ENVIRONMENT

NBG’s commitment to environmentally responsible conduct is formulated both in the Bank’s Environmental Policy Statement, which it implements in its business operations, as well as in the Group’s Code of Conduct. In line with NBG’s commitment to environmentally responsible operations, since 2004 we have developed and implemented an Environmental Management System, in compliance with international standard ISO 14001.

In the context of the Environmental Management System, the Bank’s overall environmental footprint was analysed and the results served as the basis for the formulation of the following 5 key pillars in NBG’s Action Programme:

1. Conservation of natural resources and energy.
2. Rationalisation of work-related travel and commuting.
3. Effective management of paper and solid waste.
4. Deployment of environmental standards in purchasing.
5. Deployment of an environmental risk assessment policy in investment and credit processes.

Concerning Natural Resources and Energy Management:

In its efforts to reduce consumption of natural resources and related operating costs, the Bank has decided to deploy an electronic system for their recording and measurement, a project which is currently in the planning phase and will be completed in stages. To this end natural gas, heating oil, electricity, and water consumption have been placed under centralized monitoring. Effective energy management and reduction in energy consumption are significant components of our CSR endeavours. To this end, a number of actions are taken, which will be described below:

Reducing Emissions: NBG has taken specific measures in order to reduce CO2 emissions aiming at:

• The reduction of consumption of energy for the operation of its premises.
• Acquiring and upgrading equipment.
• The rationalization of its officers’ and customers’ travel.

Water Management: NBG fully recognizes the importance of effective drinking water management, as this is an extremely important natural resource, which will gradually be under pressure as a result of the impact of climate change in Greece and abroad. The Bank’s water supply comes from the public water supply network. Because of the nature of the Bank’s activities, the water is mainly used in rest room facilities and for cleaning work areas, while the use of water-cooled air-conditioning systems is limited. The Bank’s efforts have focused on preventing and avoiding leakages via regular maintenance of plumping installations. In 2013, total water consumption amounted to 47,767 m3 and was recorded in 309 units (50 administration buildings and 259 Branches).

Rationalizing Travel: NBG’s staff’s and customers’ travel result emitting air pollutants which aggravate the greenhouse effect. That is why NBG tries to take measures of eliminating direct emissions (staff’s travel) and indirect (customers’ travel), combining at the same time environmental responsibility and financial effectiveness. To rationalize staff travel, in 2013 the Bank activated its “NBG Travel Policy”, aiming at establishing a single framework regulating long distance travel by the Bank’s staff and the harmonization with the Environmental Management System principles.

Reducing Direct and Indirect emissions: NBG takes specific measures regarding staff’s travel such as distance learning courses (e-learning), installation of video-conferences and use of hybrid technology cars, the main features of which are lower fuel consumption and lower greenhouse gas emissions. Taking into consideration that Provision of services by NBG entails travel by its customers to and from its branches. The Bank has taken measures to limit travel by reducing both the frequency and the mileage of customers’ travel to the Bank’s branches or ATMs. The need to travel is reduced by increasing the number of transactions available through internet and phone banking services and by upgrading mobile banking services. Accordingly, customers are not required to visit a branch or ATM, as they are able to carry out transactions remotely, and as a result the Bank achieves an indirect reduction in greenhouse gas emissions, making a positive impact on climate change. Mileage is reduced by the rationalization and broader geographical dispersion of the Bank’s network (540 branches, 40 transaction offices, 1,396 ATMs and 43 APS). In its network development strategy, the Bank takes into account such criteria as the mileage between its units and the frequency of visits to a unit, accordingly minimizing the travel required for daily services to customers.

Ozone Layer:

To try and address the problem of ozone layer depletion, the Bank focuses on its air-conditioning and fire-fighting systems. Most of the air-conditioning units at the Bank’s premises have been replaced with new technology units, while any obsolete unit that cannot be repaired is replaced by a new one containing environmentally friendly liquid refrigerants, such as R134, R407 and R410.

Paper and Solid Waste Management:

NBG implements a paper recycling programme in the Administration Buildings and its Branches. At the same time tries so that its needs for paper (A4, A3, and special printing) are met by purchasing recyclable paper awarded the EU Ecolabel logo for certified sustainable forests: FSC (Forest Stewardship Council) or PEFC (Programme for the Endorsement of Forest Certification). This paper is bleached using environmentally friendly methods (ECF, PCF, TCF) and not using elemental chlorine that is environmentally harmful.

Toner Management: NBG has outsourced the servicing of its Managed Print Services (MPS) printing needs at its central offices based in 38 central buildings and 103 Branches. This agreement also includes the environmentally friendly management of waste originating from the device consumables. This pilot programme has led to a reduction in printing and, as a consequence, reductions in paper and ink/toner consumption.

Accumulator, small battery, waste lighting items and bulbs, equipment, management: Within the context of the Environmental Management System implementation, recycling of accumulators takes place via partner companies, to the accredited recycling organization SYDESYS SA, small battery recycling via AFIS SA, waste lighting items and bulbs in all its premises (439 collection points at administration and branches). Via accredited organizations and equipment recycling via “Appliances Recycling S.A.” (“Anakyklosi Syskevon S.A.”).

Environmental Criteria for Supplies:

Besides its other CSR actions, NBG seeks to act responsibly in the sphere of purchasing, with a view to reducing its own environmental footprint and exercising indirect pressure on its suppliers to improve their own CSR. Accordingly, it strives to promote best practices within its sphere of influence, including its suppliers and associates. To do this, NBG evaluates its suppliers in terms of environmental criteria, including:

• Technical specifications of the products (i.e. low energy consumption).
• Compliance with legal requirements concerning environmental issues (e.g. avoiding the use of harmful chemicals).
• Participation in alternative management and recycling systems for obsolete equipment.

To minimize the impact of its electrical and electronic equipment on the environment, the Bank applies a number of environmental criteria, on both the mandatory and optional levels:

• Mandatory criteria include the supplier’s declaration that the equipment in question meets legal provisions regarding recycling/alternative management.
• Optional criteria include an environmental management certificate issued by the manufacturer or any other document evidencing environmental actions taken by the manufacturer or supplier.

Responsible Financing - Environmental Risk Evaluation and Management:

NBG uses the Risk Advisor Model included in the Risk Analyst system developed by Moody’s KMV to assess the credit ratings of most enterprises (large and medium-sized) included in its corporate loan book. Alongside various other criteria, the said model includes industry risk due to adverse events, with three score levels (high, moderate and low-risk) regarding the environmental impact and risks associated with the industry sector, in line with the ratings of the independent international organization Ethical Investment Research Services (EIRIS). In addition, the Bank places special emphasis on approvals of loans that serve to support business activities that will enhance employment and protect the environment. Failure on the borrower’s or the guarantor’s part to comply with the environmental and sanitary legislation may lead to termination of the loan contract by the Bank. Polluting businesses that do not take any protective measures are deemed undesirable on the basis of the Bank’s credit policy.

The Bank supports business activities that boost the total environmental potential of Greece, such as:

• Production of “green”, traditional and biological products.
• Infrastructures (local government organizations etc).
• Investment in environmental protection, “clean” technology, certification of environmental management systems, saving energy and natural resources. Participation in joint funding packages for “environmental” programmes for the enhancement of entrepreneurship.
• R&D of environmental products and practices.

The Bank does not undertake the funding of activities banned by EU regulations, such as trade in protected wild fauna, production and trade of radioactive materials and chemicals that have been banned by international protocols, transportation and release of genetically modified products into the natural environment, etc. NBG channels funding into a variety of business activities, taking into consideration assessments and studies by relevant authorities, as well as by independent bodies specializing in the evaluation and supervision of environmental risks. Moreover, in line with its credit policy, the Bank assesses risks on the basis of the Risk Analyst platform (which includes, inter alia, environmental criteria). The assessment is carried out every 12 months (in certain cases more frequently, i.e. every 4-6 months), including visits by Relationship Managers to the premises of the borrowers. NBG also monitors, on an annual basis, borrowers’ compliance with the relevant contractual terms by sending special units from its Technical Services Division to borrowers’ premises to reassess their property and industrial facilities. Note that in the case of funding handled by the Bank’s Project Finance Division, environmental risks are assessed ad hoc by specialized environment advisors who act for the account of the lending banks. These advisors carry out relevant reviews on projects to be financed and certify that the project in question complies with the requirements of environmental legislation and that relevant permits are obtained. Specialized environment advisors have been employed for most of the 20 projects included in the Project Finance Division’s portfolio, while compliance and the obtaining of relevant environmental permits are among the prerequisites for the loan disbursement.