its Customers through educational activities:

  • The regular monthly meetings with customers continued, which took the form of webinars.. The audience mainly included customers from the Prestige and Private segments, as well as a select group of customers from the Retail segment.. The themes of the meetings were very diverse, which resulted in a significant increase in the number of participants – the number of people registered for online events tripled compared to 2021. In addition to meetings dedicated to investment topics (market, current affairs, macroeconomic projections), participants had the opportunity to meet several special guests: specialists in real estate, communication, personal growth, and inspiring and internationally recognized entrepreneurs. The high ratings and positive comments from participants confirm the appeal and great value of these meetings for the Bank's clients.
  • For corporate Customers, Bank Millennium organized a series of webinars, alone or in cooperation with specialists and external partners, aimed at financial departments dedicated to:
    • ✓ Prospects for the Polish economy in 2022;
    • ✓ Cybersecurity;
    • ✓ preparing the company to participate in investment financing tenders: available forms of financing and good practices to prepare the company for future tenders, effective preparation of the grant application, correct settlement of investments with community funding;
    • ✓ changes resulting from the new law on real estate developers.
  • We continued to cooperate with the CFO Club of the ICAN Institute.. The CFO Club is a development and networking initiative that brings together CFOs from companies operating in Poland. The CFO Club provides access to current knowledge and serves as a platform for sharing experiences and networking. In 2022, in addition to webinars with experts and professionals from leading companies representing different sectors of the economy, face-to-face meetings were also resumed. The themes addressed at the meetings included the biggest challenges faced lately by CFOs and those responsible for finance in a company: modern methods of financial and team management, data management, changes in the legal environment, automation and digital transformation. The webinars and meetings were highly appreciated..
  • As part of the 5th edition of the Family Business Forum a joint initiative by Forbes Magazine and Bank Millennium a series of 9 meetings were held with businessmen throughout Poland. It is a regular annual event that brings family businesses together. Bank Millennium is the Strategic Partner of the Forbes Family Business Forum since 2018.

Within a context of accelerated transformation of the banking relationship and of the channels that support it, BCP Group also assumed the priority of contributing to the improvement of the financial literacy levels of the communities it serves

Employee Benefits

GRI 401/2

The BCP Group provides a diversified set of social benefits to its Employees that go beyond what is set forth in the legislation applicable in the different countries where it operates.

Health and Safety

GRI 403-3

In Portugal and in Poland, Millennium bcp's employees have medical clinics and a group of full-time doctors, who ensure the provision of curative medicine, occupational medicine and medical assistance. The employees are also provided with a regular and broad medical check-up, largely surpassing what is defined by law for occupational medicine.

In Portugal, to improve health benefits granted to its Employees, the Bank's Internal Medical Services in Taguspark now include experts on Nutrition (543 consultations vs 334 in 2021) - also for -and Clinical Psychology (866 consultations vs 866 in 2020, Experts Employees working in Porto). A service for posture correction is also available at this stage in Taguspark, the purpose of which is to correct anomalies in the spinal column and nervous system, as well as the remaining symptoms thereto related. The Physiotherapy services are also available in Taguspark and in the head office of Club Millennium in Lisbon. In addition, a service for the collection of clinical tests is also available.

The bank employees with Médis Insurance may also use the support phone line made available by Hospital da Luz.

In Mozambique, Millennium bim has in its registered office: i) a medical office, which, in addition to medical appointments, also offers various specialities and basic health care; ii) a HIV office, ensuring prevention and follow-up of this disease; and iii) social support office, offering counselling to Employees with serious social problems that also provides, whenever necessary, legal and psychological support.

HEALTH SERVICES (1)-

2022 2021 2020 VAR.% 22/21
MEDICAL SERVICES
Medical appointments made 25,220 24,472 35,007 3.1%
Check-ups made 10,426 8,344 6,487 25.0%
HEALTH INSURANCES
Individuals involved 44,733 46,862 46,737 -4.5%

(1) Includes active Employees and retired Employees.

The Employees of Group BCP as well as their families also benefit from health insurances, free of charge, or with subsidized conditions which ensure very wide cover plans.

In Portugal, for more complex situations, the employees, whether active or retired, their spouses and children, may also have access to healthcare at Clínica Universidad de Navarra. In 2022, 309 consultations were carried out, which resulted in 53 hospitalizations.

The disclosure, through internal communication corporate platforms, of information on issues related with health and well-being, prevention of illnesses and healthy life habits are a practice transversal to all operations of Group BCP.

In Poland, Bank Millennium decided to reinforce health care packages for employees from 2023 onwards. Medical care will include access to a much larger number of specialist doctors and, additionally, the scope of specialized medical diagnoses will be expanded and the number of laboratory procedures will be considerably greater.

In Poland, the "Millennium Active Zone" continues available, a programme for employees that aims to promote and promote exercise and to disclose concepts, practices and habits for a healthy life.

Within the scope of pandemics or other situations that may severely and broadly impact the health of the Employees, as happened from 2020 to 2022 with the Covid-19 pandemic,Millennium defines and discloses and implements contingency plans together with the Bank's Medical Services and the local health authority. Vaccination campaigns against seasonal flu and/or pneumonia, such as those carried out at national level in Portugal and Poland, are an example of this.

In Poland, the Bank's Board of Directors instituted the Special Support Fund for Employees in the event of corona virus infection. The Fund was active from April 2020 to May 2022. 164 employees and their immediate family members received a total of approximately PLN 200,000 in financial assistance during this period.

The Bank seeks, every year, to improve and complement its social benefits policy for its Employees, always aiming to meet the needs conveyed by the Employees.

Since 2017, at Millennium bcp's premises, Thursdays became Farmers Market Day. The covered patio of the restaurant area at Taguspark now hosts a farmers market every week to sell different food products, from fruit to smoked meats. This initiative, which resulted from an idea presented by Employees, aims to give access to those working at Taguspark to seasonal produce, with a good price/quality relation and without having to leave the bank's premises.

It is also available since the beginning of 2018, an innovative space near the meals area in Taguspark called the Books Bank a library based on a rationale of sharing wherein any employee of the Bank may take a book at his/her choice home, provided that he/she replaces it by another one.. The Books Bank is made by all Employees. Therefore, the more the library is used, the more books it has.

One must also make an additional reference to the internal information flow, which, based on corporate communication platforms, publishes contents regarding business, operational, training and technological issues, but also contents on social responsibility, employee advantages and many other general interest pieces.

In Portugal alone, 5,712 pieces were published on the intranet, 366 of which with videos produced by Millennium TV. From the regular items, a note for content on Sustainability, Financial Literacy and Healthy Living.

It is also published a weekly newsletter, transversal to all countries where Group BCP operates, the "About us", a communication vehicle though which the news and the most relevant events that mark the activities of Millennium in Portugal, Poland and Mozambique are shared. In 2022, 96 editions were carried out (Portuguese and English), with an average circulation of 6,252 units per edition.

Remote work

Millennium bcp, in Portugal, based on the experience of teleworking imposed by the Covid-19 pandemic from 2020 onwards, approved, in 2022, a new "Regulation for the provision of work under a teleworking regime" which provides, for compatible functions (essentially Central Services) and, in addition to what is legally foreseen, the possibility of resorting to a hybrid work regime, with a weekly distribution of 60% at the workplace (3 days) and 40% in remote work (2 days). In 2022, of the employees covered, around 35% benefited from this work regime.

In Poland, the hybrid work modality developed and widely used during the Covid-19 pandemic was consolidated at Bank Millennium. The Bank recommends that Employees work 50% of the time in the office and 50% at a distance.

This hybrid regime, which allows a greater balance between professional and personal/family life, reconciling the interests and priorities of the Bank and its employees, is also a contribution towards reducing home/work travel.

The BCP Group offers a diversified set of social benefits to Employees, which have been reinforced to respond to new challenges and improve the balance between Professional and Personal life

BCP Group provides a workplace that enables its employees to undertake their activities with minimum risk and maximum productivity. So as to guarantee these conditions, the premises are monitored regularly, there are occupational safety and health (HST) visits to the premises, so as to find and correct problems. In 2022, 182 inspections were made in the Group.

Also in this context, and with a view to reinforcing Millennium bcp's commitment to the Health and Safety at Work of its Employees – which constitutes a permanent concern in the management of its daily activity –, in 2022 the specific corporate policy on this matter was revised, incorporating elements that reflect the Bank's reality in Portugal and the applicable legal and regulatory context, as well as good voluntary implementation practices.

The Bank maintained a regular and constant flow of information and training on matters of Health and Safety at Work throughout 2022, of which the following examples in Portugal are: i) "Minuto Seguro", an internal communication item that disseminates video content with information brief on topics ranging from emergency response plans, plants and teams to access to Bank facilities and security systems; ii)

specific training on health, hygiene and safety at work, which covered 5,625 employees (about 90% of the total). 42 Employees received specific training on means of 1st intervention against fires.

Following up the needs resulting from the concentration of employees from central services of Millennium bcp from Lisbon in TagusPark, and without damaging increasing parking space with the creation of a new car park, the focus continues on the daily and free use of buses that ensure transportation to and from Taguspark which, since 2020, are managed based on the existing demand, an improvement that enables optimising the number and frequency of the travels.

Credit

Employees of the BCP Group benefit from mortgage loans, permanently and under special conditions. The credit is granted abiding by the credit risk assessment principles set by the Bank's regulations. The Employees may also benefit from loans for social purposes that, among other, serve to meet credit needs in order to face education or health expenses, repairs made in their own domicile or in a rented one and the acquisition of other goods and services with an exceptional nature.

LOANS TO EMPLOYEES (1)

(Million Euros)
2022 2021 2020
Amount Staff Members Amount Staff Members Amount Staff Members
HOME LOANS
In portfolio 437.3 6.637 574.4 7.395 529.8 7.940
Granted in the year 17.9 148 22.8 158 23.1 217
SOCIAL PURPOSES
In the portfolio 10.2 2.047 9.64 2.210 9.1 2.199
Granted in the year 3.7 848 2.4 876 3.2 265

(1) Includes active Employees and retired Employees.

In Portugal, Employees with term contracts do not have access to the specific conditions of the credit lines for the acquisition of a permanent residence or to loans for social purposes. Part-time employees have access to the benefits common to all, but whenever those benefits are related to the number of years, the value of the benefit is computed based on effective work time.

Parenting

The Bank, aware of the demands that being a parent implies, implemented a Programme for the Protection of Parenting. This Program started in 2015, to create the necessary conditions to enable Employees to better reconcile work and family life.

In this sense, one of the initiatives that we highlight in the Parenting Protection Program is the attribution of a savings voucher, the amount of which was updated in September 2022 to €812.84, and which translates into a contribution by the Bank to the creation of a Savings Account, intended to celebrate the birth or adoption of a child of an Employee. 135 savings accounts were opened, totalling 109,931 thousand Euros.

The Program Guide was also updated with information on teleworking, noting that Millennium bcp, in compatible functions, has processes that ensure compliance with the law, in terms of teleworking for those who have children.

In 2022, we celebrated the birth of 81 babies, with their parents receiving the respective gift kits in their homes. Around 1,549 Employees were able to enjoy their children's birthday afternoon with them.

To support children in entering pre-primary and secondary education, under the Parental Protection Program, parents have half a day off to accompany their children who are going to enter the 1st and 5th grade.

In addition, Millennium bcp also guarantees:

  • The mother and her baby also receive a flower bouquet with a greetings card from the Bank, together with a teddy-bear;
  • Afternoon off work on the birthday of the child of an Employee until the child's 12th birthday (inclusively);
  • Use of an outsourcing company, whenever necessary, to ensure the replacement of the absent Employee (in commercial areas);
  • Adoption of measures to follow-up the moment the parent returns from the parental leave to ensure a good interaction with the team.
  • Carrying out of a follow-up questionnaire made to all Employees that take parental leave so as to identify eventual improvement opportunities.

Satisfaction with this program remains at very high levels. Most of the topics addressed in the satisfaction questionnaire obtain a score equal to or greater than 90 points, and the questions with the best evaluation are those related to the reception of the Millennium Baby Kit in perfect conditions, in the respective residence, the reaction by the Hierarchy to the news regarding maternity/parenthood and the support felt since that moment. The enjoyment of breastfeeding hours shows opportunities for improvement.

It is a program that continues to be highly appreciated by our employees not only because it offers several benefits to the employees, but also because the same enables Millennium bcp to be part of a very significant moment in the life of our Employees and respective family.

In Poland, an operation where 66% of the staff is composed of women, most of them mothers, the new Bank Millennium programme "Yes for Parents" helps them to balance their professional life with their personal and family life.

This initiative, apart from the relevant information (rights, family health, etc.) - available for consultation at a digital platform - and of several social benefits, also enabled the creation of three nurseries at the Bank's central services in Warsaw.

Support to Education

In line with the Sustainable Development Goals (SDGs) of the United Nations.

BCP Group continues to encourage academic qualification, providing financial support, in accordance with the regulations in force, to Employees who, on their own initiative, intend to obtain degrees, postgraduate degrees or executive programs at a level equivalent to a postgraduate and master's degree, relevant to their careers and for the Group.

In Portugal, in terms of education and through monthly subsidies, the Bank also supports: i) Employees who qualify as Student-Employee, granting a total of 6,838 Euros, to 55 Employees; ii) Employees with children of school age, supporting 3.483 Employees, totalling 1,201 thousand Euros; and iii) school-age children of deceased Employees. The bank supported 111 young people with 255,954 Euros.

Inclusion and Diversity Programs

The renewal of this commitment took place at the Inclusive Talks 2022 event – an annual event of the Inclusive Community Forum (ICF), an initiative of Nova School of Business & Economics – NOVA SBE, which took place on the 18th of October. With this renewal, the bank reaffirms its interest in promoting the employability of people with disabilities, recognizing the economic and social value of this reality for Employees and also for the community in general.

Continuing the Journey for Inclusion, in 2022 two more classes of "Formação Vencer no Mundo do Trabalho" were held, with the aim of improving the social skills and employability potential of people with disabilities. The impacted associations were Novo, Somos Somos, Pais em Rede and, for the first time, Casa de São Fran-

cisco de Assis (formerly Casa do Gaiato in Lisbon), with the participation of a total of 29 trainees (18 PCD and 11 Technicians).

In 2022, the Bank also entered into a partnership with APSA – Associação Portuguesa de Syndrome de Asperger, with a view to including its associates in the labor market.

With this partnership, and within the framework of the commitment to law no. 4/2019 that establishes the employment quota system for people with disabilities (with a degree of disability equal to or greater than 60 percent), Millennium bcp intends to help to respond to the challenges that the inclusion of people with disabilities poses for everyone and to benefit from the opportunities it creates, namely by valuing the skills and potential of young people/adults who fit the

profiles sought by the Bank.

Also noteworthy is the partnership established with Valor T, an employability agency created by Santa Casa da Misericórdia de Lisboa, in order to assess opportunities and promote the recruitment of people with special needs. By being more inclusive, Millennium ensures a greater variety of points of view and an organization that is increasingly more diverse and sustainable and increases the number of talented employees.

Culture and Leisure

Activity of Clube Millennium bcp - Initiatives developed in 2022

The Millennium bcp Club is an Association created to take care of the free time of Employees and former Employees of the Banco Comercial Português Group, enabling the practice of activities, hobbies and sports of interest to Members and their respective households, thus contributing to improving your well-being and quality of life, promoting a healthier, richer and more fulfilling life.

To fulfil this purpose, the Club presents a variety of initiatives to occupy free time, whether sporting or cultural, and a range of promotions and discounts on products and services that Members can enjoy, extending its scope to the participation of its Members in civic, humanitarian, environmental and social solidarity causes.

In 2022, the Club resumed its regular activity, normalized as was the pandemic situation of previous years, maintaining an intense sporting and cultural activity, although some effect of the economic crisis has already been felt on Members' adherence to the existing offer at the Club, especially from the last quarter of the year. As in previous years, activities were carried out in a mixed format (when possible): in person and at a distance (online), so with this model, the Club was able to reach outside the usual circuits of Lisbon and Porto, where there are more 74% of its Members.

This diversification of the offer format by the Club was accompanied by new information content in order to maintain a permanent flow of connection with its Members, allowing the provision of information, training and alerts about the activities to be developed in the course of 2022. The activities, initiatives or information disclosed in 2022 reached the number of 370. Its strong membership resulted in 629,000 visits and more than 1.4 million page views (average of 2.3 page views/visit) on the Club's website, as a result of the Members' interest and recognition of the actions carried out.

Recognition was also demonstrated in the results of the survey carried out among the Club's Members at the end of 2021 and whose responses allowed the collection of auxiliary information for management during 2022, and where a high level of satisfaction with the Club's performance was manifested.

The Club's activity in 2022 registered 14,020 registrations in the initiatives disclosed: 5,373 related to the attendance at the Christmas Circus, 4,506 related to sporting activities, 2,591 cultural, 414 leisure, 1,136 related to requests for tickets to the Zoo, Dino Parque, Badoca Parque and Oceanarium.

Christmas was celebrated with the distribution of 1,959 toys for the children of Members up to 12 years of age and with the usual Circus Show in Lisbon, Porto and Funchal during the month of December, the Christmas Audition of the Escola de Música do Clube Millennium bcp on the 11th of December and a Christmas Concert by the Coro do Clube at the Igreja da Ameixoeira also on the 11th of December, bringing together a program that is for all ages and is especially aimed at children, with theatre, magic, and workhops.

The solidarity aspect was also present throughout the year, not only through the donation of 2,750 euros to each of the IPSS, Aldeia Crianças Bicesse and Albergues do Porto and 200 euros to the Cerebral Palsy Association of Madeira, but also with the donation of 50 books "Contos de Natal do Millenito", to the EB1 school in Vouzela.

At the end of 2022, the Club had 34,590 members, of which 10,611 were effective members and 23,979 were family members, with 48% of effective members being active and 52% retired or having terminated by mutual agreement with one of the companies of the Banco Comercial Português Group.

For 2023, the Club itself suffering the consequences of the current financial situation, will try to maintain its levels of demand regarding the quality of products and services, innovation and diversity of initiatives/activities, as well as the conditions of the protocols that it will celebrate, claiming the best discounts and services for its Members and households, the sole focus of the existence of the Millennium bcp Club.

For the new year, the Club's ambition is for all Employees and former Employees of the Banco Comercial Português Group to feel more mobilized and involved, actively contributing to achieving a healthier, richer and more fulfilling life.

MEMBERS OF CLUBE MILLENNIUM BCP

2022 2021 VAR.%
22/21
Active Employees 5,118 5,214 -1.8%
Retired Employees 5,493 5,600 -1.9%
Subtotal 10,611 10,814 -1.9%
Relatives 23,979 24,010 -0.1%
Total 34,590 34,824 0.7%
Total of signing up in events on the website 14,020 9,347 49.9%

Source: Members database and website December 2022

At the end of 2022, the Club had 34,590 members, of which 10,611 were effective members and 23,979 were family members, with 48% of effective members being active and 52% retired or having terminated by mutual agreement with one of the companies of the Banco Comercial Português Group.

For 2023, the Club itself suffering the consequences of the current financial situation, will try to maintain its levels of demand regarding the quality of products and services, innovation and diversity of initiatives/activities, as well as the conditions of the protocols that it will celebrate, claiming the best discounts and services for its Members and households, the sole focus of the existence of the Millennium bcp Club.

For the new year, the Club's ambition is for all Employees and former Employees of the Banco Comercial Português Group to feel more mobilized and involved, actively contributing to achieving a healthier, enricher and more fulfilling life.

Plataforma MyBenefit

In Poland, we have an online shopping platform, where purchases can be made using funds from the Social Fund. On the platform, employees can enjoy more than a thousand different benefits related to tourist, cultural, sports and recreational services. Employees can choose the benefits they are interested in and use them at any time and place. The platform also offers the MultiSport card, which gives employees full access to various sports activities, such as swimming pool, gym, fitness, squash, dance and yoga classes, combat sports and climbing wall. The card gives employees the opportunity to live a healthy and active life. They can also buy a card for their family members at negotiated prices.

Employees associated with MilleKlub, a club of a recreational nature that promotes initiatives outside their professional activity – sports, travel, culture and art – can submit ideas/initiatives in this area and manage them until they come to fruition, being able to benefit from co-financing of up to 50 % of project costs. Additionally, Kids Projects also allows the co-financing of projects that encourage family activities.

In 2022, Bank Millennium was, for the 9th consecutive time, awarded as "Solidny Pracodawca 2022" (Employer of Trust). This award, that distinguishes the best Polish employers, recognises the quality of management of human capital, translated in reliable employment policies, the promotion of training and management of careers, in solutions and benefits addressed to employees and also in the development of social responsibility actions and in the volunteer work opportunities created by the Bank.

Bank Millennium was also distinguished by the magazine Forbes as one of the best employers in Poland.

In Mozambique, the Millennium bim Club continued its activities with the goal of supporting the development of initiatives related to sports, culture and leisure, to promote the Employees' identification, cohesion and involvement with the Bank, while promoting healthy habits, regular exercise and artistic expression.

The Employees of Group BCP also have preferential access to cultural events and spaces sponsored by the Bank in the various Countries where it operates, for example in 2022 the Concerts of Festival ao Largo (Portugal), the film festival Millennium Docs Against Gravity film festival (Poland) and the Art Nucleus Exhibition (Mozambique).

Human Rights

The subject of Human Rights (HR has been gaining relevance in the public sphere, either through regulation, through initiatives such as the Due Diligence Directive Proposal published by the European Commission, or through voluntary, national and international initiatives, examples of which are the UN Global Compact or the UN Guiding Principles Reporting Framework (further details on this framework are presented in the table attached to this report).

The organizations that make up the financial sector play a vital role in the global economy, have a substantial influence on other sectors and are essential, therefore, to guarantee respect for human rights on a global scale, for which reason they become decisive players in the protection of human rights.

At the same time, value chains are becoming more complex, so the approach to the subject of Human Rights goes beyond what is established in legislation and makes companies responsible for their actions throughout the value chain. This is how the reporting of information through standards, guidelines and reference documents that allow and facilitate the approach, management and protection of human rights, not only within the scope of the Bank's activities, but throughout the entire value chain, is nowadays a power/duty whose relevance Group fully assumes.

Within the scope of the bank's approach, we act at several levels:

S t r a t e g y f o r t h e F u t u r e

At the BCP Group, respect for Human Rights is an underlying principle in the way in which the various activities are carried out, transversally to operations and geographies, and is reflected in all its lines of action. In this sense, Human Rights are one of the aspects considered in Millennium bcp's Sustainability Master Plan (SMP) for 2023, similar to what had already happened in previous SMP. In this sense, actions with an impact on human rights were defined, among which the following stand out for their contribution to the organisation:

Axle Action
Social Implement Group-wide human rights management and disclosure
process, including identification of vulnerabilities and improvement
actions

C o r p o r a t e P o l i c i e s a n d P r i n c i p l e s

The commitment of BCP Group in respecting and protecting the fundamental principles of human rights is translated in theHuman Rights Policy, a document that binds all operations included in the consolidation perimeter of the Group to the strict compliance of the legislation applicable in the different countries where it operates, but also to the main references, principles and commitments in terms of Human Rights, namely:

  • United Nations Universal Declaration of Human Rights;;
  • International Labour Organisation (ILO) Conventions on fundamental principles and rights at work;
  • Guidelines of the Organisation for Economic Co-operation and Development (OECD);
  • Principles of the United Nations Global Compact;
  • Declaration of Business Leaders for Global Cooperation of the UN Global Compact;
  • Guide of the CEO on Human Rights of the World Business Council for Sustainable Development (WBCSD);
  • Charter of Principles of the Business Council for Sustainable Development Portugal (BCSD).

In addition to this Policy, there are other Policies with an impact on Human Rights, such as the Social Impact Policy and the Policy for Diversity and Equal Opportunities. Regarding regulatory instruments, we point out also theCode of Conduct, that includes a number of guidelines on issues related with Human Rights and are relevant to ensure that the same are complied with. Moreover, the Bank also has the Code of Good Conduct on Equality, Harassment and Non-Discrimination, that sets forth the approach and regulations on equally relevant themes.

R i s k M a n a g e m e n t

The theme of Human Rights is also included in the risk management process, namely in Operational Risk, in the categories of Employee Relations (R3), Violation of hygiene and safety regulations (R4), Discrimination against employees (R5), Customer relations ( R12), Design of products/services (R13) Regulatory, legal and tax duties (R16) and (R19) Outsourcing. In 2022 as in previous years, the results of the Self-Assessment of Operational Risks show the low level of exposure to those risks (maximum level of 1.48 in a scale from 1 to 5) in the most significant countries where it operates.

W h i s t l e b l o w i n g m e c h a n i s m

The Bank has a mechanism for reporting irregularities (see more information in the Ethics and Professional Conduct chapter) that allows issues related to various topics, namely Human Rights, to be reported In 2022, no situation related to Human Rights was reported.

S e l f-A s s e s s m e n t

In order to identify the main Human Rights issues and risks in BCP Group, a human rights self-assessment was also carried out in 2022 in the different countries where the Group operates: Portugal, Poland and Mozambique. This self-assessment did not identify any risk situations with potential appreciable impact, however, it made it possible to identify, from a risk management and minimization perspective, the areas in which the Bank's action could be intensified. Despite not having identified situations with high risk, the Bank, having completed the self-assessment process, is now defining and implementing plans for improvement in the various geographies.

The self-assessment focused the following themes:

T r a i n i n g

The Bank seeks to communicate and make its Employees aware of the importance of Human Rights and the best practices to be adopted to ensure their respect and promotion. In this context, training on Human Rights themes is provided within the scope of regular training programs aimed at Employees, such as,in Portugal, in 2022, courses on (i) the Code of Conduct, (ii) Sustainability and (iii) Happiness, Emotional Intelligence, Stress Management, Diversity and Inclusion and Emotional Management, already carried out by 3,732, 509 and 2,403 Employees, respectively. These training actions, which covered Human Rights topics, made it possible to record, in Portugal, an overall value of 44,315 hours of training.

S u p p l i e r s

The Value chains tend, as mentioned, to become more and more complex, and therefore, with regard to the Bank's suppliers, there is the intention (and mechanisms) to encourage them to improve and respect the practices for promoting Human Rights, namely through the implementation of the Sustainability Guidelines for Suppliers,developed in accordance with the Universal Declaration of Human Rights and the UN Global Compact Principles. In this document, that applies to all suppliers, there is a specific topic dedicated to the Human Rights theme and the expected conduct of suppliers in this matter, as well as other thereto related themes. In 2022, the Principles were revised, in order to incorporate aspects identified within the scope of the Human Rights self-assessment, carried out in 2021/2022, namely aspects related to Freedom of Association, Migrant Workers and Modern Slavery.

The Human Rights Policy of Group BCP reaffirms the commitment to respect and protect the fundamental principles of human rights in all countries where we operate

Fundação Millennium bcp

Culture, Knowledge, and Solidarity constitute the three focuses of performance of the Millennium bcp Foundation. During the year 2022, the Foundation sought to support projects in these areas in order to contribute for the development of society, in its various aspects, and encourage the activity of supported entities, so that these enrich their potential for innovation and sustainability.

In Culture, it supported projects aimed at valuing national museums, for the recovery of national architectural and artistic heritage and for the dissemination of contemporary art and new artistic talents.

Of note, in this context, is the signing of a protocol with the Fundação Centro Cultural de Belém through which the Foundation assumed the status of patron of Garagem Sul from 2022 to 2024, as well as the support granted for the holding of the Architecture Triennale of Lisbon, with the attribution of the respective prizes and the holding, at the Millennium bcp gallery at the National Museum of Contemporary Art, of the exhibition Multiplicidade.

Equally important has been the dynamization of the renovated space of the Núcleo Arqueológico da Rua dos Correeiros (NARC), providing free guided tours to all who visit this National Monument.

The work carried out at this level was recognized by APOM, which in 2022 distinguished NARC with the prestigious "Visitable Collection" award.

In Science and Knowledge, the Millennium bcp Foundation has been favoring research, training and scientific dissemination projects with a special focus on the health area and post-graduate programs in leading Portuguese universities, which contribute to the internationalization of schools, as well as to the university teaching of excellence in areas related to financial activity and the arts

For the area of Social Solidarity, it sought to include relevant projects within the scope of social innovation and structuring social programs that contribute to local development, namely in helping the most vulnerable sections of the population.

Within the scope of Millennium bcp's Corporate Social Responsibility, the Foundation became part of an internal team jointly with the Human Resources Department and DESC – Corporate Sustainability Area, with a view to boosting, planning and monitoring the actions carried out and was also involved in creating a volunteer program for employees.

In 2022, the Foundation supported a total of 101 projects, of which 61% were in the area of Culture, 12% in Knowledge and 27% within the scope of Social Solidarity

Culture

In Culture, we supported the following initiatives:

Conservation and Disclosure of the Bank's Art Assets

  • National Museum of Contemporary Art:
    • a. Within the scope of the existing protocol, support was given to the holding of the exhibition "The Other Life of Animals", curated by Emília Ferreira and in collaboration with Ana Vasconcelos, Casa das Histórias Paula Rego, the Museum of Natural History and Science and several contemporary artists. This exhibition of real and fantastic animals featured works of drawing, painting, photography, ceramics, sculpture and media art and was designed for a younger audience, but suitable for all ages. It was on display between 05.05 and 28.08.2022.
    • b. Support for the presentation of the exhibition "In the dream of the dreaming man, the dreamer woke up" at the Millennium bcp gallery at MNAC, in partnership with Umbigo LAB and curated by students of the second year of the Master in Curatorial Studies, from Colégio das Artes , from the University of Coimbra. The exhibition was open to the public from 28.01 to 27.03.2022.
    • c. Lisbon Architecture Triennale Support for holding, at the National Museum of Contemporary Art, the exhibition Multiplicidade which was open to the public between October 2, 2022 and January 8, 2023 at the Millennium bcp Gallery. This exhibition, curated by Tau Tavengwa and Vyjayanthi Rao, showcased the work of individual practitioners, architecture studios and organizations from around the world who explore architecture in a multitude of ways contributing to the emergence of a new and agile architecture. This exhibition registered, until December 31, 9,895 visitors.

d. Under the existing protocol, a series of supports were granted that contributed to the museum developing and implementing its programming. The support granted contributed to the realization of a more comprehensive and higher quality exhibition and educational program and to expanding the offer to other areas of culture, with the insertion of an annual musical program and the publication of catalogs and other specialized bilingual editions, but dedicated to the general public. During the year 2022 the museum received around 50,000 visitors and launched 4 bilingual publications.

Within the scope of the MNAC's Educational Service, a program of visits was implemented for schools, families, and visitors of various age groups, covering an annual total of 1908 people, of which 723 related to activities exclusive to the exhibitions of the Millennium bcp Gallery (activities plastic arts, story time, workshops, lectures and other visits with artists).

  • Shared Art Faro Municipal Museum "Itineraries of Painting/Modern Art in the Algarve through the Millennium bcp collection": Contribution to the exhibition "Itineraries of Painting/Modern Art in the Algarve through the Millennium bcp collection", an exhibition that covers a long chronological period, between the beginning of the 20th century and the 1960s, spread over several thematic nuclei, always with the Algarve as a common denominator. The exhibition, which was open between June 25 and October 16, 2022, had 10,289 visitors.
  • Shared Art Loan of works from the BCP collection Painting/Modern Art in the Algarve through the Millennium bcp collection", for which works from the BCP collection were donated, works were also loaned to integrate in initiatives promoted by:
    • a. Museum Gallery of the Cultural Forum of Ermesinde The Christs from José Rodrigues of the Millennium bcp collection;
    • b. Casa de Histórias Paula Rego A set of 6 paintings from Maria Menez;
    • c. Atelier-Museu Júlio Pomar –Oil painting from Júlio Pomar;
    • d. Cordoaria Nacional / ARCO Lisboa Young Art awards from Ana Romãozinho and Francisco Painço Santos;
    • e. Museum and Art Centre of Figueiró dos Vinhos 5 paintings from José Malhoa to be part of the exhibit "A importância do riso: José Malhoa e Rafael Bordalo Pinheiro";
    • f. Casa das Histórias Paula Rego 4 pintings from Paula Rego for the exhibition "Paula Rego: Anos 70";
    • g. Fundação Champalimaud 3 oil paintings by Armanda Passos for the exhibit "Armanda Passos, Pintura a óleo em retrospetiva";
    • h. Atelier-Museu Júlio Pomar: 1 oil painting from Júlio Pomar to be part of the exhibit "Em matéria de matérias primas: Júlio Pomar, André Romão, Jorge Queiroz, Susanne S.D.Themlitz";
    • i. Museum of Contemporary Art of Madeira 1 Tapestry from Lurdes de Castro (Tapestries from Portalegre) to be part of the exhibit "Como uma ilha sobre o mar: Lourdes de Castro";
    • j. Sociedade Nacional Belas Artes loan of 19 works from several authors for the exhibit to celebrate the centenary of the birth of Francisco Pereira Coutinho.

• Núcleo Arqueológico da Rua dos Correeiros (NARC)

The dynamism of this space, classified as a National Monument since 2015, was maintained and which, after a profound renovation with the aim of improving the museum experience of its visitors, reopened at the end of 2021, providing the public with the possibility of coming into contact with remains archaeological sites from the last 25 centuries of Lisbon's history. In 2022, the ZoomGuide platform was installed at NARC, a technology based on artificial intelligence combined with augmented reality, which allows, when necessary, users to enjoy an immersive experience autonomously. Visitors have at their disposal leaflets that summarize the main characteristics of the Nucleus, and a more exhaustive catalog of the history of the site has also been

developed. During 2022, free guided tours were offered to 7,900 visitors

Museum activities

• Fundação Centro Cultural de Belém

A protocol was signed that grants Fundação Millennium bcp the status of "Sponsor of Garagem Sul" from 2022 to 2024. Garagem Sul is a space dedicated to architecture where ideas and practices for transforming the built environment are presented, from temporary exhibitions, conferences, workshops and other public programs. The established partnership aims to support the exhibition project, the restructuring of the Garagem Sul entrance, which now has a new reception and reception space for the public, as well as a new point of sale for the A+A bookstore, designed by the hand of the architect. Ricardo Bak Gordon, as well as the publication of two catalogues. As part of the celebration of 10 years of Garagem Sul and its educational service, between July and December 2022, a series of around 30 events were held. The programming for the first day of the celebrations had around 600 people and the activities carried out by the educational service, between July and December 2022, included the reception of 1,478 participants in guided tours and more than 700 children in workshops. It should also be noted that the exhibition "Sound It. Rádio Antecámara & Os Novos Novos" by Pedro Campos Costa included many online activities with the various associated radio programs, between July and September, registering around 3,355 listeners.

  • National Museum of Ancient Art
    • a. Support for the conservation and restoration of the São Vicente Panels, in accordance with the TRIENNIAL SPONSORSHIP PROTOCOL, to be in force between 2020 and 2022, signed between the Museum, the Group of Friends of the National Museum of Ancient Art, the Directorate-General for Cultural Heritage and the Millennium bcp Foundation, as well as the monumental bas-reliefs in polychrome terracotta.
    • b. Support for the exhibition "The Golden Age of the Portuguese Renaissance" that was on display at the Louvre Museum, between June 10 and October 10, 2022, within the framework of the Season Cross between France and Portugal, an initiative that aimed to deepen the relationship culture between the two countries. Through this exhibition, visitors to the Louvre Museum had the opportunity to discover the painting of artists such as Nuno Gonçalves, Jorge Afonso, Cristóvão de Figueiredo and Gregório Lopes, among others.

During 2022 the Museu Nacional de Arte Antiga received 114.668 visitors.

• Museu Nacional do Azulejo – Suppport to the Sala dos Arcos museography renovation project.

Museu Nacional dos Coches - Support for the conservation and restoration of the Processional Berlinda (inventory number V0063) dating from the 18th century, a horse-drawn vehicle of religious apparatus used to transport the Image of the Virgin in the Procession of Nossa Senhora do Cabo Espichel (cult that dates back to the mid-16th century).

• DGPC - Palácio Nacional da Ajuda - Maintenance of support, within the scope of the existing protocol, for the musealization of the existing collection in spaces adjacent to the "queen's dining room", in the National Palace of Ajuda. This support recognizes the existence of one of the most representative collections of objects linked to the "arts of the table", which includes very diverse items ranging from ceramics to jewelery or textiles.

Recovery of Heritage

Venerável Ordem Terceira de São Francisco - Support for the Conservation and Restoration project of the Main Altar of the Church of the Convent of São Francisco in Porto, classified as a National Monument since 1910 and located in the Historic Center of Porto. The Heritage that is being restored has approximately 400,000 annual visits from all over the world.

Other cultural Initiatives

• Lisbon Archtecture Triennial

"Earth" was the theme of the 2022 Lisbon Architecture Triennale. The program consists of four exhibitions, four books, three awards (Trienal de Lisboa Millennium bcp), three days of conferences (Talk Talk Talk), a set of educational activities and a selection of independent projects. With general curation by Cristina Veríssimo and Diogo Burnay, "Terra" embodies a declaration of intent and a call to action. It proposes the evolution of the current fragmented and linear system model, characterized by the excessive use of resources, to a circular and holistic system model, motivated by a greater and deeper balance between communities, resources and processes. Within the scope of the existing protocol, the Foundation supported the prize component of this 6th edition

  • a. Career Award was attributed to Marina Tabassum, for the positive influence that her projects, combining traditional construction techniques and technological transformations for greater sustainability, have on the current scenario.
  • b. The Début Prize distinguished the atelier vão, for the originality, commitment to the environment and elegance of its work, both for the architectural design and for a deep understanding of the materials. For this award, 95 applications from 38 countries were submitted.
  • c. In 2022, the Universities Award included two categories for the first time, Masters, with 81 applications, and Research, with 30 applications. Due to the high quality and relevance of the proposals, the prize in the Masters category was awarded to four ex-aequo winning proposals
    • ✓ Aquatic Livelihoods Harvard University, Graduate School of Design (GSD), Department of Landscape Architecture;
    • ✓ Coastal Interference Bergen School of Architecture (BAS);
    • ✓ The (in)visible traces of the landscape Paris-Saclay University, École nationale supérieure d'architecture de

Versailles (ENSA-Versailles);

  • ✓ The Theater of the People City College of New York (CUNY), Spitzer School of Architecture.
  • ✓ Na categoria de Investigação, foi distinguida a proposta Biogenic Construction: The Royal Danish Academy, Institute of Architecture and Technology, Center for Industrialised Architecture (CINARK)
  • ARCO Lisboa is one of the most relevant international art fairs that took place between the 19th and 22nd of May 2022 at Cordoaria Nacional. Organized by IFEMA MADRID and the Lisbon City Council, ARCO is a meeting point for collectors, gallerists, artists and professionals from all over the world. The Millennium bcp Foundation sponsored the Millennium Art Talks, which presented current themes related to Art. In 2022, also with the support of the Millennium bcp Foundation, the Exhibition Crack the Egg – Millennium bcp Young Art Award ARCO Lisboa 2022 took place, a new exhibition space, in Torreão Nascente da Cordoaria, entirely dedicated to the works of emerging artists participating in the Millennium bcp Young Art Award, a program that Carpe Diem Arte e Pesquisa has been promoting with the support of the Foundation. The event had around 11,000 visitors and around 70 galleries were present.
  • Carpe Diem Arte e Pesquisa

Support for the Fundação Mbcp 2022 Young Art Award, an initiative aimed at publicizing works by artists who have just entered the world of art, providing a broader view of national artistic production, creating the opportunity for the first presentation exhibition to be held of works, with curatorial accompaniment and catalogue. The selected works were gathered in an exhibition opened on October 1, 2022, in Pavilion 31 of the Centro Hospitalar Psiquiátrico de Lisboa.

The Foundation attributed two awards:

  • ✓ Award "Viagem a Madrid Millennium bcp": which will take plece in 2023 during the art fairs and parallel events in the said city, which was attributed to Catarina Braga, Faculty of Fine Arts of the Universidade do Porto;
  • ✓ Award "Aquisição Fundação Millennium bcp": consists in the acqusition of a work to be part of the of Millennium bcp,and wa attributed to Luís Marques (Universidade do Algarve).

The Jury for this 6th edition of Arte Jovem was made up of the Artistic Duo Daniel Moreira and Rita Castro Neves, the plastic artist Pedro Pires and the Urban Art researcher Ricardo Campos

Exhibit Art Management – Drawing Room - The event took place from October 26 to 30, 2022 at the Sociedade Nacional de Belas Artes and sought, in this 2022 edition, to consolidate its contribution in creating opportunities for the artistic class dedicated to drawing and in affirming the space that drawing can occupy in the contemporary art sector.

This year's edition, which received more than 7,000 visitors, was attended by 23 national and international galleries, representing more than 70 Portuguese and international artists with a program with several parallel activities, including the Millennium Art Talks which, after the period of the pandemic, returned to Drawing Room Lisboa 2022, with programming by Portuguese curator Maria do Mar Fazenda.

Within the scope of this initiative, the following awards were attributed:

  • ✓ Prémio Aquisição Fundação Millennium bcp Emerging Talent, which supports na artist under the age of 35 through the acquisition of a work and its inclusion in the collection Mbcp – Heron P. Nogueira;
  • ✓ Prémio Projeto Artístico Destacado, that distinguishes na artist of the ongoing edition Ana Pérez-Quiroga;
  • ✓ Prémio Projeto Curatorial Galeria, that distinguishes a curatorial proposal from a participating gallery Fonseca Macedo - Arte Contemporânea, gallery based in Ponta Delgada, São Miguel, Azores
  • A.I.C.A Art Critics Association Support for the AICA/MC/Millennium bcp Visual Arts and Architecture Awards, which are awarded annually in Portugal to a visual artist and an architect. They aim to distinguish Portuguese artists and architects who, through their work and personal journey, make an excellent contribution to culture and art. This year, the 2021 prizes were awarded, with Rui Chafes, for the solo exhibition "Nada Existe", and Nuno Brandão Costa, for the work on the Intermodal Terminal of Campanhã, in the categories of visual arts and architecture, respectively.
  • Terceiro Direito Cultural Association Support granted to the organization of the exhibition of finalists of the Post-Graduation in Art Curatorship - NOVA/FCSH – Department of Art History. This exhibition, inaugurated on September 24, 2022 at Galeria Liminare, explored the theme "Horizon" bringing together a group of six young artists.
  • Fundação D. Luís I Support for the exhibition "Paula Rego: Anos 70", inaugurated on November 6, 2022 and which will be open to the public until May 21, 2023
  • Federação de Amigos dos Museus de Portugal Support for awarding the Prof. Reynaldo dos Santos, which is intended to reward the best temporary exhibition presented in Portuguese museums, inaugurated in the year 2021 or 2022.
  • Pergunta Exótica Associação Cultural Support for the exhibition "ALICE", by Jorge Barreto Xavier and Alice Joana Gonçalves,

which constituted a multidisciplinary project of photography, performance, debate/conversation and social networks

  • Ar.Co Support for the publication of the catalog of the exhibition "Ar.Co Bolseiros & Finalistas'20" which had the participation of 22 finalists and/or scholarship students. It is an important document for publicizing Ar.Co's activities and for exhibitors, as it is normally the first institutional publication to include its work.
  • AIR 351 Project aimed at welcoming national and international artists in the field of visual arts to Portugal for artist residencies, creating an environment conducive to professional development and facilitating the interaction of AiR 351 residents with external interlocutors and institutions, nationals and internationals. Since the beginning of its program, AiR 351 has hosted around 50 artists and curators from 25 nationalities (including Portuguese).
  • O Espaço do Tempo A project that supports national and international creators through its artistic residency program (in Montemor-o-Novo) in the areas of theatre, dance, performance, music, visual arts and the arts in general, directed especially for emerging contemporary creation. In 2022, the new XL Box space was inaugurated, an infrastructure, one of the largest in the country, which will be used as a rehearsal room for new shows that will pass through other major national stages. During the year 2022, 99 residences were held in the different structures of Espaço do Tempo, with a total of 686 people. 23 public actions were promoted within the scope of the artistic residencies programme, namely open rehearsals, staged readings and previews, with a total of 887 spectators.
  • UmbigoLAB Support for activities carried out within the scope of UmbigoLAB, a project based on a social network and networking system made up of artists and curators, which aims to create synergies and establish a collaborative wave in the various spectrums of the art system. Taking into account the medium in which it develops – the Internet – UmbigoLAB also intends to promote digital, hybrid and multimedia art, while stimulating thinking about the exhibition of works and contents in these contexts. The platform has 765 users, including 353 artists, 40 curators and 22 consultants.
  • RHI Arte Institute The RHI is an initiative organized by the Arte Institute, with the aim of internationalizing contemporary Portuguese art and culture. Its 4th edition, held on the theme RHI – Think arts, Talk business, Make culture, took place between the 17th and 24th of June in 12 cities – Cascais, Évora, Lisbon, Torres Vedras, Alcobaça, Leiria, Loulé, Faro, Porto, Vidigueira, Braga and Funchal. A total of around 1500 spectators attended the 33 organized and promoted events (lectures, workshops and multidisciplinary events) in person or online. On an environmental level, RHI is proud not to print any program, calling for and publicizing the use of the digital version, in order to avoid waste and waste production. In addition, fulfilling its educational purpose, the RHI promotes artistic creation in schools and families using used materials instead of purchasing new ones.
  • TEATRO MURMURIU GROUP Collaborative and transdisciplinary, Futurama Ecossistema Cultural e Artístico do Baixo Alentejo, produced by Grupo de Teatro Murmuriu, aims to provide the Baixo Alentejo region with a structuring, educational, innovative and continuous cultural program based on transdisciplinarity . Establishes a partnership with 7 municipalities (Beja, Serpa, Mértola, Castro Verde, Vidigueira, Cuba, Alvito) that are part of the Low Density Territories, identified in the National Program for Territorial Cohesion (PNCT) of the Government of Portugal. In 2022, 9,800 people benefited from educational and public actions
  • BOCA Support for carrying out the activity plan which, in 2022, comprised a wide range of initiatives, including Artistic Residencies in various spaces in Lisbon; the Dez Criações Dez Documentários project, with the production of a series of documentaries that show the creations and the artists in their searches and creative processes until the premiere; Defense of Nature, where creation and artistic programming are combined with the creation and programming of natural spaces; Educational and Mediation Program oriented towards an educational investigation that takes the aesthetic experience as a starting point and understands each individual as an agent capable of constructing meanings. In 2022, a year without a Biennial, but with a large circulation of projects, the initiatives developed had 23,500 spectators/visitors.
  • Plutão Camaleão Associação Cultural e Recreativa Support for the 9th Edition of the Tremor Festival, which took place between April 5 and 9, 2022, on the island of São Miguel, in the Azores. In this edition, Tremor returned to its traditional model, occupying various spaces on the island, making them a privileged stage for music with a multidisciplinary program, which included a circuit of concerts, surprise concerts, shows, workshops, conversations, music in the community and artistic residencies. The 9th edition also included the Tremor Todo-o-Terreno initiative, which corresponds to walking and cycling tours accompanied by site-specific sound compositions, in two formats: a song to be heard during the journey and a live presentation to be enjoyed at the end of the journey, of which the Foundation was the sole patron, with the initiative taking on the name Tremor Todo-o-Terreno Fundação Millennium bcp. In the 2022 edition, which was attended by 7,500 participants, 65 events were held by 150 artists from 16 nationalities in 17 spaces in the historic center of Ponta Delgada, Ribeira Grande and on the island of São Miguel. The event was accompanied by 30 journalists, national and foreign, and generated the release of 281 news
  • Pausa Possível Jardins Efémeros - Os Jardins Efémeros (JE) is a multidisciplinary and experimental cultural platform based in Viseu. Its experimental component aims to enhance the relationship between artists, curators, researchers, universities, cultural, social, commercial, tourist associations, companies, museums, schools, the municipality, residents and visitors. The foundation supported the educational service, which constitutes a fundamental pillar of Jardins Efémeros, with the programs Casa de Sonho and Casa da Imaginação. In 2022, within the scope of the Ephemeral Gardens, 249 activities were carried out with 180,877 participants, of which 132 were measurement and training service activities (pedagogical activities) with 2,982 participants.
  • Escolíadas Associação Recreativo-Cultural Support for the Escolíadas Glicínias Plaza project, an initiative aimed at young people residing in the central region of Portugal (districts of Aveiro, Coimbra, Viseu and Guarda), which seeks to provide experiences and opportunities for young people to express themselves through performing arts, promoting access by students and teachers to technical means and concert halls, as well as occupying young people's free time, in order to promote their development and prevent risky behaviour. The 2022/2023 edition had the participation of around 3000 students and teachers from at least 24 schools in the districts of Aveiro, Coimbra, Guarda and Viseu and 14 shows will be presented in 5 rooms.
  • Nascentes Festival Held between June 29th and July 3rd a five-day program of music, workshops and residencies (for all ages) in the middle of the natural landscape of Fontes (Leiria), created from scratch in full collaboration with the community and which had as its starting point the idea that integration and social development have, at their base, a work of meeting people, places and habits. The activities took place throughout the space – gardens, threshing floors, residents' cellars – and aimed to promote mutual help, community spirit and the sustainability of the villages and their natural wealth. Nascentes presented a program of 9 concerts, 4 artistic residencies in the musical field, 1 residency in the field of visual arts, 9 workshops for children and young people, 1 staged walk and 1 community dinner for 230 diners. About 70 artists, creators, trainers were involved in the initiative; an organization, production and technical team of 20 people; around 100 inhabitants of the village of Fontes and around 5,000 people as an audience who enjoyed the 2022 edition.
  • Círculo de Artes Plásticas de Coimbra Support for the 4th edition of the Coimbra Contemporary Art Biennial AnoZero 2021- 2022, entitled Meia-Noite by curators Elfi Turpin and Filipa Oliveira, which was presented as an important moment in the programming of the Temporada Cruzada Portugal- France in Portugal. This edition had the participation of 47 artists from 20 different nationalities, 51% of new works, exhibited in spaces located in different parts of the city. It carried out, among other actions, 30 parallel events (activations), with the participation of 2,036 visitors, and 34 convergent events in partnership with other cultural institutions and associations, which registered 53,369 participants. Within the framework of the Anozero Bienal de Coimbra, various actions were carried out to raise environmental awareness and raise awareness of the ecological footprint through educational actions and works presented. Among them, the visits of the artist Jarbas Lopes to public schools in the city of Coimbra stood out, where he carried out actions aimed at this theme. Globally, the 4th edition of Anozero 21-21 registered 81,630 visits/participations.
  • Municipality of Lisbon / Academy of Cultural Producers nSupport for the 14th Edition of the FestivalADOS Caminhada de Cultura, 2022, an initiative that celebrates Lisbon as an intercultural city through contemporary performing arts. In 2022, the event took place between September 1 and 11, 2022, in the territory of the Parish Council of Santa Clara and was subordinated to the theme "Set the World in Santa Clara". 415 people participated in the organization and realization of the events, of which 189 from the local community and 106 artists. 10,702 spectators attended the live events. Additionally, a series of documentaries, reports and livestreaming events were produced, which registered 9,420 views.
  • DSHC Associação Musical Support for the Festival and Academia Verão Clássico 2022, which took place between the 1st and 13th of August 2022, an initiative with a performative and educational axis that includes concerts and masterclasses with the participation of musicians and teachers from some of the most prestigious international teaching institutions and the best orchestras in the world. This initiative also seeks to promote the training and public presentation of young talent, encouraging and supporting them in building their careers, while encouraging cultural exchange between participants of different nationalities. There were 10 concerts attended by 4,320 spectators. In the Classic Summer Academy Masterclasses component, 572 sessions were held with 254 participants.
  • Memories and Heritage Artes MIMO Festival Support for the holding of the MIMO Festival 2022, which took place between the 23rd and 25th of September 2022, in the city of Porto with free admission. The contribution attributed was destined to the educational service and to the cycle of concerts in the churches, which took place in the churches of Carmo, Carmelitas Descalços, São José das Taipas, Nossa Senhora da Vitória and São Bento da Vitória. During the 3 days of the Festival, 62 activities were carried out, which, among others, included 19 concerts, of which 6 related to the cycle of concerts in churches, 8 educational programs, 15 DJ-VJ Sets, 6 video mapping and video art and 5 lectures. The Festival had an audience of 150,000 people, generated 213 news and motivated 717 publications on social networks.
  • Associação Academia Miamas Marvão International Academy for Music, Arts and Sciences Support granted to support the activities of the academy in 2022.
  • Association of the Cascais and Oeiras Chamber Orchestra Support for the III Entre Quintas 22 festival, an initiative which, during two weekends in July, featured symphonic concerts, recitals and two concerts for the whole family, as well as an exhibition of 5 works by the sculptor Rui Chafes. During the two weekends, 10 concerts were held with an audience of over 2,000 people.
  • Círculo Musical Português Ópera Gala 2022 Support for the Youth Symphony Orchestra's concert, which, traditionally and with great impact, marks the end of the year.
  • CULTURXIS VII Edition of the Coimbra Concert Cycle An initiative aimed at promoting a more diversified cultural offer in the region with a special focus on its tangible and intangible heritage, presenting for this purpose a program of concerts with names of excellence, holding workshops , masterclasses and school activities. The initiative took place between May 5 and 8, 2022 and had around 5,000 participants, with all concerts being sold out.
  • Banda de Alcobaça Support for the 30th edition of Cistermúsica Alcobaça Music Festival, which in 2022 was subordinated to the theme "Amores Proibidos". This initiative promotes concerts by some of the most recognized artists and groups in emblematic places of national architectural heritage. In the 2022 edition, 43 shows were performed, in which 846 performers participated, with 7,662 spectators.
  • LES NOUVEAUX TALENTS -Support for the release of the second volume of the record series "José Vianna Motta | Pianistic poems" by pianist João Costa Ferreira.
  • Sociedade Imparcial January 15, 1898 Support for the 2nd edition of the International Clarinet Festival in Alcochete.
  • Óbidos Criativa Folio 2022 Support for the organization of one of the main reference events in the field of literature in Portugal. With a diversified program spread over eleven days, the festival is divided into several programming lines, including: FOLIO Autores, FOLIO Educa, Folia, FOLIO Ilustra and FOLIO Mais. The event was spread across 24 spaces in the village, with a vast program and with the participation of around 300 authors, two of whom were Nobel Prize winners in Literature, Olga Tokarczuk and Wole Soyinka. The festival was the stage for 16 exhibitions, 36 concerts, 14 author tables, 62 presentations and book launches, 16 workshops, to which, among others, gatherings, workshops, masterclasses and film sessions, in a total of around 200 initiatives. In 2022, FOLIO received around 60,000 visitors.
  • University of the Algarve Support for the edition of the Art History Monographic Prosecutor's Office collection under the title Imaginary algarvian altarpiece.
  • United Artists Support for the publication of new titles in the Livrinhos de Teatro collection, including works by Federico Garcia Lorca, Ricardo Neves-Neves, André Murraças and SillySeason.
  • Associação Trienal de Arquitetura Support for the launch of a tactile children's book aimed at children who are blind or have low vision (6 to 10 years old).
  • Municipality of Faro Support for the 9th edition of the António Ramos Rosa National Poetry Prize, for which poetic works, in the 1st edition, published in 2021 and 2022 may apply. contest over 50 works, both by renowned authors and new poets
  • Eça de Queiroz Foundation Eça de Queiroz Foundation / Millennium bcp Foundation Literary Award This biennial award aims to encourage the production of literary works in Portuguese, as well as honoring Eça de Queiroz, one of the greatest national and international figures in Portuguese literature and culture . The prize, to be awarded in 2023, will distinguish a fictional work (novel or novel) written in Portuguese and published in Portugal in the years 2021 and 2022 by a national author aged no more than 40 years at the date of publication, excluding previous winners.
  • Universidade Nova de Lisboa Support for the 8th European Network for Avant-Garde and Modernism Studies International Conference which, among other topics, reflected on the process of globalization of the avant-garde in arts and literature and on the situation of the avant-garde artistic activities in the context of globalization – technologically, economically and politically.
  • University of Trás-os-Montes and Alto Douro -Support for the seminar "The Ocean and the Climate".
  • ACEGE Christian Association of Entrepreneurs and Managers Support for the activities of the community of Christian business leaders in promoting people's dignity and building good. The programs developed seek to raise awareness and

impact leaders so that they promote new policies in companies that affect organizations and, consequently, society, namely in terms of changing the payment period for suppliers, changing the culture of companies with a view to defining and reconciling of personal and professional life and in reinforcing the importance of values and ethics as criteria for companies' decision-making.

  • Associação Intervenção Democrática Support granted within the framework of the commemorations of the centenary of Seara Nova magazine.
  • Associação Isto não é um Cachimbo Support for the Mapa das Artes 2022 project a contemporary art platform that exposes the various art spaces in Lisbon, such as art galleries, museums and foundations. This map can be consulted through the website online or in paper format.

In 2022, the Foundation supported 101 projects, of which 61% in Culture, 12% in Knowledge and 27% in Social Solidarity

Education and Research

Alignment with United Nations Sustainable Development Goals

Scientific Research Projects

• Rui Osório de Castro Foundation: Protocol established for the period from 2020 to 2022 which aims, through the attribution of a prize, to promote the development of innovative scientific works that deal with the subject of pediatric oncology and that are capable of encouraging and promoting the improvement care provided to children with oncological disease. In the 6th edition, 14 applications were submitted, with the prize being awarded to Jorge Lima, from OPATIMUP and i3S, with the project "3D ex-vivo organoids for precision medicine in pediatric tumors of the central nervous system – Ex-brain". In this edition, the jury also awarded two Honorable Mentions to projects by Bruno Sarmento, from INEB – National Institute of Biomedical Engineering and i3S – Institute for Research and Innovation in Health, University of Porto, "Development of

innovative Nanosystems for the treatment of Pediatric Medulloblastoma Addressed to the Metabolism of the Tumor Microenvironment", and by Adriana Danes, from the Champalimaud Center for the Unknown, "Discovering Brain Plasticity During the Development of Pediatric Cancer (Valance)".

  • Casa da América Latina: Support for a Chair to be awarded to a qualified professional selected by the IHMT/UNL, whose objective is to carry out research projects on malaria, involving teams of researchers from the IHMT and international collaborators, as well as clinical research, together with the institution's research laboratories within the scope of travel assistance activities, namely through training programs in the area of tropical diseases.
  • Centro de Ciências do Mar do Algarve: Support for the II Marine Biogeochemistry course, which took place between May 29 and June 3, 2022. The course brought together a group of 5 world experts in Marine Biogeochemistry and had 36 people attending assiduously, out of a total of 50 subscribers.
  • Faculdade de Letras of the University of Lisbon: Support for the Doctoral Summer School of The Hermes Consortium for Literary and Cultural Studies which, between June 20 and 24, 2022, will be hosted by the Center for Comparative Studies, a member of the consortium, and will have as its theme "Hosts, Hospitals and Hospitalities: Notions, Images and Narratives of Hospitality in Literature, Culture and the Arts".
  • Pedipedia / ASAU: PEDIPEDIA is an online medical-surgical pediatric encyclopedia, free of charge, with two separate entries: one for health professionals, the other for parents and caregivers of children and young people. This publication is complemented by subtitled videos translated into Portuguese Sign Language, which continue to be produced and published. Developed by ASAU (Association for Health Support, Non-Governmental Organization for Development), PEDIPÉDIA has the support of the Institute of Health Sciences of the Catholic University of Portugal and aims to contribute to the improvement of health care provided in Portugal and in the Portuguese-speaking countries to children, young people and adolescents, disseminating scientifically correct, current, clear, credible, succinct and clinical practice-oriented information. It also provides pedagogical content for the teaching of health sciences. PEDIPEDIA was visited in the last 12 months by 580 thousand Internet users from 47 countries.

University Education

  • Camões Instituto da Cooperação e da Língua: In 2022, the Millennium bcp Foundation scholarship program was discontinued, aimed at students from Portuguese-speaking African Countries and Timor (PALOP). Management of the programme, which provided for the annual attribution of up to 7 grants, was assigned to Instituto Camões through a collaboration protocol. Under the terms of the protocol, support is maintained for students who were benefiting from the scholarship until the completion of the course.
  • Catholic University of Portugal: Support for the activities of the Center for European Studies at the Institute of Political Studies of the Catholic University of Portugal.
  • Universidade Católica Portuguesa Faculty of Human Sciences: Scholarships were awarded to two students to participate in the academic program The Lisbon Consortium (Art Scholarships).
  • IPRI Portuguese Institute of International Relations at Universidade Nova de Lisboa: Support for the activities of this Institute dedicated to advanced studies in Political Science and International Relations.
  • Aprender e Empreender Junior Achievement 2022: Initiative aimed at developing entrepreneurship programs for university students through the creation of new mini-companies. In the form of a university competition on entrepreneurship, with the guidance of professors from different universities and higher institutes, students learn how to create and manage a company.
  • This initiative allows students to develop a wide range of personal skills and allows educational institutions to offer their students a more global view of the set of professional opportunities. Additionally, and because it is linked to an international network, participation in this program allows students to broaden their horizons and get to know new realities and generates, for teachers, opportunities to create synergies with other national and international educational institutions. During the 21/22 school year, 9 universities, 725 students and 26 volunteers were involved in this initiative.
  • PAWPET from the University of Minho was the winning team of the XV edition of the National Competition and represented Portugal in the European competition - GEN-E Festival - organized by JA Europe - JA Estonia. In this competition the team won the prize: Public Choice Award powered by Arconic Foundation.
  • Astrophysics Center of the University of Porto: Support for the organization of AstroCamp 2022, an academic program in the area of astronomy and physics, aimed at students in the last 3 years of pre-university education and organized by the Center for Research in Astronomy/Astrophysics of the University do Porto (CAUP). This initiative's main objectives are to provide students with high-quality training, promote scientific knowledge in the field of Astrophysics, stimulate curiosity and critical thinking skills and encourage the creation of personal relationships between young people of the same age. In the 2022 edition, which took place at the Center for Environmental Education and Interpretation of the Protected Landscape of Corno de Bico, from August 7 to 28, 2022, 11 students from 5 countries participated.

Basic Education

• Associação Empresários pela Inclusão Social (EPIS): Support for the promotion of initiatives aimed at creating job opportunities and social reintegration of people, families or groups in situations of exclusion or risk of social exclusion, with special focus on promoting the social inclusion of young people through school success and professional insertion.

Social Action

Alignment with United Nations Sustainable Development Goals

Within the scope of Millennium bcp's Corporate Social Responsibility, the Foundation supported actions by different entities, having covered various sub-areas of intervention, such as childhood/adolescence/seniors, poverty and disability, of which the following stand out:

  • AESE Associação Estudos Superiores de Empresa: Support for the implementation of the GOS Program Management of Social Organizations, which results from a partnership between AESE and ENTREAJUDA and aims at training in management for leaders of entities in the social economy sector, seeking to provide response to the training needs felt in this sector. The 2022 edition had 53 participants, 30 in Lisbon and 23 in Porto.
  • Banco Alimentar Conta a Fome: Support for campaigns to collect food carried out by this institution, which throughout the year sought to provide an adequate response to the impacts of the pandemic, which were still felt among many families. In 2022, Banco Alimentar supported 392,750 people and 2,600 institutions. During the year, 2 food collection campaigns were carried out, one in May and the other in November, which made it possible to collect around 3,790.38 tons of food. Around 38,000 volunteers participated in the November campaign. The foundation's support was channeled to the purchase of paper bags that are used in food collection campaigns (779,238 bags in 2022). The bags are reused in subsequent campaigns or, if damaged or dirty, forwarded to the Paper for Food campaign.
  • Associação dos Ucranianos em Portugal: Support for the "CHRISTMAS OF PEACE HOLIDAY WEEKEND FOR CHILDREN" initiative, which sought to provide around 50 children and young Ukrainian refugees with an important moment of normalcy and socializing that would contribute to their social and psychological empowerment. This initiative forms part of the corporate social responsibility programme, developed in partnership with other areas of Millennium bcp.
  • Associação de Emergência: Association whose main mission is the social integration of the population of slums in Lisbon and which has a temporary reception centre, called "A Pousada", operating in the premises of its headquarters. The support granted was intended to contribute to the work to be carried out, aiming to increase the capacity for temporary accommodation (ideally for a maximum period of 3 months) for 6 people who are in a crisis situation without being able to pay rent for a room or house.
  • 55 MAIS+: Project that aims to activate, value and integrate people aged 55 and over into society to prevent or act against loneliness and reinforce self-esteem and wellbeing. To this end, it has developed a technological and human platform, connecting the needs of citizens and the services provided by people aged 55+ (food, pet-sitting, monitoring of seniors and children, watering plants, …) by a competitive and fair value for all. At the end of 2022, 2,899 specialists aged 55+ were registered, with 9,686 hours of activity having been provided throughout the year in 1,053 services performed

  • Associação Mais Proximidade Melhor Vida: Support for carrying out the 2022 activities of this Association, which seeks to reduce the impact of loneliness and isolation and contribute to improving the quality of life of elderly people. At the end of the 1st half of 2022, this association accompanied 123 beneficiaries with an average age of 85 years.
  • Associação Dignitude: The abem program. Rede Solidária do Medicamento's mission is to allow access to medicines prescribed and reimbursed by the National Health Service to those who do not have the financial capacity to purchase them. The beneficiaries are referred by local entities (Autarchies, Cáritas, IPSS and Misericórdias) so that the support is carried out in close proximity and with humanity. Taking into account the average value of support per beneficiary, the donation granted allowed supporting around 100 beneficiaries for a period of 1 year.
  • Associação Vida Norte: Support granted for the development of the activities of the association whose mission is to support pregnant women and babies in fragile situations, in Porto and Braga, ensuring close monitoring, with a view to empowering the family and building a autonomous, responsible and happy life project. During 2022, the institution received more than 400 requests for support. The Millennium bcp Foundation donation made it possible to support 10 families, during a period of 1 year, in all their needs: close monitoring carried out by the Vida Norte team of psychologists and social workers, access to various training actions in the area of pregnancy, neonatal care, employability and financial literacy and material support (clothing, childcare articles, baby layette, adapted milk, diapers, hygiene products, among others).
  • APSA Associação Portuguesa Síndrome Asperger: Support for the Employability Program whose main objective is to develop the gain of social skills and functional autonomy that allows the integration and inclusion in a professional and social context of young people, over 18 years old, and adults with Asperger's syndrome.
  • FAMSER Place to be: The Association's mission is to promote support for families and individuals who, due to various circumstances and/or social impediments, cannot temporarily ensure the satisfaction of their basic needs and/or daily life. The Foundation made its contribution to carrying out the activities planned for 2022 by the institution within the scope of the GPS project – Gerar, Percorrer e Socializar, developed from a Residential Shelter for young people aged between 12 and 18 years. In 2022, the project directly supported 20 beneficiaries and, indirectly, 40 (parents).
  • Associação Terra dos Sonhos We Guide project: This project's mission is to improve the quality of life of cancer patients, working to improve the overall health outcomes of people diagnosed with cancer. At the same time, some patients (or all when possible) will also benefit from the monitoring of a WeGuide Health Guide, a person who intends to support the patient and their main caregiver, in a bio-psycho-socio-spiritual approach that not only empowers the patient to selfmanage the disease, but also boosts their inner strength and mental health, and that of their caregiver.
  • Associação Terra dos Sonhos transformative dreams project: The main objective of Os Sonhos Transformadores is to provide children and young people with a serious illness, or in a terminal phase, with the realization of their dreams, showing that nothing is impossible. By improving their state of mind, the aim is to increase levels of hope by creating magical moments that reinforce the importance of positive emotions in situations of great vulnerability and, in this way, contribute to the treatment of the disease, the process of recovery or acceptance of the condition.
  • Instituto de Apoio à Criança: Support for the activities of the association that develops projects that promote the Rights of the Child and that contribute to all children having a future with more dignity. According to the latest available data, from 2021, this institute intervened with 32,377 direct beneficiaries (children, young people, families and social workers) at national level.
  • Associação Ajuda ao Récém-Nascido (Banco do Bebê): Support for the "Ser mais familia" project, which includes home

support for newborns with disabilities or at social risk. The objective of the program is to train families in emotional and social skills, ensure care and therapy until parents become autonomous.

  • Ajudaris: Support for the "Stories of Ajudaris" project, which in the 2022 edition worked on the theme "Water".
  • CESAP / Critical Concrete: Offer of a scholarship to two students for the postgraduate program in sustainable architecture. The program focuses on sustainable building development, natural building, urban development, participatory design and social project management. In the renovation of spaces, the use of natural materials such as earth, wood and stone is ensured, and pioneering sustainable technologies are implemented, such as insulation with cork or protection with natural wood. A key part of the mission is to minimize the projects' CO2 emissions by rejecting unnecessary concrete or steel structures. Participants gain hands-on experience with this low-tech, sustainable form of building, which they can then apply to their own projects. This extends to teaching about sustainable infrastructure, food systems, material reuse and deconstruction.
  • Associação Música, Educação e Cultura O Sentido dos Sons: Support for AMEC | Metropolitana by granting 3 scholarships to the Academia Nacional Superior de Orquestra.
  • University of Évora: Contribution to the Social Support Fund for Students at the University of Évora, which aims to support students in a situation of social emergency or with manifest and proven economic difficulties. In the 2021/2022 school year, 163 applications were submitted to the Fund. The Foundation's donation supported 5 students.
  • Portuguese Association of Large Families: Support for the projects "Study of Water, Sanitation and Waste" and "Observatory of Family-Responsible Local Authorities", whose main objectives are to monitor, reward and disseminate the best practices of Portuguese local authorities in terms of family responsibility. In 2022, around 290 municipalities were registered on the Observatory's website, of which 145 completed and finalized the survey, with 95 having been distinguished. The 95 awarded municipalities cover more than 1,500,000 families.
  • Fundação Portuguesa de Cardiologia: Support for the activities carried out by the Foundation in 2022.
  • Lupus Patients Association: Support for the development of the association's activities
  • Again Support Association for Traumatic Brain Injuries and Their Families: Support granted for the development of the association's activity plan.
  • ACAPO Portuguese Association for the Blind and Visually Impaired: Support for the association's activities.
  • Parish Assistance Center of Santa Maria de Belém: Support for the institution's activities in helping young mothers with difficulties.
  • Associação de Estudantes da FEUNL: Support for the Country Mission, a Catholic project by university students whose main objective is to take university students to a Portuguese village for a week and, there, meet the concrete needs of that community, bringing, above all, joy to who is more alone, to the children during school breaks, to the elderly at home, among others.
  • BUS Goods of Social Use: Support for the development of activities in 2022, which consist of collecting and forwarding goods for domestic use to people/families in need.
  • Irmandade da Misericórdia de São Roque: Support for the 2022 Christmas Auto.
  • Hospital Magalhães de Lemos: Support for the realization of an exhibition of works by the artistic nucleus of users of the Psychosocial Rehabilitation service of the Magalhães de Lemos Hospital.

Bank Millennium Foundation

The Bank Millennium Foundation, in Poland, has at the heart of its mission the support of engagement and proximity projects that translate into actions with the potential to create social value and benefit local communities.

The purpose of the Foundation is to support activities that improve the reputation of respect for and trust in Polish financial institutions, as well as to promote social initiatives for the benefit of building a modern civil society, focusing on three priority areas: i) financial education; ii) culture; and iii) promotion of volunteering.

Act without hesitation

As a consequence of the invasion of Ukraine by Russia and the millions of refugees brought by this war in the middle of Europe, the volunteers of Bank Millennium Foundation acted without hesitation in welcoming and protecting the many Ukrainians who arrived in Poland to escape from a reality of violence and deprivation. This spirit of solidarity has led to a doubling of the number of projects and activities proposed and developed by Employees when compared to the previous year, with many of these actions being implemented in the context of the special edition of #WElistenWEsupport (#słuchaMYwspieraMY) aimed at Ukrainian citizens.

The Foundation has also continued its involvement in the "Financial ABC" project. This year, the OECD report on financial literacy in Poland reinforces the importance of implementing this type of programme. These trainings sessions are an effective way to increase knowledge on financial concepts, services and instruments, equipping the addressees to better manage their personal and family budgets, to make informed decisions on saving and investing, but also to avoid unnecessary risks of indebtedness.

Financial Education

Since 2016, Bank Millennium Foundation has had its own financial education programme for pre-school children, called "Financial ABC", whereby it has organised educational workshops in various formats to impart financial knowledge to children, parents and pre-teens. The programme is carried out according to an original concept by professional instructors and Bank Millennium volunteers.

The Foundation has continued the programme in 2022 on a face-to-face basis and has successfully concluded two editions. The "Financial ABC" programmes address current needs and respond to the changing awareness of children and their parents, which is also largely due to the role that the virtual world plays in their lives today. The programme is aimed at pre-school children (4- 6 years old) and is designed to introduce children to the world of finance through games and interesting encounters with many attractions. The trainings are held in cooperation with the Verba Foundation.

In August and September 2022, the Foundation held around 400 sessions in 118 kindergartens across Poland as part of the 8th and 9th editions of the programme, reaching around 10,000 pre-school students. This year's sessions were intended to motivate children to be aware of the use and value of money - the children were able to use coins and notes specially designed for them - and were carried out, as always, with the participation of programme volunteers and the main character and key mascot of the programme - Sebastião.

In 2022, in addition to the pedagogical course already used in previous editions, the Foundation extended the topics covered to other areas of interest. So, in addition to notions about "money", the programme now includes topics such as cybersecurity, BLIK payment methods, internet payments and new technologies. The participants of the "Financial ABC" classes were able to acquire knowledge about finance through conversations, games or by using teaching materials made available by the Foundation. The programme allowed children to learn about the new technological possibilities that are available to them in the adult world, some of which they can explore today. The aim of the "Financial ABC" programme is to teach children and make them actively aware of issues such as finance and security, so that they know from an early age how to navigate efficiently in a fastchanging world.

The use of video content in the programme was extended in 2022. The Foundation recorded a set of short videos with children and experts - Bank Millennium employees. These films, which cover safe financing, saving, the use and knowledge of banking products, were promoted on the Foundation's external media - namely the Foundation's YouTube channel, the Foundation's funpage on Facebook and Bank Millennium's profile on LinkedIn.

All the other teaching materials used by the Foundation, including anonymous stories of Sebastião's adventures and manuals with practical guidelines on how to teach finance to children, are available on the Bank Millennium Foundation's YouTube channel.

"Financial ABC" has the honorary patronage of the Ministry of Finance, which confirms and recognises the merit and ability to create educational value of "Financial ABC" in Polish society.

Handbook for Parents

The expansion of the "Financial ABC" programme proves how financial education is especially relevant in a context of continuous changes in the economic environment of Polish households. Changes in the labour market caused by the pandemic, economic downturn and rising inflation have become frequent topics of conversation among adults. Unsurprisingly, children are also receiving such messages, which can cause some stress regarding their family's financial situation.

It is therefore very important that parents, being the predominant source of world-related information for their children, bring up con-

versations about money and how to manage it. We must not forget that the most efficient way of teaching children is through fun and games and that each child acquires knowledge at his or her own pace.

Educational materials and guides for parents, prepared by the Bank Millennium Foundation, have proved to be an invaluable support.

Online educational materials

Educational materials, available on Bank Millennium's website and social networks, include guides with activities for the younger ones that teach them how to deal effectively with financial education. The articles make suggestions and help increase knowledge related to saving, entrepreneurship, charity, technology and how to run a business.

In addition to these materials, the Foundation also published on its YouTube channel the series of interviews with Małgorzata Chojak - PhD, neuro-pedagogist, author of the guides available online. In a conversation with Paulina Wołosz-Sitarek, member of the board of the Bank Millennium Foundation, the expert explains how to introduce the world of finance to children.

Participation in the Congress on Financial and Business Education

Bank Millennium Foundation was one of the partners of the 6th Congress on Financial and Business Education, which took place in March. It is the most important Polish discussion forum and a platform for exchange on the development of financial education.

During the Congress the results of the survey, promoted by the Foundation, on the attitude of Poles to financial education issues were presented. It was evident that obtaining knowledge and adopting strict habits of money management and use are of great importance for both adults and young people.

Parents asked to list three key characteristics to develop in pre-school children, and most often mentioned were: selfconfidence, creativity and the ability to operate as a member of the group. These elements, together with the ability to resist and manage stress, planning and resourcefulness are natural aspects of the educational process. In addition to financial literacy, the Bank Millennium Foundation is concerned with the development of a wider range of skills that support and prepare participants in programmes such as "Financial ABC" for adult life.

Volunteering makes a difference

Bank Millennium Foundation was at the forefront of emergency support for the millions of people fleeing the war caused by Russia's invasion of Ukraine who are seeking refuge and protection in Poland by launching a special edition, on 1 March of the #WElisten-WEsupport (#słuchaMYwspieraMY) volunteer programme targeting Ukrainian citizens.

During the project, which had a more intense phase between the beginning of March and the end of May, reception centres were made available where volunteers helped to prepare and deliver meals, as well as products and basic necessities (hygiene products, food, clothing). The Foundation also supported the accommodation of refugees and the reception of Ukrainian children, either through hosting pakages and providing adapted and furnished facilities, or by collaborating in the organisation of workplaces and carrying out translations and preparing workshops.

On 24 August, on the 31st anniversary of Ukraine's independence, we published a film

on "#WElistenWEsupport, for Ukrainian citizens", recapping the main support activities developed under this solidarity project and which is available on the YT channel and on the Foundation's social media accounts.

Social Responsibility and Social Solidarity Initiatives in Portugal, Poland and Mozambique

Millennium bcp volunteers in action at the Food Bank (Portugal)

Millennium bim volunteers in action for the programme "A Clean City for Me" (Mozambique)

Jungle Marathon, celebrates World Lion and Elephant Days (Mozambique)

José Maria Brandão de Brito, participates in a panel at the "UN Day Celebration Conference" (Portugal)

15th edition of the Millennium bim Minibasket Tournament (Mozambique)

Social Responsibility and Social Solidarity Initiatives in Portugal, Poland and Mozambique

"Brigada do Mar" (Sea Brigade) clean the beach of the Portuguese coast (Portugal)

11th edition of the Banking Olympics promotes financial literacy (Mozambique)

Bank Millennium is "European Diversity Leader 2023" for the Financial Times (Poland)

The Customer is central to Bank Millennium's values (Poland)

Paulo Neves shares the Bank's experience in the course "Sustainability: A Corporate Journey", from ISEG. (Portugal)

Bank Millennium Volunteers in another action of the #słuchaMYwspieraMY programme (Poland)

Environmental Responsibility

Environmental Responsibility

The Bank recognises its responsibility in the management of the environmental impacts for the promotion of the sustainable development. For that purpose, it promotes several initiatives to reduce the negative impacts associated with its operations and with its portfolio, through the provision of solutions and financial products that translate its concern in combating climate change and improving the quality of life.

For the definition of an effective strategy and plan of action that result in the effective minimization of negative impacts on the environment and greater eco-efficiency in the manage-

ment of operations, the Bank assumes its commitment to international frameworks, tools and indices.

Main highlights 2022

Caption: 2022, % evolution versus 2021

Bank's Journey to improve environmental performance

The path of efficiency of Millennium bcp in Portugal

Electricity
Target 2022: - 3%
Performance +12%
Target 2023: +6%
Energy
✓ Target2022: 3%
Performance: -11%
Target 2023: -11%
Direct Energy
✓ Target2022: - 3%
Performance: -44%
Target 20231
: -60%
Indirect energy
Target 2022: - 10%
Performance: +12%
Target 2023: +6%
Water
Target 2022: - 2%
Performance: +5%
Target 20232
: +2%
Waste
✓ Target2022: - 2%
Performance: -16%
Target 2023: 0%
Materials:
✓ Target2022: -2%
Performance: -8%
Target 2023: -5%
Emissions of CO2
✓ Target2022: - 7%
Performance: -33%
Target 20233
: -15%
Direct Emissions
scope1
✓ Target2022: - 7%
Performance: -39%
Target 2023: -15%
Indirect Emissions
scope 2 and 3
Target 2022: 0%
Performance4
: +288%
Target 2023: 0%

1 The defined target implies an increase in consumption since Taguspark buildings 1 to 8 are being supplied with electricity instead of gas, which will determine a decrease in gas consumption and, consequently, an increase in electricity consumption.

2 The defined target implies an increase in water consumption, since consumption in the first two months of 2022 was still reduced, as we are still in a pandemic period. The target was calculated based on pre-pandemic figures, thus assuming a reduction versus those figures.

3 The target was calculated based on the following assumptions: 1) continued acquisition of green energy; 2) considering a 5% reduction in consumption in the car fleet, and continuity of air and train travel (in-service mobility).

4 The significant increase recorded in 2022 results from the lifting of restrictions on movement with regard to mobility on duty, with a more relevant impact resulting from plane travels.

ELECTRICITY CONSUMED

MWh PER EMPLOYEE

ENERGY PRODUCED IN THE PHOTOVOLTAIC PANELS (MWh)

Toneladas de CO2 evitados

116% increase in energy produced by photovoltaic panels since 2020

Reduction of 38% in the consumption of electricity per employee since 2012

Sustainable Development Objectives

ODS Our goals Our contribution in 2022
Contribute to limit global warm
ing to 2ºC.
Promotion of decarbonisation in Group BCP
Initiatives:

In Poland and in Portugal, the cars of the fleet are being gradually replaced by hybrid
models. Millennium Bank estimates that, until 2030, all the cars have ben replaced by
hybrid models.

Installation of the second photovoltaic solar plant in Portugal.
Results:

In Portugal, 5,5% of the fleet is composed by electric or hybrid vehicles. An increase
that contributes to reach the commitment of increasing the % of energy-efficient ve
hicles for the Bank's vehicle fleet in Portugal of 80% by 2030.

Group BCP reduced in 67% the total of CO2 emissions of its operations versus 2021, a
reduction that depends in part on the transition to 100% power supply in Poland. We
must underline that, in 2022, it was possible to include within the reporting scope the
operations in Mozambique, maintaining the same reduction trajectory.
Increase the percentage of re
newable energy in total con
sumption of fuel.
Consumption of renewable energies
Results:

In Portugal, all electricity consumed was 100% green, in a mix of energy produced by
the TagusPark photovoltaic plant and energy purchased with a certificate of renewa
ble origin, thus fulfilling the commitment to use 100% renewable electricity in all the
Bank's facilities in Portugal.

In Poland, from 2022 onwards, purchased electricity became 100% certified from re
newable sources.
Mobilise and increase the finan
cial means for the conservation
and respect for biodiversity and
for eco-systems and for the
promotion of a sustainable
management of forests, includ
ing maintenance and re-foresta
tion.
Financing of projects that contribute directly or indirectly to the conservation of biodiversity
and ecosystems and to the sustainable management of forests
Initiatives:

The BCP finances several projects in the areas of energy, forest and agriculture
through Guarantee Lines with the European Investment Fund (EIF) and the European
Investment Bank (EIB), under the Community Program EGF – European Guarantee
Fund; Linha Capitalizar Mais - SI Inovação; Linhas de Crédito apoio Setor Agrícola e
Florestal - IFAP Curto Prazo, Apoio às Pescas, Flores 2020, Intempéries 2020; Leasing e
ALD Verde; Programa de Garantia Biznesmax; Polish Green Economy Financing Facil
ity, Leasing Eko Linha de crédito KFW; Credit Line FECOP Calamidades, among other.
Ensure the universal access to
modern energy services and to
accessible prices.
Financing of renewable energy infrastructure and equipment projects and others that contrib
ute to/enhance the consumption of renewable energy
Initiatives:

Renewable Energy Personal Credit - credit intended to finance the acquisition of
equipment for the production of renewable energy.

Millennium TFI Funds - funds in line with article 8 of the SFDR.

Participation in the Mój Elektryk Priority Program - guaranteeing co-payments from
the National Fund for Environmental Protection and Water Management for the
rental of electric vehicles.

Strategic Plan - Superação 24

The Millennium Strategic Plan for the 2021-2024 cycle consolidates the progress achieved in the 2018-21 period and adds new elements consistent with the new framework. Within the scope of the strategic priorities, the Bank presents in its Plan the commitment with sustainability so as to translate the adjustment to the trends in the financial sector. Within the scope of those commitments, the following objectives have been established:

  • Innovate in own products with green and social classification aimed at Individuals and Companies, risk appetite and funding structure influenced by the adoption of a green business model;
  • Explore partnerships to increase the offer of ESG products, providing consultancy and advisory services to companies to support them in their transition process.
  • Increase the origination of bonds linked to sustainability criteria and the issuance of ESG bonds;

• Establish a strong communication with internal and external Stakeholders, training all Employees and linking incentives with behaviours and results aligned with ESG criteria.

> 50%
Reducing the level of ex
posure to coal and petro
leum products in Euro
pean operations
> 50%
Green project finance
#1
Origination of green
bonds in Portugal
----------------------------------------------------------------------------------------------------------- -------------------------------- -------------------------------------------------

2022 Sustainability Master Plan - Envoronmental Action Plan

The Bank published its 2022 Sustainability Master Plan, which includes several lines of action that contribute to reducing the Bank's negative environmental impacts and to boosting the positive impacts. Below please find the main action lines related with environmental aspects and focused on the approach to risk management, the portfolio and operations.

Size Action Line
Policies and regulations on - Follow up the development of the Action Plan for sustainable finance of the European Commission.
sustainable financing - Follow-up a business strategy in line with climate and environmental risks.
Risk management - Ensure skills to manage ESG risks
- Ensure the integration of environmental and social risks in the risk assessment process.
Climate changes, energy ef
ficiency and alternative en - Contribute to limit global warming in line with the Paris Agreement.
ergy sources
Environmental performance - Minimize the environmental impact of the operations.

Sustainable Operations

Various environmental performance indicators are monitored in order to monitor the eco-efficiency of the Bank's operations and, based on the observed performance, develop actions to improve it. 2022 marked the return of employees to the office, as well as the return of some travels and associated trips, which naturally had an impact on the Bank's performance. Notwithstanding this evolution, the figures recorded by the several indicators in 2022 continue to be more positive than in years prior to the pandemic, revealing the effectiveness of the approach that has been implemented at the Bank.

The Bank seeks to rationalize consumption, namely energy, water and materials, mainly based on a logic of dematerializing processes and preserving natural resources, in line with the provisions of its Environmental Policy, updated in 2021 and adopted by all BCP Group's geographies and operations.

Environmental performance of Group BCP

2022 2021 2020 Variation % 2022
Unit: Var. %
22/21
Values Var. %
21/20
Values Var. %
20/19
Values versus 2017 (5
years)
ELECTRICITY MWh + 1% 46,464 -23% 45.884 -10% 59.214 - 37%
ENERGY TJ - 13% 313 -13% 359 -6.9% 412 - 41%
Direct TJ - 35% 69 + 12% 107 -26% 96 - 63%
Indirect TJ - 3% 243 -21% 251 -1% 316 - 27%
WATER m3 + 8% 176,288 -22% 163.747 -24% 208.817 - 52%
WASTE * t - 5% 1,216 + 55% 1.285 - 830 -
MATERIALS t - 3% 1,532 - 9% 1577 -18% 1.732 - 36%
Cardboard/paper t - 3% 1,491 - 9% 1531 -17% 1.692 - 35%
Plastic t - 11% 41 + 13% 46 -33% 41 - 51%
EMISSIONS OF CO2 (tCO2e) -67% 12,800 -22% 38.611 -3% 49.307 - 77%
Direct Emissions (tCO2e) -34% 4,619 +9% 6.988 -23% 6.421 - 64%
Indirect Emissions (tCO2e) - 74% 8,182 -26% 31.623 -4% 42.886 - 81%

* Updated information in accordance with the new methodology for calculating the total waste generated

Main communication initiatives and awareness of sustainability
Portugal In order to make its employees aware of the relevance of environmental issues, the Bank frequently disseminates content on
the internal Portal, with good practices and general information. An example of these initiatives was the information sent
regarding greenwashing, where the concept was outlined and the mechanisms implemented to avoid it were explained,
namely with regard to the performance of Compliance.
In 2022, the total number of headcount Employees involved in the MiFID II Certification and Annual Renewal processes was
3,695, corresponding to 90,915 hours of training.
Bank Millennium was recognised as a" Climate-Conscious Company 2022" Climate-Conscious Company 2022"as part of the
Climate Awareness Assessment of Companies, carried out based on the content of 2021 Reports. The Bank received 8,17
points, standing in the 7th place among 152 companies listed in the Warsaw Stock Exchange.
Poland In order to find out how Polish regions are involved in the green transition, Bank Millennium has developed an eco-innovation
index. The report "Millennium Eco-index – the potential of eco-innovation of regions"Millennium Eco-index – the potential of
eco-innovation of regions" was developed with the cooperation of partners: the Patent Office of the Republic of Poland, the
AGH University of Science and Technology in Krakow and the Higher School of Economics in Warsaw. This Report helped to
create a platform to discuss the importance and development of green innovation in Poland and also aimed to encourage
cooperation, since, as the study shows, cooperation is conducive to eco-innovation. The study also showed that environmen
tal regulation can stimulate innovation and that the implementation of environmental solutions, especially innovative ones, is
an investment that pays off in the long run.
Mozambique Millennium bim signed a memorandum of understanding with the company Reciclagem & Serviços (R&S – Recycling and Ser
vices)) thus joining the cause of raising awareness of the fight against poaching and of conservation of Biodiversity. The pur
pose of this initiative is to promote the painting of around 40 murals on Mozambican wildlife, marine and flora, marking yet
another commitment by the Bank to support initiatives to protect Biodiversity and conserve the environment.

Group BCP carries out its initiatives so as to be able to comply with the goal of reaching carbon neutrality from the Bank's activity

De-carbonisation

The BCP Group promotes its activities in order to comply with the objective of achieving carbon neutrality resulting from the Bank's activity (direct emissions) by 2030. The effort to mitigate the carbon footprint has been intensified, namely through the reduction of emissions resulting from its activity.

Reduction of 90% in the total emissions of CO2 in the last 5 years.

Classification of B in CDP Climate Change

4,619 tCO2e - 34% of than in 2021 Fuels

Scope 1 - Direct emissions

7,769 tCO2e - 75% of than in 2021 Electricity/Heat

Scope 2 - Indirect emissions (market-based)

412 tCO2e + 126% than in 2021 In-service mobility

Scope 3 - Other indirect emissions

In 2022, the trend of reducing GHG emissions (Greenhouse Gases) associated with the activity of the BCP Group was maintained, with a reduction of 67% having been recorded compared to the total values of emissions for 2021, largely justified by the transition to 100% renewable electricity in operations in Poland.

Regarding the BCP Group's scope 1 emissions, there was a reduction of 34% compared to the previous year's results. Regarding scope 2 emissions - which consider the acquisition of electricity and thermal energy in Poland - calculated on a marketbased basis, there was a reduction of 74% compared to 2021, driven by the transition in Poland to electricity consumption from renewable sources. In 2022, the Bank updated its calculation methodology, in line with the GHG Protocol, to include the reporting of scope 2 emissions calculated on the basis of location (location-based), having recorded a total of 25,606 tCO2e in 2022. It should be noted that the location-based method reports the average intensity of GHG emissions of the networks where energy consumption occurs, using mainly data from the average emission factor of the network (at national level), while the market-based method reflects the emissions derived from electricity consumption based on information from energy suppliers.

With regard to scope 3 emissions, associated with mobility in service, there was a 162% increase following the end of the institutional ban on travel, implemented within the scope of the pandemic period.

As for the emission reduction targets established for Portugal (reduction of 7% in total emissions and in direct and indirect emissions), the Bank complied with what was defined in the case of global emissions and direct emissions, with a reduction of 33% and 38% respectively.

419 tCO2 avoided through the energy produced through photovoltaic panels

In Poland, there was a 71% reduction in total emissions, as a result of switching to electricity from 100% renewable sources. Likewise, there was a reduction, albeit less expressive, in scope 1 emissions (28% less compared to 2021). With regard to scope 3 emissions, similar to the Portuguese reality, there was an increase of 37% due to the lifting of restrictions on circulation. In its most recent business strategy, the Bank committed to reducing greenhouse gas emissions in Scopes 1 and 2 by 50% in 2022 compared to 2020 (market-based) – an objective that was achieved.

With regard to the overall performance of the BCP Group, there was also an 67% reduction in the value of tCO2 per employee (considering only scope 1, 2 and scope 3 emissions associated with the Bank's activity as an organization and not as a financier, that is, only emissions from mobility in service), changing from 2,9 to 0.97.

Main De-carbonisation Initiatives

In 2022. The second photovoltaic solar power plant was installed at the TagusPark facilities, with 1,834 photovoltaic modules. This new plant avoids the release of 275 tCO2 into the atmosphere annually, equivalent to the capture of CO2 by 12,491 trees.

Portugal

This project, completed in December 2022 and started in November 2017, with the installation of the first power plant, is now operational and certified by the General Directorate of Energy and Geology (DGEG).

With the aim of reducing emissions associated with mobility in service, the Bank encourages its employees to hold face-to-face meetings, a habit that was facilitated by the Pandemic period - with regard to the use of collaboration and productivity tools MS Teams and Skype recorded 365,823 meeting sessions, 11,795,667 instant messaging sessions, 1,515,992 audio sessions and 15,355 video sessions. With the same purpose, the Bank also promotes, the bus transport offer between Tagus and Lisbon, constantly adapted to

demand.

Main De-carbonisation Initiatives
With the aim of transitioning to more sustainable mobility, the Bank replaced all gasoline cars in its fleet
with hybrid models running on gasoline, while rented cars with diesel engines are replaced by gasoline hy
brids. For business trips, low-emission means of rail transport are privileged and limits associated with the
use of air transport are implemented.
Poland With the same purpose, the Bank encourages employees to use their bicycles as an alternative to public
transport and cars, boosting the transition to more sustainable mobility. At each location at the Headquar
ters, the Bank also built parking spaces for cyclists and sanitary facilities.
By installing an ordering machine at its headquarters in Warsaw, the Bank promotes the reduction of CO2
emissions, as its employees do not have to travel to obtain orders. It is estimated that a single ordering ma
chine will be able to reduce the CO2 emissions in almost 14.000 kg.
Mozambique Installation of solar panels at the Matola branch opened in 2022 (the first in Mozambique).

Energy efficiency

In order to reduce energy consumption and its consequent impacts, the Bank has been investing in renewable energies, with its operations in Portugal and Poland operating with 100% of electricity coming from renewable sources.

Reduction of 37% in the total consumption of energy in the last 5 years

Since 2021, Millennium bcp, in its operations in Portugal, has ensured that 100% of the energy consumed is renewable, through the acquisition of energy with a certificate of renewable origin and the consumption of energy produced by the Bank's photovoltaic plant. In 2022, Poland adopted the same strategy, contributing to the significant reduction of impacts associated with energy consumption.

Consumption of electricity 2022
Domestic: Portugal
Electricity originated in renewable sources 26,374 MWh (6%) 100%
Electricity originated in non-renewable sources
0 MWh (6%)
0%
International Poland & Mozambique
Electricity originated in renewable sources 20,090 MWh (6%) 100%
Electricity originated in non-renewable sources 0 MWh (6%) 0%

In 2022 there was a reduction of around 13% in energy consumption, with Poland recording a 6% reduction and in Portugal an 8% increase. The increase that occurred in Portugal is justified by the return of employees to the office.

Within the scope of the goals established by Portugal regarding energy, the goals related to total energy consumption and reduction of direct energy consumption were exceeded, with reductions of 14% in total energy consumption and 44% in direct energy consumption. Only in the case of indirect energy consumption was the target not met, with an increase of 8% observed, partly justified by the return of employees to the offices.

(*) Includes consumption from the cogeneration plant, excludes facilities with data centers in Portugal and excludes data from Mozambique.

-10.0 -5.0 0.0 5.0 10.0 15.0

Main energy efficiency initiatives

Portugal With regard to measures promoted to improve energy performance, emphasis should be placed on the in
stallation of a new photovoltaic plant with a capacity of 1 MW in Taguspark, inaugurated in December
2022.
The installation of solar panels in nine branches of the Bank is also in the market consultation phase.
Poland In 2022, several initiatives were promoted for greater energy efficiency, namely, the use of energy-efficient
lighting at the head office and branches – almost 14,000 light fixtures were replaced - and automatic sys
tems to reduce energy and water consumption in the head office building in Warsaw, by which was
awarded the BREEAM certificate (very good level), and LEED Gold in Wrocław. In addition,daylight supply
sensors and occupancy sensors are used throughout the space, through the DALI system, which significantly
contributes to energy efficiency and also has an impact on the health, well-being and productivity of em
ployees.
Given the difficulties in the energy market, Bank Millennium is introducing additional measures to reduce
electricity consumption. It decided to turn off light signs and advertising screens at its headquarters and
branches across the country after office hours. This campaign was widely promoted by the media.
In 2022, the first 25.3 kwp photovoltaic system consisting of 69 modules was also installed.

1. Management of resources - Water, Materials and Waste

WATER

Total water withdrawal/consumption at the BCP Group has registered a downward trend, with an increase in 2022 justified by the return of employees to the office. Despite this increase, both in Portugal and in Poland, the values recorded in 2022 are significantly lower than in 2019 (pre-pandemic period).

Reduction of 52% in the total consumption of water in the last 5 years

With regard to the target set for Portugal regarding water collection (2% reduction), this was not achieved, with a 5% increase having been registered due to the return of employees to the office.

Water withdrawal (4)

MATERIALS

Regarding the consumption of materials, BCP Group (includes Portugal, Poland and Mozambique) registered a 3% reduction in the consumption of the main materials: paper and cardboard, plastic and ink cartridges/tonners. The most consumed materials, in terms of total weight of materials, continued to be paper and cardboard, which represent 97% of the materials consumed.

34% reduction of the total consumption of materials in the last 5 years

In Portugal, there has been a trend towards a reduction in the number of prints and copies and, consequently, in paper consumption, through the continuous digitalisation of some business processes (currently over 40) and the half-yearly communication of consumption to all Divisions. This is due, for example, to the reduction of local printing and the digitalisation of incoming processes, with operations being opened directly in the systems and applications, avoiding the physical circulation of documents. These practices have also been implemented in Polish operations, contributing to the reduction of the total consumption of materials in BCP Group.

Prints and copies (Portugal) 2020 2021 2022 Variation
22/21
Prints/Coloured copies 73,6 M 65,4 M 52,7 M -19%
Prints/Black and white copies 4,6 M 3,9 M 3,2 M -18%

Main initiatives for reduction/ promote culture efficiency in materials consumption

Currently implemented in the Millennium bcp Operations Division, the Kaizen Programme is applied by 310 employees, distributed among 39 teams and 8 divisions. Its objective is to support the teams in the analysis and development of initiatives that promote the improvement of their processes, always based on a Lean methodology.

In 2022, 240 improvement initiatives were implemented, 5% of which led to savings of around 106,382.88€ in consumables (e.g.: paper, printing, internal mail stamps, internal and external envelopes, among others).

Portugal

Continuity of the "GO Paperless" project, a transformation that focuses on dematerialising operations as a way of innovating and optimising processes, using solutions for the electronic production and signing of documents, and which in 2022 saved 1,451,251 cash transaction printouts, corresponding to a reduction of 9% in the printing done on branch equipment when compared with the same period in 2021, and which translates into a monthly average saving of 120,938 printouts.

Implementation of pending operations that are transactions prepared by the Branches and that the Customer can later accept to join through the Millennium website or App. Concluding operations in this way makes it possible to replace the signing of paper documents, thereby contributing to reducing printing and ensuring the service's quality, compliance and security.

Implementation of initiatives to reduce printing of customer documents by encouraging the use of e-mail instead of physical mail and by changing the rules of extraction and aggregation of documents sent by mail.

Poland The purchasing discipline and consequently the rational consumption of resources is enhanced through the use of an IT tool - REZA+ - through which each item ordered is verified as to the legitimacy of the purchase. The permanent monitoring of budget execution and the definition of limits to reduce purchases at the level of current consumption also contribute significantly to the reduction of material consumption. In 2022, there was a lower consumption of paper, despite the significant increase in the number of customers. The Bank permanently limits paper consumption through further digitalisation and process optimisation, for example, the Bank offers the option to open an account online with a selfie or with identity proof. Both processes are fully remote and do not require printing any documents. It has also promoted a marketing campaign encouraging customers to switch to digital statements, resulting in a significant decrease in the number of bank statements sent to customers. The popularity of payments using virtual cards, BLIK mobile payments and BLIK contactless payments via mobile app reduces the need to issue plastic cards. In addition, the temporary card lock option avoids the need to issue a new card (when, for example, a customer loses his card and finds it in the meantime). The provision of water purifiers for head office employees and water dispensers at branches has further reduced plastic consumption. In 2022, water purifiers were installed in 80% of corporate premises.

WASTE

Regarding waste production, in global terms, in 2022, there was an 5% increase in the total waste produced, compared with 2021. In Portugal there was a 16% reduction in the volume of waste generated in the three types of waste that make up the calculation.

Paper and cardboard Plastic Cartridges and
Tonners
Waste Produced (t) 2020 2021 2022 2020 2021 2022 2020 2021 2022
Activity in Portugal 471.3 851.3 717.3 2.55 2.23 0.49 0.78 0.60 0.72

In BCP Group, more important than the waste generated is the destination given to it, and, whenever possible, the necessary efforts are made to ensure its recycling or reuse.

Waste Produced, by destination (t) 2020 2021 2022
Recycled/reused waste 538.98 644.02 630.37
Waste to landfill 0.00 0.01 0.01
Other destinations 294.24 640.88 576.71
Total 830.23 1284.91 1216.09

Main waste reduction/management initiatives

In Portugal, the paper recycling process has been continued in the Archive and the OU.

Portugal It was also possible to reduce the number of copies and Office Printing with the entry of a new service provider, namely through: • Installation of New equipment and newer SW; • Reduction of the number of equipment. Poland The annual electronic waste collection campaign was organized at Bank Millennium Headquarters and allowed employees to donate equipment they no longer use. The Administration and Infrastructure Division encouraged employees to do their annual clean-up, allowing a convenient way to deliver electronic waste. Bottles and container caps are collected at Headquarters and Branches and donated to a charity institution. The capsules collected in 2022 by employees were donated to the Don Rodzina Człowiek Association, which will sell them as recyclable material and donate the money to: material assistance for poor and disabled people, financing the purchase of prosthetics, meals for needy families, among other initiatives. In 2022, the Bank modernised its headquarters in Gdansk. The furniture from the previous premises did not fit into the new headquarters premises and was not used in the Bank's other premises and was

therefore scheduled for liquidation. In order to minimise as much as possible the amount of waste resulting from the unnecessary liquidation of furniture, the Bank organised the sale of the furniture, including chairs, cabinets, desks, containers, tables, among others, through a specialised company. 901 goods were disclosed on the sale platform and although the furniture at the Gdańsk headquarters was older and had some wear and tear, the sale aroused great interest. Employees bought almost 50% of the equipment scheduled for liquidation. Employees also organised the equipment sale to raise funds for donation to charities. Ultimately, about 80% of the equipment was given a second life and only 20% was recycled because it was worn out or damaged.

Eco-friendly products and services offer

Considering the role of Banking as an accelerator of the green transformation of the economy, in addition to the Bank's actions within the scope of its operations (see chapter Sustainable Operations), the consideration of ESG criteria, namely environmental performance criteria, has been intensified in the Bank's offer of products and services. In the geographic areas in which it operates, products and services have been developed that consider environmental aspects or that are developed considering their environmental impact, and which aim to promote the adoption by customers of more ecological choices, promoting more sustainable life habits.

Providing financial solutions and products that show a concern for combating climate change and improving the quality of life is Millennium's commitment to sustainability, promoting the necessary changes for the development of a sustainable future.

Portugal

  • Green home loans product that requires compliance with energy classification requirements: acquisition or construction of properties with an A+, A or B energy classification; works on properties with an A+ and A classification or improvement of 2 more levels after the works.
  • Loans promoting electric mobility At a time when the relevance of rethinking new forms of mobility, more efficient, economic and, above all, more environmentally friendly, is reinforced, the Bank has prepared the "Green Leasing and ALD", a specific product that distinguishes vehicles: 100% electric (0% emissions) and hybrid cars with CO2 emissions up to 50g/km
  • Renewable energy personal credit - product for the purchase of equipment for the production or storage of renewable energy.
  • Decarbonisation and Circular Economy Credit Line Protocoled credit line to support projects for reducing energy consumption, of measures allowing the change from fossil to renewable energy sources, or accelerating the process of transition to a circular economy.
  • Green Home Promotion Credit product aimed at the construction or rehabilitation of buildings, residential or otherwise, that obtain top ratings in the most prestigious building environmental certifications.
  • ESG/SRI investment funds funds that respect social and environmental aspects and are made available to customers in the various distribution channels.

Poland

In 2021, the Bank launched the strategic EU green finance project, under which it prepared product and process infrastructures to effectively support businesses in their sustainable development, implementation of green investments and energy transition.

  • Millennium TFI Funds One of the measures implemented as part of Bank Millennium Group's strategy was to integrate ESG factors into the asset selection processes in investment portfolios. Millennium TFI transformed three separate Sub-Funds within the Millennium Specialised Open-ended Investment Fund, in accordance with the requirements of Article 8 of the SFDR. These sub-funds promote environmental, social and corporate governance aspects (so-called light green products) by including them in the investment selection criteria and applying certain investment restrictions.
  • WWF Millennium Mastercard credit card offered as part of the Bank's long-term partnership with the WWF Foundation Poland, this card is made with recycled plastic. As part of the long-term partnership with WWF Poland, Bank Millennium will provide financial support for the organisation's statutory activities to protect forest ecosystems. The cooperation involves, among others, issuing the WWF Millennium Mastercard credit card, which enables committed customers to support conservation efforts. Bank Millennium donates PLN 50 to the organisation for every WWF Millennium Mastercard issued. The card is made out of 85% recycled plastic..
  • Biznesmax Guarantee Programme (in cooperation with Bank Gospodarstwa Krajowego) The guarantee is used to secure loans granted to finance innovative projects in the SME sector, including environmentally efficient enterprises. Customers benefiting from the "environmental path" in the Biznesmax Guarantee Programme can execute an investment project with at least one category, for example: electromobility, renewable energy sources covering photovoltaic installations, technologies to reduce energy consumption, technologies to produce alternative fuels, circular economy, facilities to recover raw materials in production processes, etc.
  • Mój Elektryk programme implemented by Bank Ochrony Środowiska In 2022, Millennium Leasing joined the Mój

Elektryk programme implemented by Bank Ochrony Środowiska, which guarantees copayments from the National Fund for Environmental Protection and Water Management for leasing electric vehicles and copayments from the National Fund for Environmental Protection and Water Management for advance payment in leasing contracts for electric vehicles. The purpose of the programme is to reduce air pollution emissions by co-financing companies to reduce the consumption of fuel generators in transport. Co-financing is a support and incentive for the purchase/lease of zero-emission vehicles.

Green loans for photovoltaic projects: Self-consumption - The loan can finance 100% of the net construction costs of micro and small photovoltaic installations with a capacity up to 1 MWh, aimed at the production of renewable energy entirely for own needs. Mix - The loan can finance between 80% to 90% of the total net construction costs of a photovoltaic installation with the production of renewable energy for sale and own needs, but with a minimum level of 50% of self-consumption. The investment may also include the purchase and installation of an energy storage facility with a maximum capacity of 10 MW.

A few years ago, Bank Millennium in Poland decided to significantly reduce its exposure to the coal industry, whose financing constraints are expressed in the Environmental Policy. As a result, the portfolio of exposures to coal mining and directly ore-related industries is insignificant.

Mozambique

Smart IZI - Smart IZI is a totally digital service that covers all the moments associated with the service: subscription, registration and use. This service takes the form of a Mobile Banking application, through which private Customers can obtain information and submit operations wherever and whenever they need. Last year, the Bank invested in improving the service provision in this channel, simplifying the channel's adherence flow and making available documents such as current account statements and proof of debit and credit. By making these types of documents available in a totally digital way and free of charge, and other functionalities such as the updating of documents and international transfers, the Bank has contributed to a saving of resources that contributes to a reduction of negative environmental impacts.

Green Project Finance

Within the scope of the Bank's lending portfolio in Portugal, we seek to increase the percentage of funding for environmentally sustainable projects and organisations, having published in 2021 the Principles of Responsible Finance that identify, among other aspects, the excluded projects and sectors/projects constrained in the scope of the financing promoted by the Bank. As noted, in the last three years there has been an increase in the percentage of 'green' financing in the total project finance portfolio 3 4 , with an increase of 10 percentage points between 2020 and 2022.

Included in the scope of financed activities are Wind, Hydro, Biomass, Solar and other environmental issues, namely the financing of investments in urban waste collection and treatment plants, in drinking water distribution and wastewater treatment networks (ETAR), waste treatment plants, among others. As in previous years, the 'green' financing in wind energy is the most significant, representing 43% of the total number of projects.

"Green" financing at Millennium bcp

3 The Bank's Sustainable Financing Policy is available here: https://ind.millenniumbcp.pt/pt/Institucional/sustentabilidade/Documents/Principios\_financiamento-responsavel.pdf

4 The operations of project finance whose purpose is aligned with the Green Loan Principles.

"Green" finance by type of investment

Carbon footprint of the corporate loan portfolio

With the purpose of characterising the Bank's loan portfolio in terms of exposure to transitional climate risks and to complete the calculation of the Bank's carbon footprint, a sectoral analysis of the loan portfolio to companies was carried out, which made it possible to estimate the scope 3 downstream emissions, i.e. the indirect greenhouse gas emissions resulting from lending activity, and which constitute a significant part of the total scope 3 emissions of the credit institutions.4

The value of the carbon footprint of the loan portfolio to companies represents the contribution of the loan granting activity to the GHG emissions of the companies it finances, considering attributable to the Bank the emissions (scope 1 and 2) of the companies with exposure in the form of loans, in proportion to the activity of the companies that are financed by the Bank.

As part of the monitoring of the carbon footprint of the corporate loan portfolio, the Bank has identified which sectors are the largest contributors to scope 3 indirect emissions.

Manufacturing industries
represent 40% of the total emissions
Transport and storage
represent 27% of the total emissions
Water withdrawal, treatment
and distribution & Sanitation,
management of waste and de
pollution
represent 7% of the total emissions
Wholesale and retail trade &
Repair of motor vehicles and
motorbikes
represent 6% of the total emissions
Agriculture, livestock, hunt
ing, forestry and fishing
represent 5% of the total emissions
Construction
represent 4% of the total emissions
Accommodation, restaurants
and similar
represent 3% of the total emissions

Top 8 Sectors

4 Information of scope 1 and 2 emissions of the companies comes from the respective report when available, and is estimated based on information of fuel and electricity costs in the other cases.

In the case of credit exposure to holding companies (CAE 64201, 64202 and 70100), which perform management functions within economic groups and whose sector of activity does not reflect the economic activities to which they are actually exposed, the exposure was allocated to the sectors of activity of the related companies in proportion to their respective assets.

Emissions associated to suppliers

The carbon footprint associated to suppliers corresponds to scope 3 emissions that result from the acquisition of goods and services5 .

Estimated Scope 3 emissions (%)

Taxonomy of the European Union

In its Sustainability Master Plan, Millennium bcp defined objectives that respond to the most recent trends in sustainable finance and disclosure of non-financial information, namely with the European Union Taxonomy classification system (EU Regulation 2020/852), which will be essential to promote transparency of information in the market.

Taxonomy is a system that identifies economic activities that can be considered green or environmentally sustainable and that will empower investors, companies, issuers and project promoters in the transition to a resilient, efficient and low-carbon economy, translating the EU's climate and environmental objectives into criteria for investment in certain economic activities.

On this basis of transparency and regulation, the European Commission adopted on 6 July the Delegated Disclosure Act, which sets out the information - content, methodology and presentation - to be disclosed by financial and non-financial companies regarding the proportion of environmentally sustainable economic activities of their business, investment or credit activities, in the form of KPIs and templates for different types of entities.

In this context, Millennium bcp discloses the applicable indicators and information pursuant to Article 10 of the Delegated Act of Article 8 of the EU Taxonomy:

2(a) Proportion of exposure to Taxonomy eligible economic activities
in total assets
2.95%
2(b) Proportion of exposure referred to in Article 7 paragraphs 1 and 2
(central governments + central banks + supranational issuers + deriva
tives) in total assets
27.69%
2(c) Proportion of exposure referred to in Article 7 paragraph 3 (enti
ties not required to report under the NFRD) to total assets
63.26%
2(d) Qualitative infor
a. Contextual information to understand the
mation as referred to in
quantitative indicators (including at least
Annex XI
the scope of covered assets and activities,
data sources and limitations)
On the indicator 2(a) Proportion of exposure to Taxonomy eligible eco
nomic activities in total assets:
The numerator includes: cash balances and other demand deposits to
Central Banks, securities, equities and credit to NFRD entities.
The denominator includes: all assets of the Loans and advances, debt se
curities, equities and repossessed collateral types, except sovereign ex
posures (securities and credit) and trading portfolio.
NFRD entities were considered to be listed companies, banks, insurance
companies and others identified by national authorities as being of pub
lic interest.
Source: FINREP as of December 31, 2022, at BCP Group level.
On indicator 2(b) Proportion of exposure referred to in Article 7 para
graphs 1 and 2 in total assets:
The numerator includes cash balances and other demand deposits with
Central Banks; securities (central governments + central banks + supra
national issuers); credit (central governments + central banks + suprana
tional issuers); derivatives.
The denominator includes: all assets of the Loans and advances, debt se
curities, equities and repossessed collateral types.
Source: FINREP as of December 31, 2022, at BCP Group level.
On indicator 2(c) Proportion of exposure referred to in Article 7 para
graphs 3 in total assets:
The numerator includes cash balances and other demand deposits to
Central Banks, securities, equities and credit to non-NFRD entities.
The denominator includes: all assets of the Loans and advances, debt se
curities, equities and repossessed collateral types.
Non-NFRD entities were considered to be those other than listed compa
nies, banks, insurance companies or others identified by national author
ities as being in the public interest.
Source: FINREP as of December 31, 2022, at BCP Group level.
On the indicator Proportion of trading portfolio and interbank on de
mand loans in total assets:
The numerator includes trading portfolio; interbank loans on demand.
The denominator includes: all assets of the Loans and advances, debt se
curities, equities and repossessed collateral types.
Source: FINREP as of December 31, 2022, at BCP Group level.
c. Description of compliance with Regulation
(EU) 2020/852 in the business strategy,
product design process and engagement
with customers and counterparties.
If and how the entity uses Taxonomy in its
business strategy, product design process
and engagement with customers and coun
terparties.
The Bank is preparing the alignment of its activity with Taxonomy EU, in
the context of which it has already taken concrete steps:
- Assumption of commitments, in its Sustainability Master Plan, to create
and develop green offer;
- Adoption of the EU Taxonomy as a reference for the design and identi
fication of the offer as green;
- The framework for analysing proposals for funding relevant amounts
and/or sectors of activity with impact already involves ESG due diligence
and alignment of the activity and/or the use of proceeds with the EU
Taxonomy;
- In the oil and coal sectors, it has made a commitment to limit funding
for purposes of transition to a low carbon economy and ongoing man
agement;
- Report, in the 2022 Sustainability Report, as per requirements of Article
10 of the Delegated Act Article 8 (disclosure) of the Taxonomy.
Proportion of trading portfolio and on demand interbank loans in total
assets
0.85%

5 The scope 3 emissions associated to suppliers (amount) were calculated using spend-based methodologies, which tend to be more conservative, so the calculation presented here is mainly illustrative and intends to present an order of magnitude based on an estimate of these emissions.

Climate Materiality assessment

In 2022, Millennium bcp performed its first materiality assessment for Climate and Environmental (C&E) Risks, thereby characterising the impact of key C&E transmission channels relevant for the Group. This assessment allows to estimate the materiality of C&E risk as a driver on all other risk types in its risk taxonomy and evaluate the implications across portfolios. Forming an understanding of the potential impacts of climate change on its business and the businesses of its customers will allow the Group to make informed decisions on how to manage and mitigate these risks, while allowing for the identification of new opportunities arising from the transition to a low-carbon economy.

Scope of the assessment

The materiality assessment covered the three key geographies to which the Group has significant exposure – Portugal, Poland, and Mozambique. The initial assessment covered all the main portfolios and focused on the two main drivers of climate risk:

  • Transition risk: Transition risks refer to the financial risks associated with the shift to a low-carbon economy. This transition may involve changes to energy systems, regulation, taxation and investment patterns, which could disrupt established business models and cause significant financial losses in vulnerable sectors or enterprises.
  • Physical risk: Physical risks refer to the direct and indirect impacts of physical changes to the natural environment caused by climate change. These risks include events such as extreme weather conditions (e.g., heatwaves, hurricanes, droughts), sea-level rise etc. These risks can cause physical damage to assets, infrastructure, and communities, as well

as disrupt supply chains, causing financial losses and reducing economic productivity. In the assessment, the Group covered both Acute and Chronic Physical risk events1 . In terms of the acute risks, the Group analysed the impact from wildfires and flood, while for the chronic risks, the impact from drought and sea-level rise were assessed.

In terms of risk types, the bank has analysed all the risks where climate can have a relevant effect, which include relevant portfolios in credit risk, market risk, business risk, operational risk, reputational risk, pension fund and real estate risk, IRRBB and liquidity risk.

Overview of methodological approach

The Group developed a bespoke, three-step approach to perform the materiality assessment:

  • Compile a comprehensive list of potential risk drivers, covering both transition and physical risk, as well as the main risk types (i.e., credit, market, operational, etc.) and transmission channels derived from Millennium bcp's existing risk taxonomy.
  • Develop a risk heatmap to illustrate the underlying inherent and residual risk2 associated with different asset classes and risk types. The assessment for each asset class and risk type was established via four risk levels (high risk, medium-high risk, medium-low risk, and low risk) to classify the overall residual risk for the Bank.
  • Perform a quantitative analysis using a bottom-up assessment approach, of the main portfolios, leveraging granular customer and exposure information, as well as other inputs, such as loss events for operational risk or income data for assessment of business risk. Additionally, quantitative analyses were also performed and then synthetized to estimate the materiality level for each portfolio and risk type.

The methodology to compute those impacts has leveraged other climate risk quantifications performed within the Group, such as the pilot bottom-up Climate Risk Stress Testing exercise executed in 2022. In terms of data, the analysis was based on internal data sources at granular level for exposures or company financials, amongst other and also used a range of external reports and databases to estimate climate risk impacts, including ECB's 2022 climate scenarios developed for the 2022 SSM Climate Stress Test, amongst others. The four levels of risk used in the materiality assessment are defined as follows:

  • High risk: Assigned to portfolios that are highly vulnerable to physical impacts from climate change and/or to significant disruptions from the transition to a low-carbon economy. Bank's exposure to the climate related risks stemming from these portfolios is carefully managed and monitored.
  • Medium-high risk: Assigned to portfolios that are moderately vulnerable to physical impacts from climate change and/or to some disruptions from the transition to a low-carbon economy.
  • Medium-low risk: Assigned to portfolios that are relatively less vulnerable to physical impacts from climate change and/or to disruptions from the transition to a low-carbon economy. While these sectors or regions may face some risks, they are expected to be relatively minor and manageable (either through mitigation action applied by the counterparty or the Group).
  • Low risk: Assigned to portfolios that are expected to experience minimal or no physical impacts from climate change and/or disruptions from the transition to a low-carbon economy. These sectors or regions are considered to be relatively low risk and may be less impacted by changes in the economy and climate.

Overview of assessment results

While performing the materiality assessment, the Group also integrated a forward-looking perspective into its assessments (e.g., sectorial GVA scenarios provided by ECB for Portugal and Poland were considered to identify the most vulnerable sectors and sub-regions within these countries). This has allowed the Group to develop a more holistic picture of the overall materiality of C&E risks by complementing the existing starting point information with a prospective view.

1 Acute physical risks refer to sudden and intense impacts of physical changes caused by climate change, such as extreme weather events, including hurricanes, heatwaves, and floods. The impact of acute physical risks is often immediate and visible. Chronic physical risks, on the other hand, refer to the gradual and ongoing impacts of physical changes caused by climate change, such as sea-level rise, changes in temperature patterns. The impact of chronic physical risks may not be immediately apparent but can accumulate over time.

2 Residual risk includes mitigation actions that are already applied either by the Group or by counterparties to limit the impact of climate risk.

For assessment of the transition risks, the Group considered a combination of existing and forward-looking drivers to calibrate the final materiality score. Some of these drivers are illustrated below for the credit risk assessment of Non-Financial Corporates:

  • Existing emission intensities of the sectors and some of the largest counterparties were assessed to identify the transition risk vulnerable pockets in the portfolio as of today.
  • A forward-looking perspective was integrated through the use of climate-adjusted, sectorial Gross Value Added (GVA) pathways provided by ECB for the 2022 SSM Climate Stress Test. GVA pathways under the high transition risk scenarios, like Disorderly Transition, were considered to identify the sectors in Poland and Portugal which are expected to remain vulnerable to transition risks going forward.
  • Drivers that may have an impact on the credit quality of individual corporates going forward such as transition plans of the counterparties (where available) were also factored in.

For physical risk as well, a similar approach was followed by the Group. Focusing on the four key physical risk events: wildfires, flood risk, drought, and sea-level rise, the Group developed an intensity matrix across municipalities in the countries in scope. In particular, the impact of sea-level rise was assessed at a more granular level, in order to accurately take into consideration altitude and distance to the shore. These physical risk impacts were then individually evaluated on collaterals and the bank's own assets. Additionally, the forward-looking physical risk impacts, captured in the ECB's sectorial GVA pathways, were evaluated for key counterparties of the Group. For this, the impacts captured in the severe physical risk scenarios – Hot House World – were taken into consideration by the Group.

Depending upon the risk dimension and type of the portfolio, the Group further adapted the guiding principles for assessing the transition and physical risk described above. This is detailed in the next Exhibit along with summary results of the materiality assessment (inferred via inherent risk and residual risk).

Risk type High level overview of assessment approach Portfolio covered Inherent
Bisk
Residual
Alsk
Mitigants
Credit risk Households mortgages: materiality assessment based on poten-
tial stress on the collateral value based on relevant driver (i.e.,
damages for physical risk, EPC label for transition risk) as a driver
for LGD impact; assessment based on vulnerability of sectors of
activity of debt holders as PD driver
Household others: assessment based on vulnerability of sectors of
activity of debt holders
NFCs: materiality assessment conducted at sector level assessing
physical and transition risk at NACE sector with further collateral
assessment for CRE
Sovereign: materiality based on GVA impact under different sce-
narios and its implications on debt repayment
Banks and OFCs: assessment at counterparty level due to high
concentration
Household mortgages, Re-
tail non-secured products,
Non-financial corporates
(including Commercial Real
Estate), Banks and other fi-
nancial corporates, Sover-
eign debt
Note: Deep dive on results
of Non-Financial Corpo-
rates by sector of activity
provided in Exhibit 3
Medium-
Low
Medium-
Port
Implemented sector exclusion policies
Monitoring counterparty level ESG ratings
Significant exposure covered by financial guar-
antees provided by sovereign and suprana-
tional bodies
Majority of collaterals have multi-risk coverage
Implemented green mortgages products which
are expected to increase relative exposure to
low risk assets
Market risk Sovereign: materiality based on GVA impact under different scenar-
ios and its implications on debt repayment
Non-financial corporates (in-
cluding Commercial Real Es-
tate), Banks and other finan-
cial corporates, Sovereign ex-
posures
Law LOW Limited exposure to market risk in general as com-
pared
to the overall size of the balance sheet
Credit
concentration
Lisk
Materiality assessment at counterparty level understanding sector
impact, position of the company from external ratings and reports,
etc.
Non-financial corporates (in-
cluding Commercial Real Es-
tate), Banks and other finan-
cial corporates
Law Caw Low concentration of exposures: Top 10 counterpar-
ties of the Bank represent, on average, slightly over 1%
of exposure
Business risk Assessment based on impact in revenues deriving from not adapting
to market changes or from choices to react to transition (e.g., sector
exclusion policy, restrictive lending for certain EPC labels)
Assessment of NII and NFCI by level of sector materiality
Medium-Low Law The Bank is launching new products to respond to cli-
mate related demand shifts:
Household Mortgages: Green mortgages with dif-
ferential conditions
Household Others: Electric vehicle loans, solar
panel financial, etc.
NFC: Opportunities from new activities (inc. advi-
sory services on transition
Operational
પાર ર
Operational risk derived from climate will mostly center on impacts
on business continuity associated with key physical hazards relevant
for the Group (wildfires and flood)
LOW LOW Offices and support buildings are not located in areas
with significant risk for either event
Reputational
Lisk
Assessment of the potential impact of climate associated with con-
duct
Risk based on internal and external events
Materiality assessment of business continuity analyzing all physical
risks of
the bank's branches and premises
Bank wide risk assessment Medium-Low LOW Business continuity plan in place
Pension funds
TISK
Assessment of vulnerability to physical and
transition risk drivers of the underlying assets (focusing
primarily on Bonds and Investment Funds) held by the
Pension Fund of the Group. Assessment conducted at counterparty
level
for top exposures
Medium-Low rom Closely monitoring of C&E risks
Real estate
tisk
Assessment of losses in the value of the assets owned by the banks
and its consequent impact in P&L due to:
1) Impact of physical events (including flood, sea level rise etc.)
2) Impact of transition risk (e.g., change in value driven by EPC)
LOW Lam Low exposure to assets on the balance sheet (<1%)
Liquidity
usk
Assessment of potential adverse impact on the
existing liquidity position of the Group (inferred
through Liquidity Coverage ratio) under different what-if scenarios
Low LOW Limited impact observed on outflows
under scenarios of differing severity

The results of the assessment indicate that climate risk has a medium-low residual impact on credit risk, driven by the impact on mortgages and non-financial corporates, whilst the overall materiality for the bank is currently minor for the rest of risk types. By geography, climate risk materiality is mainly driven by Portugal and Poland, and the analysis suggested that Mozambique's climate risk materiality is less relevant, given that it represents a relatively low percentage of total assets, with the exception of sovereign risk, where Mozambique represents approximately 9% of total exposure.

Exhibit 1. Overview of portfolio level results by risk type

Activity sector Transition risk Physical risk Exposure (%)
Agriculture, forestry and fishing 2
Mining and quarrying 1
Manufacturing of food products, beverages and tobacco 5
Manufacturing of textiles, clothes and paper materials 5
Manufacturing of coke, refined petroleum and chemical products 1
Manufacturing of pharmaceutical products 2
Manufacturing of basic materials, vehicles and electronics 10
Electricity, gas, steam and air conditioning supply 2
Water supply; sewerage; waste management and remediation activities 2
Construction 10
Wholesale and retail trade; repair of motor vehicles and motorcycles 21
Transporting and storage 7
Real estate activities

Exhibit 2. Overview of materiality assessment for NFCs by sector of activity

Governance and additional progress

The Group plans to conduct the materiality assessment on periodic basis. A yearly high-level assessment will determine if the expected climate changes are expected to change significantly and, if so, the materiality assessment would be repeated. If the changes are not relevant, the materiality assessment will be nevertheless repeated in 3-5 years.

Finally, the Group has committed to improving its climate risk assessment in several areas in order to keep benefiting from it. For that purpose, the Group is enhancing its methodological approaches and investing on data solutions to improve the granularity and quality of its climate-related information.

Other environmental risks - biodiversity risks

After the risks arising from climate change, in terms of adaptation and mitigation, the risks relating to the loss of biodiversity and the efforts aimed at its necessary conservation are part of the political and legislative priorities at European level. Concerns about the impact of these risks are also growing on the prudential side.

In this aspect, the necessary conservation of biodiversity or natural systems is valued, and concerns are raised about the economic impacts resulting from the scarcity or interruption of the supply of natural resources to productive activities.

In an innovative manner, Banco de Portugal has developed a methodology for assessing these risks, which, for the first time, was used to assess the materiality of the risks of (and for) biodiversity in the Bank's loan portfolio.

The methodology is based on the ENCORE classification, which provides qualitative materiality assessments for each economic activity's dependence on, and impacts on, ecosystems.

The assessment of dependence on ecosystems is determined by analysing the contribution, direct or indirect, that an ecosystem provides to an economic activity. Examples of such contributions include forest, mineral or water resources.

Considering a) the operational or functional significance of the contribution to a given economic activity, assessed in a scenario of interruption in its supply; and b) the relevance of the associated potential economic loss, a dependency classification was obtained.

Complementarily, the assessment of the impact that a particular economic activity (and the respective production processes) has on ecosystems was valued. In this assessment three vectors are considered: a) the frequency of impacts; b) how quickly a given impact can begin to materially affect the ecosystem; and c) the severity of impacts.

An individual assessment was made of each corporate loan portfolio exposure in terms of (a) its dependence on the use of natural capital; and (b) its impact on the ecosystems to which it relates, based on a sectoral analysis.

The following results were obtained by normalising the assessments and aggregating them in a matrix format:

Distribution of credit exposure to non-financial companies

Overall, and notwithstanding the concentration of exposure in medium risk ratings, it can be observed that the Bank has minimal exposure to activities with high biodiversity risks.

Notwithstanding the better knowledge that the Bank may obtain in the future about these risks, namely through the collection of information from its customers, based on the results of this analysis it is possible to start defining management and monitoring strategies for the impacts of biodiversity loss on its financing.

Photovoltaic plant - central services in Taguspark (Portugal)

Photovoltaic plant - central services in Gdansk (Poland)

Task Force on Climate-related Financial Disclosures (TCFD)

BCP Group is committed to reporting relevant information to Stakeholders in the scope of its contribution to the fight against climate change. In this sense, the Bank seeks to align its reporting with the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD), as presented in this chapter.

GOVERNANCE

In order to guarantee an effective management of environmental issues in the Bank (including climate change), the existence of a Governance structure transversal to the organisation is ensured, capable of responding to environmental issues and ensuring a timely decision-making aligned with the strategy of BCP Group.

Ownership Activities
Board of Directors Approval of Corporate Policies and Principles
Approval of the Sustainability Report
Monitoring of the implementation of the SPM through progress reporting included in the
Risk Appetite Statement
Executive Committee Approval of the SMP
Monitoring of the implementation of the SPM through progress reporting included in the
Risk Appetite Statement
Sustainability Commission
Chaired by the Chief Executive
Office, Chief Risk Officer and
heads of other Divisions
Monitoring the implementation of the SPM that includes ESG components and climate
change related
Risk Commission
Composed of the Chief Executive
Office, Chief Financial Officer,
Chief Risk Officer and heads of
other Divisions
Definition and supervision of the global risk management framework (including ESG risks)
Formal integration of ESG risk monitoring into the themes monitored by the Commission
(Art. 7 - Competences, tasks and duties)
Identification of risks related to climate change and incorporation of policies and proce
dures to ensure the continuity of the Bank's activity in the event of natural disasters
Sustainability Areas Implementation, internal promotion, and monitoring of the SPM actions, which include cli
mate change related actions, namely in the areas of improving energy efficiency and in
creasing the consumption of energy from renewable sources
Support to the structuring of supply with environmental criteria
Support to the management of climatic and environmental risks in compliance with the ap
plicable regulations, objectives, and targets

STRATEGY

Climate change is a risk considered relevant to BCP, with potential to impact the Bank in the short (up to 1 year), medium (1 to 3 years) and long term (3 to 15 years). The specific physical and transition risks that BCP Group faces in the 'climate change' risk category are presented below, as well as the mitigation measures being adopted by the Bank. The risks and their potential financial impacts are identified through internal processes of management and control of the various risks typologies according to internal taxonomy, and which consider the impact of climatic and environmental factors.

RISKS
Risk Description Impact Cost
REGULATORY RISKS Current reg
ulation on
emissions
reporting
Risk of non-compliance with more demanding regulations under the
European Union Directive on the Energy Performance of Buildings, as
several buildings owned and operated by the Bank are covered by the
Directive. To manage this risk, BCP is committed to implementing en
ergy efficiency measures, such as the installation of LED lighting, in all
geographies where it operates.
short term € ~1.2 M
Current
product and
service reg
ulations
Climate regulation impacting corporate customers and BCP's credit
and financing portfolio may result in additional compliance costs. In
addition, if a BCP customer fails to comply with the regulation and
does not have the funds to pay the fines or penalties, BCP, as lender,
medium
term
€ ~2.5 M
RISKS
Risk Description Impact Cost
may be held liable. To mitigate this risk, BCP commits its customers
not to use credit funds for actions included in the Environmental and
Social Exclusion List of the EBRD (European Bank for Reconstruction
and Development), and to hold all necessary environmental licenses
related to their activities.
Emerging
regulation
The increase in fuel prices in Portugal may represent an increase in
operating costs related to transport, the bank's fleet and the buildings
heating. To mitigate this risk, BCP is renewing its fleet, replacing them
with more efficient vehicles that have less environmental impact, so
that, in Bank Millennium, most of the fleet has been replaced by hy
brid models.
medium
term
€ ~0.29 M
REPUTATIONAL
RISKS
Reputation BCP faces competitive risks imposed by competitors and public opin
ion regarding the issue of climate change and may incur in reputa
tional risks if stakeholders do not understand whether the Bank is re
sponding adequately to the climate change issue. To mitigate this risk,
BCP is developing low carbon products and services and participates
in recognised sustainability indices, such as the CDP, in order to im
prove its reputation on climate change.
short term € ~5.70 M
Acute Phys
ical
Changes in physical climatic parameters can lead to natural disasters.
To mitigate this risk, as an example, BCP has a Business Continuity
Plan and insurance coverage for assets in case of natural disasters.
long term € ~1 M
PHYSICAL RISKS Chronic
physical
Higher temperatures or heat waves will potentially increase energy
demand for cooling in BCP branches and buildings, thus incurring
higher operating costs. To mitigate this risk, BCP is implementing en
ergy efficiency measures in its buildings.
short term € ~1.2 M
OPPORTUNITIES
Opportunity Description Impact Cost
Use of new technologies Installation of low carbon equipment and implementation of energy
efficiency measures that have the potential to reduce the operational
costs of the Bank's main central buildings and branches. In order to
take advantage of this opportunity, BCP Group is implementing en
ergy efficiency measures.
short term € ~0.50 m
Use of lower emission
energy sources
The use of lower emission energy sources and the installation of low
carbon equipment could reduce the operational costs of BCP's main
central buildings and branches. To take advantage of this opportunity,
BCP installed a photovoltaic panel plant at its buildings in Oeiras, Por
tugal.
short term € ~0.15 m
Reputational benefits re
sulting in increased de
mand for goods/services
Adapting financial products and services to a low-carbon economy
(e.g. SRI funds) could enhance the Bank's reputation, and conse
quently result in gaining new customers and revenue streams. To take
advantage of this opportunity, BCP is selling several low carbon prod
ucts and services.
medium
term
€ ~5.7 M

1 Further detail on the methodology and description of the costs associated with climate risks available in the BCP Group's response to CDP Climate Change 2022. Further detail on energy efficiency measures in buildings is available in the Environmental Responsibility chapter.

Details on BCP Group fleet change are available in the Environmental Responsibility chapter.

Further detail on low carbon products and services is available in the Environmental Responsibility chapter.

Details on BCP's response to sustainability indexes are available in the Sustainability Indexes and Recognition chapter.

For details on energy efficiency measures, see the chapter on Environmental Responsibility

BCP keeps developing and planning further actions to better understand exposure to climate change-related risks on its business and to mitigate corresponding impacts. In this sense, in 2022 the Bank:

• Actively participated in the European Central Bank's (ECB) climate stress test exercise, the first EU-wide effort to assess banks' climate risk capabilities and industry exposure to physical and transition risks;

  • Participated in the ECB Thematic Review, which assesses the alignment of each bank with the ECB's expectations on climate and environmental risks - and developed and continues to develop actions towards further alignment with those expectations;
  • Developed its first materiality assessment of climate and environmental risks, thus deepening the understanding of the impacts of these factors on the Group's activities;
  • Developed and operationalised its internal capacity for climate stress tests.

Given the risks and opportunities of climate change, BCP continues to adapt its business strategy to manage and mitigate the former, and to enhance the latter.

Climate and environmental change as a strategic priority

In line with the strategic priority given by the Bank to sustainability, and reflected in its Overcoming 24 Strategic Plan, BCP continues to adapt its business model to increase differentiation in the face of growing customer and other stakeholder expectations related to sustainability, while capturing related business opportunities and responding to regulatory requirements.

In this context, BCP remains committed to carbon neutrality by 2050, and has deepened its understanding of its environment, completing a thorough materiality assessment of physical and transitional risks in the economic activity sectors it supports and in the regions where it operates.

In addition, BCP continues to strengthen its offer of products and services adapted to customer needs, supporting them in the transition to a low carbon economy and capturing opportunities related to climate and environmental change, in alignment with the European Union Taxonomy.

Continuous adaptation of the management and control structure for climate and environmental risks

In 2022, the Bank continued to adjust and strengthen its framework for managing and controlling climate and environmental risks, defining and diffusing responsibilities across the various functions of the organization, from business origination to new product development processes, risk assessment and monitoring, IT infrastructure, process control and audit, and disclosure. The developments and improvements described below are a non-exhaustive list of what has been achieved within this scope:

  • Implementation of actions to bring BCP's performance closer to the ECB expectations and the European Banking Authority (EBA) guidelines on climate and environmental risks, in particular addressing the priorities identified in the context of the ECB Thematic Review;
  • Strengthening the process of in-depth and detailed assessment of the materiality of physical and transition risks in the risk typologies of BCP's risk taxonomy (e.g. credit risk, market risk, liquidity risk) and in its various portfolios (e.g. mortgage, retail, non-financial corporations);
  • Operationalisation of internal capacity and skills for the development of bottom-up climate stress tests, at counterparty level for non-SME non-financial companies and at portfolio level for the remaining portfolio;
  • Design and kick-off of an IT platform that aggregates and integrates all ESG data, both internal and externally sourced (for example: obtained through customer engagement or via data providers), to meet varied business and reporting needs; and
  • Involvement of the organisation in the start-up of the design of an integrated target operating model for sustainability.

RISK MANAGEMENT

As indicated in the previous section (Strategy), BCP has a formal annual process to identify, assess and manage over 60 types of risk, including "climate change" risk and "property and disaster" risk (which includes extreme weather conditions). The Risk Officer annually leads the risk identification and assessment process, with support from other Group divisions. The process consists of a self-assessment exercise of the risks impacts to the Group and its subsidiaries through formal risk identification workshops and expert panel discussions, to provide an informed opinion on risk factors, probability and materiality to BCP Group's capital and liquidity position.

METRICS AND TARGETS

As part of its environmental commitment, BCP established carbon emission reduction targets, namely reducing scope 1, scope 2 and scope 3 GGE emissions by 7% in 2022, compared to the previous year, for operations in Portugal. BCP in Portugal also has a target of decarbonising its vehicle fleet by 80% by 2030. Poland has made a commitment to replace all cars with hybrid or electric models by 2030.

BCP monitored its GGE emissions (Scope 1, 2 and 3) and presents its performance and evolution in the Environmental Responsibility chapter. In 2021, regarding operations in Portugal, Scope 3 emissions associated with suppliers (upstream) and with the portfolio of loans to companies (downstream) began to be monitored. In addition to the information referred to above, the Bank monitors other metrics related to climate change and reports them in the chapter on Environmental Responsibility. (More detail on low carbon products and services is available in the Environmental Responsibility chapter).

Metrics and targets related to climate change are incorporated in BCP's remuneration policies: the variable remuneration of the Executive Committee (EC) and remaining employees is determined by several Key Performance Indicators (KPI), which include, in the case of the EC, the percentage of compliance with the SPM targets (which foresees actions aimed at reducing emissions). Additionally, the Chief Risk Officer (CRO), in 2022, is assigned an individual KPI related to the fulfilment of the implementation plan for monitoring climate and environmental risks.

Millennium bcp doubles its green energy production capacity with the installation of a 2nd photovoltaic plant on the Bank's premises in Taguspark, Portugal

Highlight: ACTIVOBANK

ActivoBank

ActivoBank was the first paperless Bank in Portugal and since its creation it has had sustainability concerns.

In 2022 we highlight the substantive change in the Bank's sponsorship positioning, directing this amount to investments in social and environmental areas: the protection of the Oceans and the fight against Cyberbullying.

Also in the products, the integration of bank products in the sustainability area was evident, especially in the Credit, Investments and Cards area.

This information is now present in the bank's institutional website, and allows the integrated monitoring of the various sustainability initiatives (Sustainability ActivoBank | Do you accept to join the change?), and where, through the PROATIVO seal, the various aspects of the offer with sustainability impact are signalled.

Initiatives carried out in the field of Sustainability

Products and Services with Social and Environmental Benefits

ActivoBank continued a financing strategy adjusted to the needs of its Customers, with a lower price for loans based on choices that address environmental issues, thus seeking to encourage Customers to make more sustainable choices within their consumption projects.

At the end of 2022, Credit for new or used cars and motorbikes with 100% electric or hybrid engines with CO2 emissions not exceeding 50g/km and motorbikes with 0g emissions was launched, with attractive financing conditions and differentiated rate.

It kept its offer of Training Credit, providing suitable conditions for financing specialised courses, in Portugal and abroad, and Energy and EcoActive Credit, pursuing a policy of supporting its Customers' sustainable habits, by financing equipment, articles or means of travel.

We have substantially increased the number of cards produced from recyclable materials (approximately 79% of our cards an average of 580 cards per day - are already produced from recycled plastic).

The account opening is representative of the dynamics of process digitalisation. In 2022 100% of the accounts opened in ActivoBank had a digital signature, either by direct opening on digital platforms or by digital signature at an Activo Point.

99.7% of our Customers already opt to receive their statement in digital format, avoiding the printing and mailing of documents and contributing to the sustainability of natural resources.

Availability in the app of the digital contracting of the ECOActivo Credit, allowing simplified access to a product whose purpose is to support Customers in choices aimed at improving the energy efficiency of their homes and environmentally friendly mobility.

Customers with an Activo salary also have access to sustainable mobility products, with advantageous conditions, available in a showcase of articles - checklist.

Additionally, in terms of investments and given the recent mandatory classification of investment funds, we have 71% of our offer of funds classified as article 8 and article 9, which allows us to provide our customers with a very comprehensive offer of funds that promote environmental and/or social sustainability or whose investment objective is exclusively sustainable.

Initiatives to improve community financial literacy

Within the scope of Financial Literacy we ensured a set of contents, which were made available in ActivoBank's digital communication channels - Facebook, Youtube, Instagram, LinkedIn and TikTok. These contents were published in the following formats: Conferences, webcasts or informative videos and images.

There was also a partnership with Cofina, in which financial literacy contents on Investments were developed for Branded Content publications. Due to the scope of the platforms used, these contents were available to Customers and non-Customers.

With regard to digital literacy, we ensured a set of contents, which were made available in ActivoBank's digital communication channels - Instagram and LinkedIn. These contents were published in video format and informative images.

Involvement with the local community, impact assessment

During 2022, ActivoBank developed 11 social solidarity actions through its line "Dar Créditos", from Conversas Activo. Every month, an Association or Social Project was chosen by the interviewees in the program and supported with an amount up to 2,000 euros.

The donated amount was determined through a Solidarity Campaign, which consists in raising funds associated to the subscription/contracting of ActivoBank products or services. Besides the monetary contribution, visibility was also given, throughout the year, in the digital communication means of ActivoBank - Instagram page -, Site and App to each Institution and a few months later a visit and interview was made to understand how this donation was used, which is quite relevant, since it allows promoting the importance of these institutions within the community and raising new support, or volunteers.

Examples of publications about the Social Institutions/Projects:

Supported projects:

February - Johnson's Academy

• On the project: Johnson's Academy is the result of perseverance and the teachings that life gave to João Semedo, better known as Johnson. Born in Cova da Moura, he had a very hard and adverse life path, with some deviant behaviours that even led him to be imprisoned in prisons. After changing his life more than ten years ago, Johnson has focused on applying his personal experience in order to prevent risky situations for other young people in precarious situations.

• Contribution: ActivoBank donated 2000 euros to contribute to the Johnson Academy activities.

March - Salvador Association

• On the project: Associação Salvador's mission is to promote the inclusion of people with motor disabilities in society and improve their quality of life, enhancing their talents and raising awareness of equal opportunities.

• Contribution: ActivoBank donated 2000 euros to contribute to Salvador Association to continue its work of promoting the inclusion of people with motor disabilities in society and improving their quality of life.

April – UMAR

• On the Association: UMAR - União de Mulheres Alternativa e Resposta - is a women's association founded on 12 September 1976. As a Non-Governmental Organisation it is represented in the Consultative Council of the CIDM (Commission for Equality and Women's Rights) since 1977. Today, UMAR is an association committed to awakening feminist consciousness in Portuguese society.

• Contribution: ActivoBank donated 304 euros to contribute to the awareness Mission of UMAR.

May – Dimix Mission

• On the Association: The MISSION DIMIX ASSOCIATION is a non-profit association, which was born in 2016 from Sónia Pessoa's challenge to her friends, united by a cause to create a sharing project and together give their hands to children and young people in São Tomé and Príncipe.

The Dimix Mission, has as its object the promotion and defence of Human Rights, especially of children, young people, adults and the elderly, belonging to more isolated social classes, support for development in the areas of Education, Environment, Health, Equality, Development, Food, Hygiene and Solidarity. The promotion of culture, teaching and dissemination of artistic activities in a socially disadvantaged context, through various initiatives and events, such as lectures, information sessions, education, communication, social responsibility, collection and fundraising or goods.

• Contribution: ActivoBank donated 2000 euros to contribute to a better daily life for the children and young people of São Tomé Príncipe.

June – Aldeias SOS

• On the Association: The Aldeias SOS are a non-profit Non-Governmental Organisation (NGO) and a Private Institution of Social Solidarity (IPSS) of support to children. They currently develop various social responses, in the alternative care and family strengthening programmes.

• Contribution: ActivoBank donated 2000 euros to contribute to the support activity for children and young people who are in vulnerable situations.

July – Cova do Mar

• On the Association: Cova do Mar is a non-profit association for activist and humanitarian action. We carry out our mission in two ways: through field projects of profound social impact and through advocacy actions (public policy activism).

• Contribution: ActivoBank donated 2000 euros to contribute to the humanitarian actions in Cova do Mar.

August – Refood

• On the Association: REFOOD's mission is to rescue food, feed people and include the entire local community, co-creating a more sustainable, fair and caring society.

• Contribution: ActivoBank donated 1610 euros to help Refood to continue to prevent food waste while helping to feed those most in need.

September – Casa das Cores

• On the Association: Casa das Cores is a Shelter for children in danger. It offers them a healthy and balanced environment that allows them to Grow as Children and build a happier Life Project

• Contribution: ActivoBank donated 1998 euros to contribute to Casa das Cores to improve the conditions of its spaces and become an even more welcoming place for children in danger.

October - Oceans without Plastic Association

• On the Association: The Oceans Without Plastics Association works in the area of environmental conservation, as a response to the growing problem of pollution, and in education and awareness-raising. In its last project it removed more than 4 tons of rubbish from natural areas. They bet on a future where nature is not only a priority, but also a fundamental part of life.

• Contribution: ActivoBank donated 2000 euros to help the Oceans Without Plastics Association environmental conservation actions.

November – No Bully

• On the Association: No Bully is a non-profit association, founded in 2016 to prevent, stop and solve (cyber)bullying in Portugal, through Empathy and Kindness.

• Contribution: ActivoBank donated 2000 euros to help No Bully in its mission to fight bullying.

December – Associação Nacional de Cuidadores Informais

• On the Association: The mission of the Associação Nacional de Cuidadores Informais is to defend the interests of informal caregivers and democratic activity for the definition and implementation of public policies, namely the Statute of the Informal Caregiver, and called on policy makers to fight for the dignity of informal caregivers so that the status of the informal caregiver could become a reality.

• Contribution: ActivoBank donated 2000 euros to support the mission of defending the interests of the Informal Caregivers.

Besides the monthly support given to the social causes, previously mentioned, the Bank established two long term partnerships, in 2022/2023. In the Oceans Protection cause with Ocean Alive and in the Cyberbullying fight cause with No Bully Portugal. These partnerships are in line with the Bank's new Sponsorship policy, which is 100% focused on sustainability-related causes.

Protection of Marine Prairies and Partnership with Ocean Alive

The support to this cause arose because ActivoBank has always had a special connection with the theme of the Oceans and by having this desire to have an active contribution to a cause of protection of the Oceans, it reached the Marine Prairies, which are marine ecosystems with a very important role in the Planet, for being carbon sinks and habitat to several species of fish, crustaceans and bivalves. From here arose the association with Ocean Alive, which is the first cooperative in Portugal dedicated to the protection of Marine Prairies.

This partnership of ActivoBank in the environmental area will run during 2022 and 2023 and supports the preservation of the Ferry Base Marine Prairie, in Tróia, contributing to the achievement of two objectives: create scientific knowledge to support the prairie restoration actions; and encourage good practices in the vessels' behaviour.

So far, with the contribution of the ActivoBank donation the whole prairie has been mapped, which allowed us to conclude what is the state of degradation of each of the Prairie areas, as well as to catalogue the species of seagrass and some of the animal species that constitute this habitat. This work will now allow the design of the plan to restore the Prairie, which will be put into practice during 2023.

In 2022, two volunteering activities were carried out, which allowed to involve Customers and Employees of ActivoBank, in

one of the goals of this project - the awareness of the local community about the importance of Marine Prairies and the care to be taken in the preservation of these habitats.

The volunteering actions, which took place in the last two weekends of August, totaled 32 hours of activity in the field and involved 20 volunteers, among Customers and Employees of the Bank.

In addition to volunteering activities, ActivoBank played an important role in the dissemination of the Marine Prairies Protection and Ocean Alive cause, since it published content on its social networks pages - Instagram, LinkedIn, Facebook and Youtube, on a monthly basis, about the partnership.

Cyberbullying and No Bully Portugal

During the involvement of ActivoBank Employees in the causes to be supported by the Bank, an internal vote was held on the new cause to be supported and thus was chosen the Cyberbullying cause to be supported by the Bank in 2022/2023.

In order to broaden the spectrum of support to the cause, a partner Association was chosen, in this case, No Bully Portugal, which for several years has been developing a very relevant work in the area of fighting Cyberbullying and Bullying in Portugal.

During the course of this partnership three activities have already taken place - training for all Employees, a digital awareness campaign and various awareness-raising contents on the brand's social media pages - Instagram, Facebook, LinkedIn and Youtube.

The training activity for Employees also has a component of proximity and direct support in helping those who are directly or indirectly involved in cases of Cyberbullying, since Employees at the Bank's branches have a badge and a badge for the cause with the slogan "Say no to Cyberbullying" on it, so that anyone who is experiencing or knows someone who is experiencing Cyberbullying can easily identify that they can ask one of our Employees for help. This help is done by forwarding cases to No Bully Portugal, which has specialists ready to help in these cases.

activobank
activobank Encontre mais informação no site e página da
@nobullyportugal e junte-se a nos na luta contra o
cyberbullying. ♥
Informe-se em www.activobank.pt
Banco ActivoBank, S.A.
6 d
nobullyportugal Vamos parar o cyberbullying! Obrigada
ActivoBank!
6 d 2 gostos Responder
··············································································································································································
1 em cada 3 crianças
afirma ter sido vítima
Ver estatísticas
de cyberbullying.
Fonte: UNICEF Portugal
AB
NO BULLY
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Prizes and awards

The International Women's Day Campaign on Social Media alerted to gender inequality, giving some emphasis to the difference in opportunities and the demands of society's standards between genders. It was awarded bronze recognition in 2022 at the Lusophone Awards in the Press and Social Media categories.

The "Sounds" campaign that we launched during the Bank's support for the Cyberbullying cause won an unprecedented three prizes at the Lusophone Creativity Awards: Bronze for low budget film, Silver for Digital Film and Gold for Social Responsibility Campaign on Social Networks.

Communication

One of the social inclusion initiatives promoted by ActivoBank, in 2022, was the integration of sign language translation in the webcast "Conversas Activo", a measure that fits the Bank's growing concern in becoming a "Bank for all".

Besides the previously mentioned award-winning posts, ActivoBank had an important role of social activism, throughout 2022, through publications that marked ephemerides related to structuring causes for society:

  • International Day of Women's Equality
  • Deaf Education Day
  • Day for the Fight against homophobia, transphobia and biphobia

Sustainability Indexes

Recognition - Sustainability Indexes

Material issue:

BANK'S REPUTATION

In 2022, the BCP Group was listed in several Sustainability indexes.

In order to promote transparency in the communication with our Stakeholders, monitor the evolution of performance, identifying opportunities for improvement, and communicate the evaluation carried out by recognised external entities, we respond to various specialised indices.

In Portugal, as a result of the assessment made by the analyst Standard Ethics, Brupo BCP is part of the "European Banks Index", having also integrated the "Europe's Climate Leaders 2022" ranking of the Financial Times and Statista as one of the European companies with the greatest progress in the reduction of GHG emissions and the "EURO STOXX Total Market ESG-X", "STOXX® Developed Markets Total Market ESG-X" and "STOXX Europe Total Market ESG-X" indices.

In its most recent ratings, the analyst Sustainalytics attributes a score of 21.6 to the BCP Group's ESG performance, while the MCSI gives it an "A" rating and the S&P DJSI 62%. Gaia Rating gives it a 70% rating, Refinitiv a 78% rating and Vigeo Eiris an overall 46% rating (reaching 88% in assessing the quality and comprehensiveness of reporting practices).

In Poland, Bank Millennium was once again included in the Warsaw Stock Exchange's "WIG-ESG" index, in recognition of the work developed within the environmental, social, economic and corporate governance dimensions.

In the 2022 edition of the CDP - Carbon Disclosure Project, the BCP Group remained, as in 2021, in the "Management" band, with a "B" rating, after having been in the "Leadership" band in 2020 and obtained an "A-" rating.

Also in 2022, BCP Group saw its presence confirmed in "The Sustainability Yearbook", a benchmark publication in the area of Sustainability now edited by S&P based on the information gathered from the responses of companies to the 2021 edition of the "Dow Jones Sustainability Indices".

BCP Group, already in 2023, was included for the fourth consecutive time in the Bloomberg Gender-Equality Index, reaching its best global score to date with a score of 85.34%, up from 80.76% in 2022, 78.11% in 2021 and 77.79% in 2020, remaining in the group of companies that worldwide stand out in the implementation of gender equality, diversity and inclusion practices and policies.

Index/analyst 2022 2021
MSCI (*) A = A
S&P DJSI 62% 64%
Carbon Disclosure Project B = B
Bloomberg Gender-Equality Index 85% 81%
Vigeo Eiris 46% (88% disclosure) 49% (88%)
Gaïa Rating 70% 66%
Refinitiv 78% 76%
Sustainalytics 21.6 32.9

(*) The use by Banco Comercial Português of any MSCI ESG research LLC or its affiliates ("MSCI") data, and the use of MSCI logos, trademarks, service marks or index names herein, do not constitute a sponsorship, endorsement, recommendation, or promotion of Banco Comercial Português by MSCI. MSCI services and data are the property of MSCI or its information providers, and are provided 'as-is' and without warranty. MSCI names and logos are trademarks or service marks of MSCI.

ESG bonds

Allocation and Impact Report

Social Bonds Report

1. GREEN, SOCIAL AND SUSTAINABILITY BOND FRAMEWORK 177
2. MILLENNIUM BCP INAUGURAL SOCIAL BOND 181
2.1
SUMMARY OF THE TRANSACTION'S FEATURES 181
2.2
ALLOCATION ……………………………………………………………………………………………………………………………………………………. 182
2.2.1
Allocation Report 182
2.2.2
Allocation Report – External Verification
184
2.3
IMPACT…………………………………………………………………………………………………………………………………………………………………185
2.3.1
Impact Report ……………………………………………………………………………………………………………….185
3. DISCLAIMER 186

Green, Social and Sustainability Bond Framework

In 2021, Banco Comercial Português, S.A. ("BCP", "Millennium bcp" or "Bank") established its Green, Social and Sustainability Bond Framework ("Framework").

The Framework is aligned with the four principles defined by the International Capital Markets Association ("ICMA") for this type of bond issuance as presented summarized below and relies on relevant eligibility criteria for operations to be financed or refinanced in the Green and Social categories. The Framework also aims to contribute to the achievement of the United Nations Sustainable Development Goals ("SDGs").

Millennium bcp's Framework has the objective to ensure transparency and quality of BCP's Green, Social and Sustainability Bond issuance ("ESG Bonds"). It has been designed in accordance with the four core components of the Green Bond Principles (2018), Social Bond Principles (2020) and Sustainability Bond Guidelines (2018) published by the ICMA3 ("ICMA Principles"):

    1. Use of Proceeds;
    1. Process for Project Evaluation and Selection;
    1. Management of Proceeds;
    1. Reporting.

With these instruments, the Bank can access to one of the most important segments of the capital markets and make possible to significantly reinforce the commitments and efforts it makes in terms of sustainability. In fact, this is an important tool to further integrate ESG matters within the Bank's offer of financial products and services, envisaging the financing of a more sustainable society as a whole. The Framework allows Millennium bcp to issue Green, Social and Sustainability Bonds under different instruments (from Additional Tier I to senior preferred debt, also including secured and asset-backed notes).

The Framework follows market's best practices and was validated through a Second-Party Opinion ("SPO"), issued by Sustainalytics, B.V. According to the SPO, the Framework is robust and able to make an impact and follows the ICMA Principles.

As a result, the defined eligibility criteria and the expected impacts that are expected to lead to important and positive environmental and social effects, within the scope of the various sustainable development objectives pursued by the United Nations, namely the SDG 2, 3, 4, 6, 7, 8, 9, 10, 11 and 12.

Under the Framework, Millennium bcp committed to release publicly on annual basis, until full allocation of each ESG Bond issuance, an:

  • Allocation Report that explains how the proceeds from each bond are used. An external audit of the allocation process will be conducted to validate compliance with the principles established in the Framework;
  • Impact Report on the environmental and/ or social benefits of the bond issued.

The proceeds of any Millennium bcp issued under the Framework will be allocated exclusively to the Eligible Assets as defined in the following list of Eligible Green or Social Categories, aligned to the ICMA Principles.

15 ICMA's https://www.icmagroup.org/green-social-and-sustainability-bonds/

Eligible Green Assets
-- ----------------------- --
Green Eligible
Category
Eligibility criteria Supported
SDG
Renewable En
ergy
Loans or investments to finance the production4
, acquisition, operation, distribution
of renewable energy5
in line with the following threshold:

Facilities operating at life cycle emissions lower than 100gCO2e/kWh declin
ing to 0gCO2e/kWh by 2050
Green Buildings Loans to finance new or existing construction of residential and commercial buildings
as follows:

Residential buildings with energy performance belonging to the top 15% of
the most efficient buildings in Portugal or Energy Performance Certificate
(EPC) levels A and A +6

Commercial buildings with one of the following certifications or equivalent:
o
LEED Gold
o
BREEAM Very Good
o
HQE Excellent certification

Renovation of residential and commercial buildings achieving a minimum
30% reduction in energy consumption
Energy Effi
ciency
Loans to finance energy efficiency improvement projects such as:

District Heating/Cooling Distribution: using at least 50% renewable energy

Renewable energy co-generation projects

Energy storage systems7
Sustainable
mobility
Loans to finance low carbon transportation solutions and related infrastructures in
cluding but not limited to:

Public transport (e.g. trains, subways, trams, electric, biofuel and hybrid
buses8 as well as non-fossil fuel boats)

Private vehicles (e.g. electric, hybrid9 biofuel and hydrogen vehicles, bicy
cles)

Construction, improvement, maintenance and extension of related infra
structure (e.g. stations upgrade, railway networks, signalling, charging sta
tions, bicycle paths)
Circular econ
omy
Loans to finance circular economy projects including:

Procurement based on recycled materials such as paper, plastic as well as
certified forest products (FSC, PEFC or equivalent) and bio-based materials
(e.g. Roundtable on Sustainable Biomaterials)

Waste recycling with the goal of maximizing resource recovery

4 For projects financed under the Special Regime Electricity production, Millennium bcp will apply a prorata approach in order to solely take into account projects that are aligned with the eligibility criteria defined in the Framework. The reporting will specify the share of financing allocated to these projects.

5 For Hydropower, Millennium bcp to conduct or ensure that a social and environmental risk assessment by a specialized external body has been made and that there is no significant controversy surrounding the project. Biomass projects with waste as feedstock.

6 The definition of the top 15% of the most carbon efficient buildings may vary over time on the basis of the energy performance of existing building stock. As such Eligible EPC levels may also evolve in the future.

7 Excluding power-to-gas project

8 Hybrid buses with an emission threshold of <50gCO2/p-km

9 Hybrid passenger vehicles with an emission threshold of <75gCO2/km

Sustainable
water and
waste
management
Loans to finance the acquisition, development, operation and maintenance of sustain
able water and waste management projects such as:

Energy-efficient water distribution systems and/or quality improvement10

Waste management activities: non-hazardous waste and bio-waste11 collec
tion12
Sustainable ag
riculture
Loans to finance sustainable agriculture and management of natural resources:

EU Organic certification

Certified forests (FSC, PEFC or equivalent)

Eligible Social Assets

Social Eligible
Category
Eligibility criteria Supported
SDG
COVID-19 recov
ery
Loans to finance liquidity needs or expenditures from SMEs affected by the economic
downturn triggered by the COVID-19 crisis.
Target population: general population impacted by the COVID-19 crisis
Microcredit fi
nancing
Loans to finance microfinance institutions (MFIs) and entrepreneurs with the goal of
fostering stable employment creation and preservation.
Target population: unemployed, migrants and/or displaced persons, aging popula
tions, underserved women owing to a lack of traditional means of finance, low-in
come students and other vulnerable youth
MSMEs financing Loans to finance Micro, Small and Medium-sized Enterprises13 in underprivileged re
gions14
Target population: MSMEs in underprivileged regions where both the overall Re
gional Development Composite Index ("ISDR") and the cohesion index ("ISDR cohe
sion") scores are inferior to 100 (Overall ISDR <100 and ISDR cohesion <100)

10 Average energy consumption of the system is less than 0.5 kWh per m3 of water delivered II) Improvements to increase energy efficiency by at least 20%

11 The bio-waste is source segregated and collected separately; in dedicated bio-waste treatment plants, bio-waste shall constitute a major share of the input feedstock (at least 70%, measured in weight, as an annual average). Co-digestion is eligible only with a minor share (up to 30% of the input feedstock) of advanced bioenergy feedstock listed in Annex IX of Directive (EU) 2018/2001.

12 At least 50%, in terms of weight, of the processed separately collected non-hazardous waste is converted into secondary raw materials

13 Aligned with the MSME definition by the European Commission: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32003H0361

14 Indice sintético de desenvolvimento regional (ISDR), the Regional Development Composite Indicator was built by the Portuguese National Statistics Institute in partnership with DPP (a body from the Ministry of Environment, Physical Planning and Regional Development)

Access to es
sential services:
healthcare
Financing the construction, extension, equipment and operation of healthcare related
facilities:

Public hospitals, clinics, and healthcare centers providing free of charge or
subsidized medical care

Research and development on antiviral drugs and/or vaccines as well as the
manufacturing and acquisition of relevant medicines and medical equipment
in the context of health pandemics
Target population: each and every person in need of medical care, including the most
vulnerable
Access to es
sential services:
education
Loans to finance primary, secondary schools and vocational training infrastructures
and equipment:

Construction, renovation, extension of educational buildings and facilities

Furniture and additional equipment
Target population: underprivileged regions as defined above
Socioeconomic
advancement
and
empowerment
Loans to finance social welfare structures:

Social welfare bodies benefiting underprivileged groups such as defined be
low
Target population: unemployed, persons with disabilities, vulnerable youth and el
derly

For the avoidance of doubt, sectors such as, but not limited to nuclear, mining, alcohol, tobacco, gambling and dedicated to fossil fuels are excluded from both Green and Social eligible categories.

with the goal of assessing territorial impact of public policies. The index also serves as a tool for numerous actors with an interest in territorial matters.

The ISDR is based on a multidimensional approach to regional development encompassing three major components: competitiveness, cohesion and environmental quality. The composite indicators are referenced to the national average which is equal to 100 (Portugal = 100).

Millennium bcp Inaugural Social Bond

2.1. Summary of the transaction's features

In October 2021, Millennium bcp successfully executed its first ESG Bond, through the issuance of a Social Senior Preferred Bond, the first, exclusively of this category, launched by a Portuguese bank. For the future, and subject to market conditions, BCP intends to continue to incorporate the issuance of ESG Bonds in its Funding Plan, namely regarding Senior Preferred debt.

Issuer: 6.5nc5.5 Social Senior Preferred Notes
Banco Comercial Português, S.A.
ISIN: PTBCPEOM0069
Ratings at issuance: Ba1 (Moody's) BB (Fitch) /BBB(L) (DBRS)
Amount: € 500M
Issue Date: 7 October 2021
Maturity Date: 7 April 2028
Call option: 7 April 2027 (one time call) subject to the prior approval of the Relevant Authority
Coupon: 1.75% p.a., Mid-Swap +2.00% p.a., until the Optional Redemption Date, then 3m Euribor
+ 2.00% until the Maturity Date
Use of Proceeds: An amount equivalent to the net proceeds of the Notes will be used for to finance and/
or refinance Eligible Social Assets as defined in the Issuer's Green, Social and Sustaina
bility Framework which is available in addition to the second party opinion on the web
site of the Issuer.
Listing: Euronext Dublin

Breakdown by Investor and Geography

The final orderbook demonstrated a strong engagement from European investors, a significant part of them being asset managers dedicated to investing in ESG Bonds.

2.2. Allocation

According to Millennium bcp' ESG Framework, the Bank may use the proceeds of its issuances in financing or refinancing Eligible Green and Social Assets in the Portfolio. This allows the Bank to align its funding requirements with its ESG strategy and supporting the accomplishment of the main SDG priorities. Within its ESG strategy the Bank offers various financial products and services that incorporate social principles and respect for the environment and nature.

Millennium bcp commits to make and keep readily available reporting on the allocation of net proceeds to the Eligible Assets after a year from the issuance of the applicable Bond.

Allocation Report

During the pandemic crisis, the Bank developed several initiatives with emphasis to:

  • a €4,7B in support lines to families and businesses;
  • maintaining full activity even during lockdowns;
  • providing essential financial services, while ensuring safety of its Employees and Customers;
  • support measures to Portugal's public health system;
  • food aid and safety supplies to institutions;
  • anticipation of invoice payment to suppliers; and
  • joining national initiative to support culture.

In this context and more specifically, BCP fully allocated its inaugural Social Bond issue of €500M to refinance a portion of the portfolio of loans granted by the Bank to support the economy during the pandemic ("Covid-19 Lines").

An amount just over €500M of this type of loans with an average maturity of 3,5 at Year End15, was selected to account for natural and early amortizations that may occur during the life of the Bond.

15 Average Maturity is calculated as the remaining term to maturity, weighted by the outstanding amount of the loan.

Social Bond Funding ISIN Issuance Date Amount
6,5nc5.5 Social Senior Preferred Notes PTBCPEOM0069 07 oct 2021 500 000 000 €
Total Social Bonds Issued 500 000 000 €
Social Eligible Category 07 Oct 2021 31 Dec 2022
COVID-19 RECOVERY Number of Loans 5 891 5 615
Supported SDGs Amount of Refinanced Loans 789 267 267 € 616 509 804 €
Average Amount 133 978 € 109 797 €
Average Maturity 4,7 3,5
Total Amount of Refinanced Loans 616 509 804 €
Allocation Amount
Total Social Bonds Allocated 500 000 000 €
Total Unallocated Bonds Amount 0 €

2.2.2 Allocation Report - External Verification

-

-

2.3. Impact

On an annual basis, Millennium bcp commits to issue a report on the environmental and/or social benefits of the assets financed or refinanced by the issuance of ESG Bonds. Subject to data availability, this report should provide an aggregate estimate of impacts through the indicators defined in the Framework.

2.3.1 Impact Report

  • €616 mio of financing under "Covid-19 lines".
  • Above 5.500 companies supported.
  • Over 90.000 jobs impacted.16

The portfolio allocated to the Social Senior Preferred Bond includes a very diversified base of over 5,500 Millennium bcp Customers, mainly micro and small and medium-sized companies affected by the pandemic crisis. There is natural concentration in the regions of Lisbon and Oporto and in the sectors of manufacturing and wholesale & retail trade. This financial support was crucial for the Portuguese economy, as in a difficult time, it helped the beneficiary companies to maintain their activity, helping to generate but above all, to preserve jobs.

07 Oct 2021 Reference Date
31 Dec 2022
COVID-19 RECOVERY Volume of Loans Granted 789 267 267 € 616 509 804 €
Supported SDGs Number of Clients Supported 5 873 5 595
Number of Jobs Impacted 102 135 90 419

Industry Distribution (NACE) Geographic Distribution (Nuts III)

Disclaimer

To be inserted

16 Number of jobs corresponds to the number of workers reported by each customer. For those few cases where there was no information reported, it was assumed to be 1.

Methodological Notes

Environmental Indicators

GRI 301-1

The figures presented in 2022 include the operations in Portugal, Poland and Mozambique.

  • Consumption of paper and cardboard Total estimated based on the purchase of these materials and numbers in stock records. The weight of the paper units was found using standard paper measurements issued by the ISO 216 standard.
  • Plastic consumption Total estimated based on the purchase of these materials and numbers in stock records. The calculation of the amount of plastic used in bank cards was based on the number of cards issued for Customers and on the standard weight of a card.
  • Consumption of ink and toner cartridges Total estimated based on the purchase of these materials. In Portugal, the values reported include ink and toner cartridges used by the Bank through Xerox.

GRI 302-1

The figures presented in 2022 include the operations in Portugal and Poland.

  • Consumption of natural gas and liquid fuels Total estimated based on the purchase of these fuels. The LHV (Lower Heating Value) of the fuels used to compute energy is based on the Global Reporting Initiative, available at www.globalreporting.org, and APA (Portuguese agency for the environment), available at www.apambiente.pt.
  • Consumption of electricity Total estimated based on the electricity bills.

The conversion factors used were the following:

Energy - Fuel (source: GRI)
Lower Heating Value (LHV) Density
Natural Gas 0.03901 GJ/m3 -
LPG 46,00 Gj/ton
1.96 l/kg
Diesel 43,07 Gj/ton
0.835 ton/m3
Petrol 44,00 Gj/ton 0.748 ton/m3
3
Litres - M
1000 Litre = 1m3
-
Litres - TJ (litres/1000)43.070.843 Diesel
Litres - TJ (litres/1000)44.00.745
Petrol
Litres - TJ (litres/1000461.96)/1000
LPG
3
M
-Tj
((m3)*0.03844)/1000 Natural Gas
Electricity
1 kWh 3.60 MJ/kWh

GRI 303-3

The figures presented include the operations in Portugal and Poland. The total withdrawal of water in Portugal is calculated based on the assessment of the costs with water, using to estimate the water consumption in m3 the pre-defined average cost per unit of 4.93€/m3 , updated in 2021 to 5.08€/m3.

GRI 305-1 to 305-3

The figures presented include the operations in Portugal and Poland. The emission factors used were the following:

Portugal Factor – 2018 Factor – 2019 Factor – 2020 Factor – 2021 Factor – 2022
Energy and Total 0.22896 0.24854 0.19237 0.00000 0.00000
Heat - Without kgCO2/kWh kgCO2/kWh kgCO2/kWh kgCO2/kWh kgCO2/kWh
disaggregation Source: Total – EDP Source: Total – EDP Source: Total – EDP Source: Total – EDP Source: Total – EDP
(CO2/ kWh) Comercial Comercial Comercial Comercial Comercial
0.137 kgCO2/kWh
Location-based - - - - Source: APREN
Poland Factor – 2022 Source - 2022
Electricity Coal/peat (CO2/ kWh) 0.87422 kgCO2/kWh http://www.ghgprotocol.org/calculation
tools/all-tools (consumo em 2012)
Oil (CO2/ kWh) 0.48401 kgCO2/kWh http://www.ghgprotocol.org/calculation
tools/all-tools (consumo em 2012)
Gas (CO2/ kWh) 0.33734 kgCO2/kWh http://www.ghgprotocol.org/calculation
tools/all-tools (consumo em 2012)
Energy (CO2/ kWh) 0,00000KgCO2e/KWh
CO2: 169.1
Heat (CO2/ kWh) gCO2e/kWh DEFRA 2022
CH4: 1.1 gCO2e/kWh
N2O: 0.6 gCO2e/kWh
Location-based 0.70800 kgCO2/kWh Kobize

Emission factors - Fuel (source: UNL, EDP, IPPC)

CO2 69300.0 Kg/TJ
Petrol CH4 25.0 Kg/TJ
N2O
8.0 Kg/TJ
CO2 74100.0 Kg/TJ
Diesel CH4 3.9 Kg/TJ
N2O 3.9 Kg/TJ
CO2 63100.0 Kg/TJ
LPG CH4 62.0 Kg/TJ
N2O 0.2 Kg/TJ
CO2 56100.0 Kg/TJ
Natural Gas CH4 1.2 Kg/TJ
N2O 2.3 Kg/TJ

Emission Factors – Travels

Type of flight Distance (km) Emission factor Source
Short <500 0.18 kgCO2/kWh GHG Protocol
Plane Medium 500-1600 0.13 kgCO2/kWh GHG Protocol
Long >1600 0.11 kgCO2/kWh GHG Protocol
Radiative Forcing Index 1.9 GHG Protocol
Train 0.06 kgCO2/kWh GHG Protocol
Bus 0.19 kgCO2/kWh GHG Protocol

EXTERNAL AUDI-TOR'S REPORT:

-

-

-

Annexes

GRI table - Global Reporting Initiative

Information sources: AR – 2022 Annual Report SR – 2022 Sustainability Report Site – millenniumbcp.pt – Sustentabilidade

Declaration of use Banco Comercial Português S.A. reported in accordance with the GRI Standards for the period from
1 January 2022 to 31 December 2022.
GRI 1 used GRI 1: Foundation 2021
Applicable sector standard At the Report's publication date no sector standard applicable to the Bank was available.

General standard contents

Note: Whenever requirements from the indicators are omitted this is indicated in the table in the column 'Content, page or link'.

ORGANISATION AND REPORTING PRACTICES
22 SR Economic and Governance Responsibility
2-1
Organization details
Entities included in the or
2-2
ganization's sustainability
22 AR Regulatory information > Consolidated financial statements
report
22 SR Introduction > Sustainability Report
Reporting period, frequency
2-3
and contact point
22 SR Terms and Conditions
Reformulations of infor
2-4
22 SR Introduction > Sustainability Report
mation
Independent Report of Limited Assurance
2-5
External Verification
Corporate Governance Report > Section V - External Auditor
ACTIVITIES AND WORKERS
22 SR Summary of Indicators
22 SR Economic and Governance Responsibility > Products and Services
Activities, value chain and
22 SR Economic and Governance Responsibility > Suppliers
2-6
other business relationships
22 SR Introduction > Sustainability Report
22 SR Methodological Note
22 SR Summary of Indicators
2-7
Employees
22 SR Economic and Governance Responsibility > Employees
Workers who are not em
2-8
ployees
GOVERNANCE
GRI STANDARDS Content, page or link
its composition
Committees
2-9 Governance structure and Governance structure and its composition > Section II - Part B. Corporate bodies and
Appointment and selection
2-10
for the highest governance
Corporate Governance Report > Item 4 and 5
body
Chairperson of the highest
2-11
Corporate Governance Report > Item 4 and 5
governance body
Role played by the highest
2-12
22 SR Introduction > Governance Model
governance body
The Bank's Executive Committee is responsible for managing impacts within the scope of
Delegation of impact re
2-13
the Bank's day-to-day management and their monitoring is carried out by the Committee
sponsibility
for Corporate Governance, Ethics and Sustainability.
GRI STANDARDS Content, page or link UNGC princi
ples
With the objective of promoting better articulation of current management decisions, in
volving the top management of the units integrated in each of the Business Areas, regard
ing Sustainability issues, the Executive Committee appointed a Sustainability Committee
whose mission is to define and monitor initiatives that will ensure the execution of the
Sustainability Master Plan (SMP), in its strategic axes (Environmental, Social and Govern
ance), in accordance with the guidelines of the Plan approved by the Executive Commit
tee. This Committee needs a minimum quorum for decision of at least two directors.
2-14 Role played by the highest
governance body in Sustain
ability Reporting
22 SR Introduction > Governance Model
The Bank has a Code of Conduct of the BCP Group that imperatively establishes that the
members of the management and supervisory bodies, as well as the employees, must
avoid any situation susceptible of giving rise to conflicts of interest with their functions,
so that they can act with full independence of mind, impartiality and exemption and that
the members of the management and supervisory bodies cannot intervene in the appre
ciation and decision of operations, professional situation of employees and procedures of
acquisition of goods and services in which there is the risk of occurrence of conflicts of in
terest.
2-15 Conflicts of interest Additionally, the Bank also has a Policy for the Prevention and Management of Conflicts
of Interest (Group Code GR0038), which defines the fundamental principles and pro
cesses adopted for the identification and management of conflicts of interest occurring
within the Group. GR0038 also formalises the governance principles applicable to the pro
vision of investment and ancillary services and activities identified.
The Bank's Articles of Association establish that the Board of Directors appoints a special
ised Committee, called the Committee for Corporate Governance, Ethics and Sustainabil
ity, to which it attributes, among others, the power to assess the systems for identifica
tion and resolution of conflicts of interests.
The Regulation of the Board of Directors states in article 8 that directors, in the exercise
of their functions, have the duty to avoid situations that may give rise to conflicts of inter
est.
III. Economic and Governance Responsibility > Ethics and Professional Conduct
2-16 Communication of critical
concerns
Critical concerns are reported to the Committee for Corporate Governance, Ethics and
Sustainability, which has the powers delegated to it by the Board of Directors (as pre
sented in the sub-chapter on Governance Model).
2-17 Collective knowledge of the
highest governance body
22 SR Introduction > Governance Model
2-18 Performance assessment of
the highest governance
body
Corporate Governance Report
2-19 Remuneration Policies Corporate Governance Report > Section III - Part D. Remunerations
2-20 Process for determining re
muneration
Corporate Governance Report > Section III - Part D. Remunerations
Portugal:
The net annual total remuneration ratio recorded in 2022 was 19.
2-21 Annual total remuneration
ratio
The ratio between the percentage increase in the net annual total remuneration of the
highest paid individual in the organisation and the average percentage increase in the net
annual total remuneration of all employees (excluding the highest paid individual) rec
orded was 2.5.
Notes: (i) The ratios presented were calculated based on the fixed and variable amounts paid, less the
applicable tax burden and mandatory contributions, to the organization's best-paid individual and to
all the organization's employees; (ii) the total annual remuneration of the highest paid individual in the
organization does not include amounts not attributable to the 2022 financial year, namely the variable
remuneration referring to 2019 and long-term variable remuneration relating to the period 2018-
2021, paid in 2022. More information in the Corporate Governance Report.
Poland:
The annual total remuneration ratio recorded in 2022 was 37.79.
The ratio between the percentage increase in the net annual remuneration of the highest
paid individual in the organisation and the average percentage increase in the net annual
total remuneration of all employees (excluding the highest paid individual) recorded was
0.29.
Mozambique:
GRI STANDARDS Content, page or link UNGC princi
ples
14. The annual total remuneration ratio recorded in 2022 was 49.
The ratio between the percentage increase in the annual total remuneration of the high
est paid individual in the organisation and the average percentage increase in the annual
total remuneration of all employees (excluding the highest paid individual) recorded was
STRATEGY, POLICIES AND PRACTICES
2-22 Declaration on sustainable
development strategy
the Executive Committee 22 SR Joint Message from the Chairman of the Board of Directors and the Chairman of
2-23 Policies 22 SR Introduction > Governance Model
Information regarding Policies and Commitments is available on the corporate website:
https://ind.millenniumbcp.pt/pt/Institucional/governacao/Pages/normas_regulamen
tos.aspx
2-24 Incorporation of Policies Information regarding Policies and Commitments and how these are incorporated in the
Bank is available on the corporate website: https://ind.millenniumbcp.pt/pt/Instituci
onal/governacao/Pages/normas_regulamentos.aspx
2-25 Processes to remedy nega
tive impacts
22 SR Introduction > Management of Social and Environmental Risks
2-26 Mechanisms for advice and
22 SR Introduction > Ethics and Professional Conduct
raising concerns
tions Total no. of significant cases of non-compliance with laws and regula 10
for which fines were applied No. of significant cases of non-compliance with laws and regulations 4
2-27 Compliance with laws and
regulations
No. of significant cases of non-compliance with laws and regulations in
6
which non-monetary sanctions were applied
Monetary value of fines imposed in significant cases of non-compli
1,110,000
ance with laws and regulations
Monetary value of fines that occurred in the reporting period
Monetary value of fines that were paid in the reporting period
1,110,000
0
2-28 Information on the Associations to which the Bank belongs is available on the corporate
Participation in Associations
website: https://ind.millenniumbcp.pt/pt/Institucional/sustentabilidade/Pages/co
munid_externa.aspx
STAKEHOLDER ENGAGEMENT
2-29 Stakeholder engagement
approach
www.millenniumbcp.pt
22 SR Relation with Stakeholders
Institutional > Sustainability > Stakeholders management
2-30 Collective negotiation agree
22 SR Summary of Indicators
ments
MATERIAL ISSUES
3-1 Process of defining material issues 22 SR Relation with stakeholders > Stakeholders engagement
and Materiality analysis
3-2 List of material issues 22 SR Relation with stakeholders > Stakeholders engagement
and Materiality analysis
3-3 Management of material issues: Cyber-security,
privacy and information protection
22 SR Economic and Governance Responsibility > Information
Security
3-3 Management of material issues: Innovation and
digitalisation
22 SR Economic and Governance Responsibility > Innovation
3-3 Management of material issues: Ethics, conduct
and compliance
22 SR Economic and Governance Responsibility > Ethics and
Professional Conduct
3-3 Management of material issues: Prevention of
corruption and money laundering
22 SR Economic and Governance Responsibility > Ethics and
Professional Conduct
GRI STANDARDS
Content, page or link
UNGC princi
ples
3-3 Management of material issues: Transparency
of the information provided to customers about
products and services
22 SR Economic and Governance Responsibility > Products
and Services
3-3 Management of material issues: Sustainability
Governance
22 SR Introduction > Governance Model
3-3 Management of material issues: Resilience of
the business model
22 SR Value Creation
22 SR Relation with Stakeholders > SMP - Sustainability Mas
ter Plan 2022
3-3 Management of material issues: Risk manage
ment
22 SR Introduction > Management of Social and Environmen
tal Risks
3-3 Management of material issues: Satisfaction and
customer experience
22 SR Economic and Governance Responsibility > Quality Ser
vices
3-3 Management of material issues: Management of
the brand and reputation
22 SR Table of Contents and Sustainability Recognitions
3-3 Management of material issues: Economic per
formance
22 AR Consolidated financial statements
3-3 Management of material issues: Attracting, de
veloping and retaining talent
22 SR Economic and Governance Responsibility > Employees
GRI STANDARDS Contents, page or link UNGC Principles
CATEGORY: ECONOMIC
ECONOMIC PERFORMANCE
201-1 Direct economic value generated
and distributed
22 AR Information on the BCP Group > Principal Indicators
22 AR Financial Information > Results and Balance Sheet > Analysis
201-2 Financial implications, risks and
opportunities due to
climate change
22 AR Environmental Responsibility > TCFD
https://www.cdp.net > Search responses > Banco Comercial Português SA
201-3 Benefit plans
defined by the organisation
AR 22 Post-employment benefits and other long-term benefits
MARKET PRESENCE
202-1 Ratio between the lowest wage and the
local minimum wage, by gender, in the
Important operational units
22 SR Summary of Indicators
6
Men Women Total
Proportion of employees
hired locally
No. of employees
hired locally
6,993 8,678 15,671
202-2 % of employees
hired locally
99.4% 99.7% 99.5%
No. of employees of the BoD,
EC and Senior Management
hired locally
134 41 175
% of employees of the BoD, EC
and Senior Management hired
locally
91.8% 93.2% 92.1%
INDIRECT ECONOMIC IMPACTS
203-1 Development and impact of
investments in infrastructure and ser
vices offered
22 SR Social Responsibility > Share and Participate
22 SR Social Responsibility > Financial Literacy
22 SR Social Responsibility > BCP Group Foundations
GRI STANDARDS Contents, page or link UNGC Principles
203-2 Significant indirect economic impacts,
including the extent of impacts
22 SR Social Responsibility > Share and Participate
22 SR Social Responsibility > Financial Literacy
22 SR Social Responsibility > BCP Group Foundations
PURCHASING PRACTICES
204-1 Proportion of expenses with local sup
pliers in important operational units
22 SR Summary of Indicators
22 SR Economic and Governance Responsibility > Suppliers
ANTI-CORRUPTION
205-2 Percentage of employees trained in the
anti-corruption policies and practices of
the organisation
22 SR Economic and Governance Responsibility > Employees > Training 10
205-3 Actions taken in response to corruption
cases
22 SR Economic and Governance Responsibility > Ethics and Profes
sional Conduct
10
TAXES
207-1 Tax approach 22 SR Economic and Governance Responsibility > Tax Policy
207-2 Governance. Tax risk control and man
agement
22 SR Economic and Governance Responsibility > Tax Policy
207-3 Stakeholder engagement and
managing their concerns on
tax
22 SR Economic and Governance Responsibility > Tax Policy
207-4 Report by geography 22 SR Economic and Governance Responsibility > Tax Policy
CATEGORY: ENVIRONMENTAL

MATERIALS

301-1 Materials consumption 22 SR Environmental Responsibility > Sustainable Operations 7, 8
ENERGY
302-1 Energy Consumption
within the organization
22 SR Environmental Responsibility > Sustainable Operations 7, 8
302-3 Energetic intensity 22 SR Environmental Responsibility > Sustainable Operations 8
302-4 Reduction of energy
consumption
22 SR Environmental Responsibility > Sustainable Operations 8, 9
WATER AND EFFLUENTS
A significant part of the water consumed at the BCP is associated with human use, with
part also being used for irrigation in the facilities. In 2022, all the water for irrigation of
the green spaces in Taguspark came from the borehole.
303-1 Interactions with water
as a shared resource
The Group is concerned about reducing its environmental impact, which includes re
ducing water consumption in all geographies where it operates.
BCP does not identify in its direct operation areas of water stress relevant to this re
port.
22 SR Environmental Responsibility > Sustainable Operations
303-2 Management of im
pacts related to water
discharge
The management of effluents in the Bank is carried out by third parties, and most of
the liquid effluents produced by the Group are rejected into public wastewater net
works and are subsequently subject to treatment and quality monitoring by the re
sponsible entities.
22 SR Environmental Responsibility > Sustainable Operations
303-3 Water withdrawal
22 SR Environmental Responsibility > Sustainable Operations
7, 8
BIODIVERSITY
304-1 Operational facilities (owned, leased
The Bank's operations do not have a significant direct impact on biodiversity,
or managed) in areas surrounding
protected or restored habitats, which justifies the irrelevance of this indica
protected areas and areas of high bi
odiversity value outside protected
tor.
areas
8
304-2 Significant impacts of activities,
products and services on biodiversity
The Bank's operations do not have a significant direct impact on biodiversity,
protected or restored habitats, which justifies the irrelevance of this indica
tor.
8
304-3 Protected or restored habitats The Bank's operations do not have a significant direct impact on biodiversity,
protected or restored habitats, which justifies the irrelevance of this indica
tor.
8
EMISSIONS
305-1 GGE direct emissions (Scope 1) 22 SR Environmental Responsibility > Sustainable Operations 7, 8
305-2 GGE indirect emissions (Scope 2) 22 SR Environmental Responsibility > Sustainable Operations 7, 8
305-3 Other GGE indirect emissions
(Scope 3)
22 SR Environmental Responsibility > Sustainable Operations 7, 8
305-4 Intensity of GGE emissions 22 SR Environmental Responsibility > Sustainable Operations 8
305-5 Reduction of GGE emissions 22 SR Environmental Responsibility > Sustainable Operations 8, 9
WASTE
306-1 Waste generation and significant
impacts related to waste
Waste production at BCP is mostly associated with office waste (paper,
cardboard and plastic). The Group is concerned about reducing its envi
ronmental impact, which includes reducing waste production in all geog
raphies where it operates.
22 SR Environmental Responsibility > Sustainable Operations
306-2 Management of significant impacts
related to waste
22 SR Environmental Responsibility > Sustainable Operations
306-3 Generated waste 22 SR Environmental Responsibility > Sustainable Operations 8

CATEGORY: SOCIAL

WORK

6

2022
<30
Recruit
Men
ment
Women Total
no. % no. % no. %
494 48% 729 48% 1 223 48%
[30-50[ 296 9% 424 8% 720 8%
New Hiring Rate, broken down by >=50 42 1% 30 2% 72 2%
Total 832 12% 1 183 14% 2 015 13%
401-1
Turnover rate, broken down by
gender and age group.
Depar Total
%
300 29% 444 29% 744 29%
[30-50[ 392 12% 756 14% 1 148 13%
148 5% 121 7% 269 6%
840 12% 1 321 15% 2 161 14%
gender and age group. tures
2022
<30
>=50
Total
no. Men
%
no. Women
%
no.

22 SR | Economic and Governance Responsibility > Employees > Evolution of the workforce

401-2 or part-time employees

or part-time) but are not extended to interns or outsourcers.

OCCUPATIONAL HEALTH AND SAFETY
Millennium bcp has published regulations establishing the general principles relating to the preven
tion of professional risks, protection of the safety, hygiene and physical and mental health of Em
ployees, regardless of the type of contractual relationship, whatever the facilities and workplaces
where they carry out their activity, and information, consultation, participation and training in this
field,
without
prejudice
to
the
legal
rules
applicable
in
this
field.
These rules are available for consultation on the Bank's internal portal.
403-1 Occupational health and
safety management sys
tem
The Occupational Health and Safety Management System was implemented in response to the
specific legislation in this area (Law No. 102/2009 of 10 September, amended by Law 3/2014 of 28
January, with updates introduced by Decree-Law No. 88/2015 of 28 May, Law No. 146/2015 of 9
September and Law No. 28/2016 of 23 August) but its scope, particularly in the area of health, goes
beyond the limits determined by law.
The Bank's Occupational Health and Safety Policy is updated regularly, and in 2022 incorporated
elements that reflect the reality of the Bank in Portugal and the applicable legal and regulatory
context, as well as good voluntary implementation practices.

With a view to ensuring adequate health surveillance of Employees, Millennium bcp carries out, according to each case, admission exams, periodic exams differentiated according to gender and age group - up to the age of 50 the periodicity is every two years and annual after that age - occasional and complementary exams, as well as activities to promote health at work, keeping organized the clinical records and other information elements relative to the health of each Employee. Following the check-up, a consultation is made with the Occupational Health Doctor where all information is provided on the Employee's state of health and the necessary recommendations are made.

Identification of dangerousness, risk assessment and investigation of incidents

403-2

In the area of safety, risk assessment audits are carried out, whose reports are forwarded to the Procurement and Logistics Division, which after analysis issues recommendations to the areas whose intervention is justified in order to resolve the recommendations made.

All Employees are made aware of the importance of looking after their own safety and health and that of others who may be affected by their actions or omissions at work, and of the need to immediately inform their employer of any work situation that presents a serious and immediate danger to safety or health, as well as any defect in the protection systems.

Periodically, drills are carried out in order to identify improvements to be introduced in emergency procedures. In 2022, 11 drills were carried out covering both Branches and Central Buildings.

403-3 Occupational health services In addition to the occupational medicine doctors referred to above, there is a team of cura
tive medicine doctors and nurses available every day at the Bank's premises in Taguspark and
a doctor and a nurse at the Bank's premises in Porto. The coordination of this team is made
by the physician performing the functions of Chief Medical Officer, who reports to the Hu
man Resources Division.
Since 2020, the Bank has 12 AED (Automatic External Defibrillation) devices distributed
throughout all central buildings, with six employees having been trained per device, with the
aim of enabling them to use a defibrillator, duly integrated in an AED Programme licensed by
the INEM.
The themes of occupational health and well-being are considered, at any moment, bearing in
mind the importance of providing a set of services able to help employees achieving a better
balance between the professorial life and the personal one. In this area, the bank provides:
Curative Medicine Services – the medical and nursing actions comprised within these ser
vices are provided, free of charge, to all Employees. The bank also provides services of collec
tion of samples for laboratory examination.
Nutrition and Psychology Appointments – Appointments also available due to the significant
role that the same may play in the health and well-being of the Employees, in the extent that
a personalised food plan is prescribed through strategies adjusted to the lifestyle of each em
ployee, allowing him/her to change and adopt healthy habits in a gradual manner. The Psy
chology appointments allow for the appropriate monitoring of Employees on mental health
issues, through the detection and follow-up of cases with this type of pathology.
Health Promotion Campaigns and Healthy Living Habits - a series of initiatives are carried out
to inform and raise awareness among Employees of the importance of adopting healthy liv
ing habits in their daily lives.
There is a Physiotherapy Centre in Taguspark, with an agreement signed with SAMS and with
Médis. Social Support and Benefits – by means of the definition of a policy of social benefits
and support, detailed on the internal website of the Human Resources, the Bank has been
seeking to foster support to the balancing of work-family, support to education and incentive
to mobility.
22 SR Social Responsibility > Employee Benefits > Health and Safety
403-4 Worker participation,
consultation
and communication to
workers
The carrying out of internal satisfaction surveys with the various services and the possibility of
making comments, allows the periodic monitoring of the opinion of the employees about the
quality of the services provided and is an opportunity to present suggestions for improvement.
------- -------------------------------------------------------------------------- ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Training of workers in occupa Training related to health, hygiene and safety at work in 2022 totalled 8,571 hours and covered
5,625 Employees. 42 Employees had specific training on first intervention fire-fighting resources.
403-5
tional health and safety
at work
In 2022, several news items were published on the internal portal under the title "Safe Minute"
where practical safety tips were shared with the aim of reminding employees how to deal with or
avoid potentially dangerous emergency situations.
403-6 Employees are called for check-ups in accordance with the rules established and already men
tioned. Following the check-up, they are subsequently called for the occupational health consulta
tion. All other consultations, curative medicine, psychology, nutrition, as well as clinical analyses,
are booked on the initiative of the Employee through contact with the Bank's medical services.
Physiotherapy sections are booked through direct contact with the service provider.
Worker health promotion Clinical information is recorded in an autonomous application, with restricted access, in order to
guarantee the confidentiality of all data.
The increasingly frequent publication on the internal portal of news about health care, diet and
healthy living habits reflects the intention to encourage the dissemination of information aimed at
promoting a healthier lifestyle with positive effects on physical, emotional and social wellbeing,
with repercussions on the balance between professional and personal life.
403-7 Prevention and mitigation of
health and safety impacts
directly linked
with business relationships
The Bank has organised an occupational health and safety service that is responsible for drafting
and updating the Occupational Health and Safety Plan, which includes the internal emergency plan,
the specific plans for firefighting, evacuation of premises and first aid, the occupational risk pre
vention plan, the development of health promotion activities and health surveillance examina
tions.
The external entity that supports the Bank in conducting audits of workplaces ensures the identi
fication of any anomaly that needs to be corrected in the reports it draws up.
22 SR Summary of Indicators
22 SR Social Responsibility > Employee Benefits > Health and Safety
2022
number of deaths 0
403-9 Work accidents number of accidents 53
Number of accidents at work with serious consequences 0
Total hours worked 28 606 216
Compulsory report of accidents at work 1.85
Rate of accidents at work with serious consequences 0
death rate 0
TRAINING AND EDUCATION
404-1 Average hours of training per year per
employee-by-employee category
22 SR Economic and Governance Responsibility > Employees > Training 6
404-2 Competence management and lifelong
learning programmes
22 SR Economic and Governance Responsibility > Employees > Training
404-3 Percentage of employees receiving reg
ular performance and career develop
ment reviews.
22 SR Economic and Governance Responsibility > Employees > Assess and recognize 6

DIVERSITY AND EQUAL OPPORTUNITIES

Composition of the corporate bodies
of the company and list of
employees by category,
22 SR Summary of Indicators
22 SR Economic and Governance Responsibility > Employees
405-1 according to gender, age group, mi
norities and other
diversity indicators.
Additionally, BCP identifies and reports its employees with disabilities.
In 2022, in Portugal, the Bank had 155 disabled people (68 men and 87 women) and in Poland
66 disabled people (19 men and 47 women).
6
Portugal Poland Mozambique
Base Sal
ary
(W/M)
Total re
muner
ation
(W/M)
Base
Salary
(W/M)
Total re
munera
tion
(W/M)
Base
Salary
(W/M)
Total re
muner
ation
(W/M)
405-2 Ratio of total remuneration between
men and women by employee cate
Senior Man
agement
1.00 0.97 0.88 0.81 n.a. n.a. 6
gory. Manage
ment
0.98 0.98 0.79 0.74 0.79 0.72
Commercial 0.86 0.80 0.94 0.89 0.94 0.89
Technicians 0.95 0.88 0.74 0.72 0.88 0.86
Others 0.93 0.91 0.90 0.88 1.11 0.98
NON-DISCRIMINATION
406-1 Discrimination cases and actions taken In 2022 there was no record of any reported case of discrimination. 6
FREEDOM OF ASSOCIATION AND NEGOTIATION
407-1 Operations and suppliers
identified as being at risk of
violation of the right to freedom
of association and collective
collective negotiation, and actions
taken
22 SR Economic and Governance Responsibility > Suppliers 3
CHILD LABOUR
408-1 Operations and suppliers
identified with a risk of child
child labour, and actions
taken
22 SR Economic and Governance Responsibility > Suppliers 5
LOCAL COMMUNITIES

22 SR | Economic and Governance Responsibility > Employees

LOCAL COMMUNITIES
413-1 Operations with programmes for
involvement of local communities
22 SR Social Responsibility > Share and Participate
22 SR Social Responsibility > Financial Literacy
22 SR Social Responsibility > Fundação Millennium bcp
22 SR Social Responsibility > Fundação Bank Millennium
1
FS13 Access in sparsely populated or economically dis
advantaged areas
22 SR Summary of Indicators
22 SR Economic and Governance Responsibility
FS14 Initiatives to improve access to financial services
for disadvantaged people
22 SR Summary of Indicators
22 SR Economic and Governance Responsibility
FS15 Policies for the fair design and sale of financial
products and services
22 SR Economic and Governance Responsibility > Ethics and Professional
Conduct > Policies for the fair design and sale of financial products and ser
vices
PUBLIC POLICIES
No contributions are made to political parties as required by law.
415-1 Political Contributions 22 SR Economic and Governance Responsibility > Ethics and Professional
Conduct
PRODUCT AND SERVICE LABELLING
417-1 Information on products and services required by
regulations, and the percentage of significant
products and services subject to such require
ments
22 SR Economic and Governance Responsibility > Ethics and Professional
Conduct
CUSTOMER PRIVACY
Complaints received from external parties and substanti
ated by the organisation
72
418-1 Complaints regarding breaches of customer pri
vacy and losses of customer data
Complaints from regulatory agencies
Total no. of substantiated complaints regarding breaches
7
79
of customer privacy
Total no. of customer data leaks, thefts or losses that
have been identified
43
SECTOR SUPPLEMENT
PRODUCT PORTFOLIO - MATERIAL ASPECT
FS6 Percentage of specific business lines/
specific business segment,
in total volume, by region and
size
22 AR Accounts and notes to consolidated accounts < Note 52 Consolidated Bal
ance Sheet and Income Statement Indicators by Geographical and Operating Seg
ments
FS7 (Monetary) volume of products and
and services with social benefit,
by business line
22 SR Economic and Governance Responsibility > Products and Services
22 SR Environmental Responsibility > Eco-friendly products and services offer
FS8 (Monetary) volume of products and
and services with environmental benefit,
by business line
22 SR Economic and Governance Responsibility > Products and Services
22 SR Environmental Responsibility > Eco-friendly products and services offer
AUDIT
FS10 Percentage and number of
companies included in the portfolio
with which it has interacted regarding social and
environmental aspects
22 SR Economic and Governance Responsibility > Products and Services
22 SR Environmental Responsibility > Eco-friendly products and services offer
FS11 Percentage of assets subject to
to environmental and social assessment
22 SR Economic and Governance Responsibility > Products and Services
22 SR Environmental Responsibility > Eco-friendly products and services offer

GRI - Global Reporting Initiative

Table SASB - Sustainability Accounting Standards Board

SASB – Commercial Banks Category /
measure unit
Content and location of the information Scope
DATA SECURITY
FN-CB-230a.1 (1) Number of
data violation,
(2)
percentage that
involved per
sonal identifica
tion information
(PII), (3) number
of affected ac
count holders
Number,
Percentage (%)
Number of data violation: 43
Percentage that involved personal identification information: 100%
Number of affected account holders: 387
Portugal
FN-CB-230a.2 Description of
the approach to
identify and
handle the data
safety
risks
n/a The regulatory context applicable to Portugal and Poland in terms of data secu
rity is similar, as both countries are covered by the rules emanating from the
General Data Protection Regulation (GDPR). In addition to the GDPR, applicable
to the geographies of Portugal and Poland, the Electronic Transactions Law, ap
proved in 2017, which provides legal provision for the protection of personal
data in Mozambique, also stands out.
More information on the Bank's Information Security policies and procedures
can be found in the 2022 Sustainability Report, Information Safety Chapter.
FINANCIAL INCLUSION AND CAPACITATION
Millennium bcp supported 9,759 projects for the development of small busi
nesses and communities (1), with a total loan of approximately 2,092 million
euros (2).
Projects No. of
projects
Amount (thousand €)
(1) Number and Invest + 22 952.08
(2) amount of
pending loans
qualified for
Linha Capitalizar Mais/SI
Inovação
89 40 523.89
programs con EIB Lines 178 323/948
FN-CB-240a.1 ceived to pro
mote the devel
Number, Currency ADN Lines 24 11 295 Portugal
opment of
small
Credit Lines with IFAP (IFAP Short
term and IFAP ML term)
198 15 972.53
companies and
the Community
Lines to Finance Tourism 35 12 428
EIF Lines 8941 1 593 349
Covid-19 Protocol Lines 73 44 779
Microinvest 41 515.91
Other Support Lines (OSI, Ma
deira, Azores)
158 48 998
SASB – Commercial Banks Category /
measure unit
Content and location of the information
More information on the number and amount of loans to businesses with so
cial and environmental benefits can be found in the 2022 Sustainability Report,
Capítulo de Products and Social and Environmental
Services.
FN-CB-240a.2 (1) Number and (2)
amount of past-due and
nonaccrual
loans qualified for pro
grams to
promote the
development of
small companies and
of the community
Number, Cur
rency
Information on past-due and nonaccrual loans is
reported in the 2022 Annual Report 2, Chapter Earnings and Balance
Sheet - Credit to Clients
FN-CB-240a.3 Number of current
accounts without costs
supplied to clients previ
ously without a bank or
accessing only some
basic banking
services
Number Within the scope of the inclusion of individual Clients (resident and non
resident) with low incomes in the financial system, the Bank was one of
the banking institutions that voluntarily provided the current account –
Minimum Banking Services–, without associated costs, this account can
be used with a debit card and through online banking. In 2022, 6,283
accounts were opened, presently accruing to 21,574 accounts.
In Portugal, within the scope of Entities that incorporate the social sec
tor, Millennium bcp keeps available the Non-Profit Association Account,
a current account with special conditions that does not require an open
ing minimum deposit and has no maintenance and overdraft fees. 338
accounts with these features were opened in 2022, corresponding to a
total of 5,145 accounts in the Bank's portfolio.
More information on the Bank's Information Security policies and proce
dures can be found in the 2022 Sustainability Report, Information Safety
Chapter.
Portugal
FN-CB-240a.4 Number of participants in
financial education initia
tives for clients without a
bank or having only ac
cess
to some basic
banking services
Number In 2022, Millennium bcp impacted more than 9.000 people through its
initiatives for the promotion of financial literacy.
More information on the number and amount of loans to small busi
nesses
and
with
social
and
environmental
benefits
can be found in the Sustainability Report 2022, Chapter Support to the
Community.
BCP Group
INCORPORATION OF ENVIRONMENTAL, SOCIAL AND GOVERNMENT FACTORS IN THE CREDIT ANALYSIS

FN-CB-410a.1 Exposure of commercial and industrial credit per sector Currency Information on loans and credits to clients, per sector is reported in the 2022 Annual Report 2, Chapter Earnings and Balance Sheet - Credit to Clients BCP Group

FN-CB-410a.2 Description of the
approach to incor
porate environ
mental, social and
governance fac
tors in (ESG) the
credit
analysis
n/a The BCP Group offers a complete and broad range of financial products and
services, and continues, under the development of its business lines, responsi
ble for offering an increasing number of products and services which incorpo
rate social principles and respect for the environment and nature. The access
to these products implies an assessment of the credit operation in the ESG
component. BCP Group is also aware that the implementation of social and
environmental criteria and standards in the commercial offer is reflected in
more efficient risk management, reputation value and higher quality of the
products and services offered to customers, meeting the needs and ambitions
of a market increasingly related with sustainability. In that sense, the Portu
guese operation introduced an ESG matrix in the internal risk classification for
larger companies.
More information on the approach for the incorporation of ESG risks in the
credit analysis can be found in the Market Discipline Report 2022, Chapter En
vironmental and Social Risks and in the Sustainability Report 2022, Chapter
TCFD.
Portugal
BUSINESS ETHICS
FN-CB-510a.1 Total amount of
monetary losses as a
result of legal pro
ceedings associated
with fraud, insider
trading,
antitrust, anticom
petitive behaviour,
market manipula
tion,
malpractice or
other laws or regula
tions of the financial
sector
Currency Information on legal and internal procedures associated with fraud, trad
ing with privileged information, anti-trust, anti-competitive behaviour,
market manipulation, malpractice can be found in the 2022 Sustainability
Report, Internal Audit Chapter.
Portugal
FN-CB-510a.2 Description of
the whistleblow
ing
policies and pro
cedures
n/a In Portugal, a Communication of Irregularities Policy (Whistleblowing) is
implemented, regulated by a specific Service Order.
In Poland and Mozambique, in accordance with the recommendations is
sued by the Bank in Portugal, equivalent policies were adopted, adjusted
to the reality of the respective countries.
More information on the Policy for the Communication of Irregularities
of the Bank is available here: Institutional/Governance/Bylaws and main
rules and regulations of the Bank/Whitewashing Policyades
BCP Group
MANAGEMENT OF SYSTEMIC RISK
Notation of the Global The BCP Group and the banks part of it are not considered Global Sys
temically Important Bank (G-SIB).
FN-CB-550a.1 Systemically Important
Bank (G-SIB), per
category
Basis points (bps) More information on the G-SIB (2022) available here: Financial
Stability Board (FSB) - 2022 List of Global Systemically Important Banks
(G-SIBs)
BCP Group

The ICAAP is a key process within the framework of the BCP Group's

FN-CB-000.B (1) Number and (2) value
of the loans per segment:
(a)
individual,
(b)
small companies and (c)
companies
(mortgage
loans as well as revolving
credit loans should be
excluded from the disclo
sure scope).
Number, Currency Information on Customer Funds can be found in
the Annual Report 2022, in Chapter Credit to Clients.
BCP Group
FN-CB-000.A (1) Number and (2) value
of the current and savings
accounts per segment: (a)
individual and (b) small
companies
Number, Currency Information on Customer Funds can be found in
the Annual Report 2022, in Chapter Customer Funds.
BCP Group
ACTIVITY METRICS
More information on incorporating stress test results into capital ade
quacy planning, long-term corporate strategy and other business ac
tivities can be found at 2022 Annual Report, Chapter Pensions Fund
Risks and in the 2022 Sustainability Report, Chapter TCFD.
FN-CB-550a.2 tory and voluntary stress
test results into capital ad
equacy
planning,
long
term corporate strategy
and
other
business
activities
n/a For this purpose, the ICAAP starts from a prospective view of the im
pacts of the materialization of the various risks on the Group's capital
(capital requirements), considering the respective scale or dimension,
complexity, frequency, probability of occurrence and materiality, hav
ing as a background the projected developments for the Group's activ
ity in a medium-term timeframe (3 years). Impacts are estimated un
der different scenarios, including stress scenarios with a severely pe
nalizing evolution of macroeconomic indicators. Through this process,
it is possible to test the Group's resilience, verifying that capital levels
are adequate to cover the risks to which its activities may be subject.
For this purpose, the different risks are modelled or incorporated into
the framework of the Group's stress test methodology.
BCP Group
Description of approach
for incorporating manda
The results of the ICAAP allow the management bodies to test whether
the Bank is adequately capitalized in view of the risks arising from its
current activity, as well as in relation to the risks inherent in the pro
jections of the balance sheet and results of the strategic plan and
budget, in order to ensure the sustainability of the Group in the me
dium term, with respect for the risk limits defined in the RAS (Risk Ap
petite Statement) approved by the Board of Directors.
risk management function and is developed under an internal govern
ance model that guarantees the involvement of the Board of Directors
(the body responsible for approving results) and its Committee for Risk
Assessment (CAvR), the EC and the Group's top management, in its
various stages.

Table UNPG - UN Guiding Principles Reporting Framework

PART A: GOVERNANCE OF RESPECT FOR HUMAN RIGHTS

A1

Policy of Commitment

What does the company say publicly about its commitment to respect human rights?

A1.1 In what way has been public commitment developed?

A1.2 From whom are the human rights approached in the public commitment?

A1.3 In what way is the public commitment disseminated?

The BCP Group assumes its commitment to the promotion of Human Rights through the Human Rights Policy, published in 2014 and revised, after an internal reflection process and evaluation of good practices, in 2021

Since 2005, it is also a member of the UN Global Compact, which includes Human Rights in its principles, and is also a subscriber to other initiatives that promote the adoption of best practices in this matter (see the Human Rights chapter).

The various commitments to Human Rights cover mainly, but not exclusively, all those who work with us, including employees, as well as suppliers and business partners, customers and the communities in which we operate, namely through the development of partnerships and initiatives that contribute to the promotion of human rights

A2.

Incorporating respect for human rights

How does the company show how important it is to implement its commitment to human rights?

A2.1 How is the daily responsibility for the performance of human rights organized within the company and why?

A2.2 What kind of human rights issues are discussed by top management and the Board, and why?

A2.3 How are employees and service providers made aware of how respect for human rights should be taken into account in their decisions and actions?

A2.4 How does the company make clear in its commercial relations the importance it attaches to respect for human rights?

A2.5 What lessons has the company learned during the reporting period on how to achieve respect for human rights and what has changed as a result of that learning?

The Committee for Corporate Governance, Ethics and Sustainability ( that depends from the Board of Directors) and the Commission for Human Resources and for Sustainability (that depend from the Executive Committee) are the governance bodies responsible for following-up the themes related with the protection and promotion of Human Rights.

With regard to raising awareness of the importance of the topic among the various stakeholders: i) internal training is promoted and content related to the topic is disseminated, aimed at employees and ii) the Guiding Principles of Sustainability are applied to suppliers.

In 2021, a self-assessment was carried out whose purpose was to identify, in the main geographies of the BCP Group (PT, PL and MZ), which areas related to Human Rights can benefit from incremental processes of evolution (see chapter Human Rights). In 2022, the self-assessment process was concluded and improvement plans, developed following the process, were implemented in the various countries.

PART B: DEFINE THE SCOPE OF REPORTING

B1.

Declaration of Relevant Themes

State the main human rights issues associated with the company's activities and business relationships during the reporting period.

The BCP Group, within the scope of its Human Rights Policy, establishes its commitment to the following themes:

  • Prohibition of forced labour, child labour and human trafficking;
  • Non-discrimination and prohibition of harassment;
  • Freedom of association and of collective bargaining;
  • Remuneration;
  • Relations with interested parties (employees and shareholders clients, suppliers and partners and the community).

The Policy of Human Rights establishes a set of themes deemed more relevant (see reply B1. Declaration of Relevant Topics), on which the self-assessment process carried out in 2021 and concluded in 2022 also focused. These themes were identified based on the main national and international references and regulations, such as the Universal Declaration of Human Rights or the Ruggie Framework and based on the best practices in the market.

B2.

Identification of Relevant Themes

Describe how key human rights issues were determined, including any input from stakeholders.

B3.

Choice of local geographies

If the report on key human rights topics focuses on specific geographies, explain how this choice was made.

B4.

Severe additional impacts

Identify any serious human rights impacts that occurred or were still being addressed during the reporting period, but which are outside the relevant human rights topics, and explain how they were addressed.

PART C: MANAGEMENT OF RELEVANT THEMES ON HUMAN RIGHTS

The information on Human Rights reported relates to the three countries where Group BCP operates: Portugal / Poland / Mozambique Whenever such does not happen, such fact is duly identified.

Through the various mechanisms implemented, or through other means, no severe impacts on Human Rights arising from the activity of the BCP Group were identified.

C1.
Specific Policies
Does the company have any specific pol
icy that addresses its most relevant hu
man
rights
issues?
If
yes,
which
one/which are they?
C1.1 How does the company convey the rel
evance and meaning of such policies to those
who must implement them?
The BCP Group has a Human Rights Policy that establishes the
approach to the most relevant topics and that covers a wide
range of stakeholders, duly identified in the document.
This document is available on the Bank's website and on the
company Intranet.
C2.
Involvement of
Stakeholders
What is the company's approach to
stakeholder engagement with respect
to each of its relevant human rights
themes?
C2.1 How are identified the stakeholders
whose involvement in each relevant human
rights themes the company should promote,
when and how to do it?
C2.2 During the reporting period, which
stakeholders whose involvement in relation
to each relevant human rights issue did the
company promote and why?
C2.3 During the reporting period, how did
stakeholder views influence the company's
understanding of each relevant issue and/or
what is its approach to addressing it?
Millennium bcp seeks to actively involve its stakeholders in the
development of its activity, including issues related to Human
Rights.
In addition to the current involvement practices (see chapter
Relationship with Stakeholders), all issues identified through
the various existing mechanisms for this purpose are subject
to analysis and subsequent implementation of improvements,
whenever this proves to be necessary and capable of adding
value.
C3.
Assessment of
Impacts
How does the company identify changes
in the nature of each relevant human
rights issue over time?
C3.1 During the reporting period, were there
any notable trends or patterns in impacts re
lated to a relevant issue, and if so, what were
they?
C3.2 During the reporting period, did any se
rious impacts related to a relevant issue oc
cur and, if so, what were they?
Millennium bcp guarantees the analysis and follow-up of all
issues related to Human Rights identified through the specific
and confidential internal communication channel. In addition,
all situations detected by or communicated to the internal
audit function are also evaluated. Are also considered the
situations identified through the Client Ombudsman.
The self-assessment process conducted during 2021 and
completed in 2022 also represents a potential source of
information for identifying changes in issues related to Human
Rights.
In 2022, no significant changes or serious impacts related to
Human Rights were identified.
C4.
Include findings
and implement
actions
How does the company integrate its
findings on each relevant human rights
issue into its decision-making process
and actions?
C4.1How can the parts of the company
whose decisions and actions may affect the
management of relevant issues be involved
in finding and implementing solutions?
C4.2 When tensions arise between prevent
ing or mitigating impacts related to a relevant
issue and other business objectives, how are
they handled?
C4.3 During the reporting period, what
measures did the company implement to
As mentioned in item C2. Involvement of Stakeholders, all
issues identified by stakeholders are subject to analysis and
originate actions for improvement and development of
solutions/resolution of identified problems, if applicable.
In 2022, improvement plans were implemented in the
geographies, based on the results of the self-assessment
carried out in 2021.

prevent or mitigate potential impacts related to each relevant issue?

C5. Follow-up performance

How does the company know if its efforts regarding each relevant human rights issue are effectively in practice?

C5.1 What specific examples from the reporting period illustrate whether each relevant issue is being managed effectively?

Millennium bcp has a wide range of Corporate Policies, available for public consultation on the website, which establish a set of guidelines and expected conduct for groups of Stakeholders and on different matters, which include the subject of Human Rights.

In addition, and through its Guiding Principles for Suppliers, Millennium ensures that suppliers follow a set of guidelines also related to Human Rights, and compliance with them can be verified by answering questionnaires or visiting places where the activity is carried out.

C6. Remediation

How does the company offer effective solutions to people who, through their actions and decisions, are harmed in terms of relevant human rights issues?

C6.1 How can the company receive complaints or concerns related to each relevant theme?

C6.2 How does the company know if people feel able and empowered to raise complaints or concerns?

C6.3 How does the company process complaints and evaluate the effectiveness of the results?

C6.4 During the reporting period, what were the trends and patterns of complaints or concerns and related results in relation to each relevant issue and what lessons learned?

C6.5 During the reporting period, did the company provide or facilitate the remediation of any actual impacts related to a material issue, and if so, what are typical or significant examples?

We encourage the reporting of actual or potential situations of violation of Human Rights (see the Human Rights chapter) through i) the specific and confidential internal communication channel for reporting violations established in the Code of Conduct and other internal regulations and ii) Client Ombudsman. Situations that are reported through other channels are also analysed and, whenever necessary, trigger improvement actions.

In 2022, there were no complaints or concerns expressed by any group of stakeholders in terms of Human Rights.

Table regarding the alignment with the recommendations from the TCFD - Task Force on Climate-Related Financial Disclosures

Pillar Recommendations Sources of Reference
Governance
How we manage the
climate-related risks and op
portunities
and opportunities
a) Describe Management's oversight of climate-related risks
and opportunities.
b) Describe management's role in assessing and managing
climate-related risks and opportunities.
• 2022 Sustainability Report > Environmental Re
sponsibility > TCFD
• CDP Climate Change 2022- C1 Governance
• 2022 Annual Report > Risk Management
Strategy
How we manage the
current and potential im
pacts of climate-related risks
and opportunities
a) Describe the climate-related risks and opportunities iden
tified by the Organization for the short, medium and long
term.
b) Describe the impact of climate-related risks and opportu
nities on the Organization's business, strategy and financial
planning.
c) Describe the resilience of the organization's strategy, tak
ing into account the different climate-related scenarios, in
cluding the 2ºC or lower scenario.
• 2022 Sustainability Report >
Environmental Responsibility > 2022 Sustaina
bility Master Plan - Environmental Action Plan
• 2022 Sustainability Report >
Environmental Responsibility > Sustainable
Operations
• 2022 Sustainability Report > Environmental Re
sponsibility > TCFD
• CDP Climate Change 2022- C2 Risk and
Opportunities, C3 Business Strategy
Risks and opportunities
How we identify, assess and
manage the
climate-related risks and op
portunities
a) Describe the organization's process for identifying and as
sessing climate-related risks.
a) Describe the organization's process to manage climate-re
lated risks.
c) Describe how the Organization's climate-related risk iden
tification, assessment and management processes are inte
grated into overall risk management.
• 2022 Sustainability Report > Environmental Re
sponsibility > TCFD
• CDP Climate Change 2022- C2 Risk and
Opportunities, C3 Business Strategy
Metrics and targets
How we assess and
manage the climate-related
risks and
opportunities
a) Disclose the metrics used by the organization to assess cli
mate-related risks and opportunities, in line with the risk
management strategy and process.
b) Disclose GHG emissions (scopes 1, 2 and 3) and the asso
ciated risks.
c) Describe the objectives used by the organization to man
age climate-related risks and opportunities and assess its
performance against the objectives.
• 2022 Sustainability Report > Environmental Re
sponsibility > Sustainable Operations
• 2022 Sustainability Report > Environmental Re
sponsibility > TCFD
• CDP
Climate
Change
2022-
C4
Targets
and Performance, C6 Emissions data

Alignment with the CMVM model of report for the disclosure of non-financial information

Requirement Chapter/section Pages
Part I - Information on the Policies adopted
Description of the Company's general policy regard
ing sustainability issues, with an indication of any
changes to the previously approved
SR 22 Introduction > Sustainability Policy
SR 22 Relation with Stakeholders > Sustainability
Master Plan (SMP) 2022
22
37-38
A - Introduction Description of the methodology and the reasons for
its adoption in reporting non-financial information,
as well as any changes that may have occurred in re
lation to previous years and the reasons that moti
vated them.
SR 22 Introduction > Sustainability Policy
SR 22 Relation with Stakeholders > Sustainability
Master Plan (SMP) 2022
22
37-38
General description of the business model and form
of organization of the Company/Group, indicating
the main business areas and markets in which it op
SR 22 Creation of Value 10
B – Corporate
Model
SR 22 Introduction > Governance Model 22-23
erates (if possible using organization charts, graphics
or functional tables).
AR 22 Business Model 39-42
1. Identification of the main risks associated with the
subject matter of the report and arising from the
Company's activities, products, services or commer
cial relationships, including, where applicable and
whenever possible, supply chains and outsourcing.
SR 22 Introduction > Management of social and
environmental risks
SR 22 Economic Responsibility and of Governance >Employ
ees
30
49-65
SR 22 Social Responsibility > Human Rights
SR 22 Environmental Responsibility > TCFD
115-117
159-162
2. Indication of the way those risks are identified and
manage d by the company.
SR 22 Introduction > Management of social and
environmental risks
SR 22 Economic Responsibility and of Governance > Ethics
and Professional Conduct > Internal Audit
30
73-74
C - Main Risk
Factors
1. Explanation on the internal functional distribution
regarding
competences,
including
the
corporate bodies, commissions, committees, or divi
sions responsible for the identification/management
/monitoring of the risks.
SR 22 Introduction > Management of social and
environmental risks
SR 22 Economic Responsibility and of Governance > Ethics
and Professional Conduct > Internal Audit
SR 22 Environmental Responsibility > TCFD
30
73-74
159-162
2. Express indication of the new risks identified by the
company
versus
what
was
reported in previous years and well as of the risks
that stopped being risks.
SR 22 Introduction > Management of social and
environmental risks
SR 22 Economic Responsibility and of Governance >Employ
ees
SR 22 Social Responsibility > Human Rights
SR 22 Environmental Responsibility > TCFD
30
49-65
115-117
159-162
3. Indication and brief description of the main oppor
tunities that are identified by the Company in the
context of the themes object of reporting.
SR 22 Introduction > Strategic Plan 2021/2024
SR 22 Environmental Responsibility > TCFD
23-24
159-162
D - Implemented
Policies
i. ENVI
RONMEN
1. Description of the Company's strategic objectives
and
the
main
actions
to be taken to achieve them.
SR 22 Environmental Responsibility > TCFD 135-162
TAL
POLICIES
2. Description of the main performance indicators de
fined.
SR 22 Environmental Responsibility 135-162
3.
Indication
versus
the
previous
year,
of the degree of fulfilment of those objectives, at
least by reference to:
i. Sustainable use of resources
ii. Pollution and climate changes
iii. Circular Economy and waste management
iv. Protection of biodiversity
SR 22 Environmental Responsibility > Sustainable
Operations
139-147
(cont.)

(cont.)

Requirement Chapter/section Pages
Part I - Information on the Policies adopted
ii. SOCIAL
AND POLITI
CAL
POLICIES
1. Description of the Company's strategic objec
tives and the main actions to be taken to achieve
them.
2. Description of the main performance indicators
defined.
SR 22 Social Responsibility > Sharing and participate
SR 22 Social Responsibility > Financial Literacy
SR 22 Social Responsibility > Foundations Group BCP
SR 22 Economic Responsibility and of Governance >
Suppliers
SR 22 Economic Responsibility and of Governance >
Products and services
SR 22 Introduction > Sustainable Finance Disclosures
(SFDR)
SR 22 Relation with Stakeholders
SR 22 Economic Responsibility and of Governance > Fis
cal Policy
99-103
103-106
118-134
65-66
31-32
34-39
93-96
3.
Indication
versus
the
previous
year,
of the degree of fulfilment of those objectives, at
least by reference to:
i. Commitments of the company towards the
Community
ii. Outsourcing and suppliers
iii. Consumers
iv. Responsible investment
v. Stakeholders
vi. Fiscal Information
i. SR 22 Social Responsibility > Sharing and participate
i. SR 22 Social Responsibility > Financial Literacy
i. SR 22 Social Responsibility > Foundations Group BCP
ii. SR 22 Economic Responsibility and of Governance >
Suppliers
iii. SR 22 Economic Responsibility and of Governance >
Products and services
iv. SR 22 Economic Responsibility and of Governance >
Products and services
iv. SR 22 Introduction > Sustainable Finance Disclo
sures (SFDR)
v. SR 22 Relation with Stakeholders
vi. SR 22 Economic Responsibility and of Governance >
Fiscal Policy
99-103
103-106
118-134
65-66
65-66
31-32
34-39
93-96
iii. EM
PLOYEES
AND GEN
DER
EQUALITY
AND NON
DISCRIMI
NATION
1. Description of the Company's strategic objec
tives and the main actions to be taken to achieve
them.
SR 22 Economic Responsibility and of Governance >Employ
ees
49-65
2. Description of the main performance indicators
defined.
SR 22 Economic Responsibility and of Governance >Employ
ees
49-65
3.
Indication
versus
the
previous
year,
of the degree of fulfilment of those objectives, at
least by reference to:
i. Office:
i. SR 22 Economic Responsibility and of Governance >Em
ployees
ii. SR 22 Social Responsibility > Foundations Group BCP
iii. SR 22 Social Responsibility > Benefits for Employees
49-65
118-134
ii. Work organization
iii. Health and Safety
iv. Social Relations
v. Training
vi. Equality
> Health and Safety
iv. SR 22 Summary of Indicators
SR 22 Economic Responsibility and of Governance >Employ
ees> Training
vi. SR 22 Economic Responsibility and of Governance >Em
ployees
107-114
12
54-55
49-65
IV. HU
MAN
RIGHTS
1. Description of the Company's strategic objec
tives and the main actions to be taken to achieve
them.
SR 22 Social Responsibility > Human Rights 115-117
2. Description of the main performance indicators
defined.
SR 22 Social Responsibility > Human Rights 115-117
3.
Indication
versus
the
previous
year,
of the degree of fulfilment of those objectives, at
least by reference to:
i. Due diligence procedures
ii. Measures for the Prevention of Risks
iii.
Legal
proceedings
for
violation
of human rights
SR 22 Social Responsibility > Human Rights
SR 22 Table UNGP- UN Guiding Principles Reporting
Framework
115-117
210-212
(cont.)

(cont.)

Requirement Chapter/section
Part I- Information on the Policies adopted
1. Prevention of Corruption SR 22 Economic Responsibility and of Governance >
Ethics and Professional Conduct
66-74
V. FIGHT AGAINST 2. Prevention of money laundering
(for issuing companies subject to this
regime)
SR 22 Economic Responsibility and of Governance >
Ethics and Professional Conduct
66-74
CORRUPTION AND
BRIBERY AT
TEMPTS
3. Codes of Ethics SR 22 Economic Responsibility and of Governance > Ethics
and Professional Conduct
66-74
4. Management of Conflicts of Interest SR 22 Economic Responsibility and of Governance > Ethics
and Professional Conduct> Conflicts of Interest Policies
66-74
72
Part II- Information on Standards/Guidelines followed
1. IDENTIFICATION OF STANDARDS/GUIDELINES FOLLOWED IN THE
REPORTING OF NON-FINANCIAL INFORMATION
SR 22 Introduction > Sustainability Reporting
SR 22 Introduction > Evolution of the Non-Financial Re
porting
19
21
2. IDENTIFICATION OF THE SCOPE AND METHODOLOGY TO CALCULATE
THE INDICATORS
SR 22 Introduction > Sustainability Reporting
SR 22 Methodology Note
19
188-189

Table of alignement with PRB - Principles for Responsible Banking

In June 2022, o Millennium BCP subscribed to the United Nations Environment Programme - Finance Initiative (UNEP-FI) and to the Principles of Responsible Banking (PRB). During 2023, the Bank will finalize its impact analysis according to the UNEP-FI Portfolio Impact Tool and publish the first PRB Self-assessment Report. In the table below, please find preliminary information that will support the making of the report based on the structure exemplified in the Reporting Guidance Document from UNEP-FI.

Reporting and Self-Assessment Requirements

High-level summary of bank's response Reference(s) / Links (s)

to bank's relevant information

Principle 1: Alignment

We will align our business strategy to be consistent with and contribute to individuals' needs and society's goals, as expressed in the Sustainable Development Goals, the Paris Climate Agreement and relevant national and regional frameworks.

1.1 Describe (high-level) your
bank's business model, including
the main customer segments
served, types of products and
services provided, the main sec
tors and types of activities, and
where relevant the technologies
financed across the main geog
raphies in which your bank has
operations or provides products
and services.
Millennium bcp is a bank with its decision-making centre in
Portugal; it is the largest Portuguese private bank, serving, in
2022, approximately 6.5 million Customers with a network of
1,239 branches. The international activity of Group Millen
nium is carried out by banking operations headquartered in
affinity markets and in countries with a recognized growth po
tential – Poland and Mozambique -, where it operates, under
the Millennium brand, with 832 agencies. Moreover, Group
BCP also ensures a presence in the five continents by means
of representation offices, branches, business protocols and
business promoters. In Portugal, Millennium bcp is focused on
the retail market, providing services to its Customers in a seg
mented manner. The operations of the subsidiary companies
generally provide their products through the Bank's distribu
tion networks.
Institutional Website
("Who we are")
Sustainability Report 2022
(III – Economic and Gov
ernance Responsability; 1.
Millennium Network)
1.2 Describe how your bank has
aligned and/or is planning to
align its strategy to be con
sistent with and contribute to
society's goals, as expressed in
the Sustainable Development
Goals (SDGs), the Paris Climate
Agreement, and relevant na
tional and regional frameworks.
The involvement of Millennium bcp in the fulfilment of the
SGD can be found, first and foremost, in the matrix and in the
values of the Bank, especially in its relation of proximity with
people and capacity to add social value. The Bank considers
that it plays a relevant role in the compliance with the na
tional and international commitments, recognising the im
portance of the involvement and alignment of the financial
sector in the transition into a sustainable and inclusive eco
nomic development model. In terms of climate changes, the
Bank assumes the commitment established within the scope
of the Paris Agreement and the objective of limiting global
warming below 1,5º degrees Celsius. Assuming its role, as an
organization and funding entity, in facilitating the global tran
sition to a low carbon economy, Millennium bcp recognises
the need to reduce its own greenhouse gas emissions in its
operations and also of those deriving from its credit/invest
ment portfolio. In this context, the Bank is internally evaluat
ing the possibility of setting emission reduction targets based
on science, within the scope of the Net-Zero Banking Alliance
(NZBA) or the Science Based Targets initiative (SBTi). With re
gard to ethical and responsible leadership, we emphasize the
Sustainability Report 2022
(I – Introduction; 1 – Sus
tainability Reporting; 6 –
Commitments)
BCP Group's commitment to the Global Compact Principles.
Principle 2: Impact and Target Setting
significant impacts.
We will continuously increase our positive impacts while reducing the negative impacts on, and managing the risks to, people and envi
ronment resulting from our activities, products and services. To this end, we will set and publish targets where we can have the most
2.1 Impact analysis
2.2 Target setting
2.3 Plans for target implementa
tion and monitoring
In order to understand the level of alignment with the PRB, in 2021 the
Bank carried out an initial exercise to assess the positioning of Millen
nium bcp, Bank Millennium and Millennium bim, in relation to the Prin
ciples. In this exercise, it was already possible to identify a number of
actions to be considered, such as the analysis of the impact of the ac
tivity developed by the Bank on people and on the environment using
the Portfolio Impact Tool. During 2022, the bank continued to carry out
work on data collection and application of the Portfolio Impact Tool,
which it intends to complete during 2013.
N.A.
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.
3.1 Provide an overview of the pol
icies and practices your bank has
in place and/or is planning to put
in place to promote responsible
relationships with its customers.
The conduct and the management of ethics in business is de
terminant for the development and growth of companies and
paramount in the decision-making process, namely in the fi
nancial companies, providing benefits such as Clients' loyalty,
satisfaction of the expectations of internal and external cli
ents, positive differentiation among the remaining companies
and reputation consolidation. The entities of the BCP Group,
the members of its management and supervisory bodies, as
well as its Employees, guide their actions by principles of re
spect for the rights of people, for the preservation of social
and environmental sustainability, and for institutional culture
and values, committing to adopt behaviours of integrity and
honesty in all relations that they establish with each other,
with their Customers, or any other person or entity with
whom they have a relationship. The Code of Conduct estab
lishes the fundamental principles and rules to be observed in
the exercise of the activity developed by the entities that form
Group Banco Comercial Português underlying the conduct,
good practices and observance of the institutional values by
the universe of people that form the Group.
Code of Conduct
Sustainability Report 2022
(III – Economic and Gov
ernance Responsibility; 7.
Ethics and professional
conduct)
3.2 Describe how your bank has
worked with and/or is planning to
work with its clients and custom
ers to encourage sustainable
practices and enable sustainable
economic activities.
The Bank has been intensifying the consideration of ESG cri
teria, namely environmental performance criteria, in the offer
of the Bank's products and services. In the geographies where
the BCP Group operates, various products and services have
been developed that consider environmental aspects and/or
that are developed considering their environmental impact
and that aim to support more ecological choices by Custom
ers, creating sustainable living habits, in their homes and on
2022 Sustainability Report:
I – Introduction (9. Sustain
able Finance Disclosure
Regulation) III – Economic
and Governance Responsi
bility (8. Products and Ser
vices)

their travels. Examples: Program "Casa Eficiente 2020, Personal Loan Energias Renováveis,car Leasing for new vehicles100% electric, Loan EcoActivo etc. We also point out that: i) A few years ago, Bank Millennium in Poland decided to significantly reduce its exposure to the coal industry, whose financing conditions are now expressed in the Environmental Policy; ii) Environmental risk analysis is an integral part of the Customer assessment, credit granting, project finance and discretionary portfolio management processes, and is therefore incorporated into our policies, standards and management procedures.

Principle 4: Stakeholders

We will proactively and responsibly consult, engage and partner with relevant stakeholders to achieve society's goals.

4.1 Describe which stakeholders (or groups/types of stakeholders) your bank has consulted, engaged, collaborated or partnered with for the purpose of implementing these Principles and improving your bank's impacts

The BCP Group defines strategies and pursues policies adjusted to the new challenges imposed by the interested parties with which it relates, materializing a business model based on an ongoing and transparent dialogue enabling to understand and comply with the expectations of its Stakeholders. The most recent process for hearing stakeholders involved, through a representative sampling, the main interested parties, namely: (i) Shareholders; (ii) Clients; (iii) Employees (iv) Community; (v) Suppliers and (vi) Media, in an exercise that made it possible to understand their perception of the significance of the Bank's impacts, but also their main needs and expectations regarding the organization's performance in terms of sustainability. The consultation contributed to the (re)definition of material topics for the Bank, reflected in the new Materiality Matrix and in the Sustainability Master Plan.

Sustainability Report 2022 (II – Relation with Stakeholders; 1. Involvement of stakeholders and materiality analysis)

Principle 5: Governance & Culture

We will implement our commitment to these Principles through effective governance and a culture of responsible banking

social, environmental and climate changes. In 2022, within the scope
of the Committees of the Board of Directors (CA), the re-denomina
tion of the Committee for Corporate Governance, Ethics and Profes
sional Conduct to the Committee on Corporate Governance, Ethics
and Sustainability was also approved, as well as the respective regu
lations (Regulations of the CCGES), which makes this body responsible
for recommending the adoption by the Board of Directors of policies
in line with ethical principles and social responsibility and with the
best practices in matters of corporate governance and sustainability.
The BCP Group assumes, as a fundamental commitment and purpose,
to pursue business models that create value for its Stakeholders with
the aim of contributing to the economic and social development of the
countries where it operates. In its relationship with employees, it aims
to support their professional and personal development, improve
leadership skills, communication and teamwork and commitment and
identification with the Bank's culture of responsibility. In that sense,
we underline:
i) internal mechanisms for the dissemination and training of Employ
ees, which allows, among others, to clarify and support Employees on
2022 Sustainability Report:
III – Economic and Govern
ance Responsibility (7. Eth
ics and professional con
duct); V – Environmental
Responsibility (2. De-car
bonisation)
Policy of corporate volun
teering
spective, of the Sustainability strategy, which includes the economic,
the most important aspects to be considered, both in terms of the risk
We will periodically review our individual and collective implementation of these Principles and be transparent about and accountable
for our positive and negative impacts and our contribution to society's goals.
Principle 6: Transparency & Accountability
5.3 Governance Structure for Im
plementation of the Principles.
Show that your bank has a gov
ernance structure in place for the
implementation of the PRB
In order to ensure effective management of environmental issues at
the Bank (including PRBs), the existence of a Governance structure
transversal to the organization is ensured capable of responding to en
vironmental issues and ensuring timely decision-making in line with
the strategy of BCP Group. Includes: Board of Directors, Executive
Committee, Sustainability Commission, Risk Commission, Sustainabil
ity Areas and Mbcp Sustainable Finance Taskforce.
2022 Sustainability Report
(Annexes – TCFD)
v) the installation of electric charging stations on the Bank's premises,
in Taguspark, in Portugal, in order to encourage the adoption of more
sustainable lifestyles by Employees.
iv) the development of volunteering initiatives and social support ac
tions, which respond to the needs of the most vulnerable segments of
the population, and which contribute, at the same time, to deepening
the skills of Employees and to their motivation, spirit of solidarity and
involvement with the organization.
Iii) the current performance appraisal system, which assesses the Em
ployee's annual performance against the defined objectives and
makes it possible to highlight the performance level of each individual
and accurately identify eligibility for promotions based on merit.
ii) the internal policy in anti-corruption and anti-bribery, demanding
that its Employees to completely abstain from carrying out this type of
acts.
of financial crime and in the remaining risks of compliance and regula
tory compliance.

6.1 Progress on Implementing the Principles for Responsible Banking

In our Sustainability Report, published annually, we seek to respond to all themes related to the Bank's ESG commitments.. In terms of reporting guidelines, the Bank develops its Sustainability Report in line with the GRI Standards, and also publishes the SASB indicators, namely those associated with the financial sector, as well as the recommendations from TCFD and, in Portugal, from CMVM. This report also includes the reporting on Human Rights, in accordance with the UN Guiding Principles Framework. In matters related to Sustainable Finance, the Bank monitors the evolution of the legal and regulatory context of the financial sector and participates in several Working Groups, national and international, in these thematic areas. Furthermore, the Group BCP wishes to ensure an increasingly greater alignment between offer, business procedures and operations of the financial sector with the ESG themes (Environmental, Social and Governance), by means of the inclusion of social and environmental issues in the activities performed by the company, from risk governance and management model to the offer and management of internal activities. The bank's commitment is, throughout the implementation of the PRBs, to transparently report its positive and negative impacts and the contribution to the objectives of society in general.

2022 Sustainability Report: I – Introduction (2. European Regulatory Agenda)

Sustainability Report 2022

© Millennium bcp

www.millenniumbcp.pt

Banco Comercial Português, S.A., Company open to public investment

Registered Office: Praça D. João I, 28 4000 295 349

Share Capital: 3,000,000,000.00 Euros

Registered at Commercial Registry Office of Oporto under the Single Registration and Tax Identification Number 501 525 882

ERSCD - Corporate Sustainability Area Av. Prof. Dr. Cavaco Silva (Tagus Park) Edf. Edif 1, N.º 32 - Piso 0 B 2740 256 349 Phone: (+351) 211 135 250 [email protected] [email protected]

All mentions in this document to the application of any ruling mean the version currently in effect.

This report was made in accordance with the GRI Standards: Core option.

This report is included in the perimeter of verification of information on Sustainability of Millennium bcp, carried out by PricewaterhouseCoopers & Associados, S.R.O.C., Lda., in Portugal concerning the 2022 financial year.

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