2023 SUSTAINABILITY REPORT

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2023 SUSTAINABILITY REPORTBLANK PAGE

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2023 SUSTAINABILITY REPORT

Table of contents
7
9JOINT MESSAGE OF THE CHAIRMAN OF THE BOARD OF DIRECTORS AND OF THE
CHAIRMAN OF THE EXECUTIVE COMMITTEEVALUE CREATION

11

SUMMARY OF INDICATORS

14

MAIN EVENTS

18

INTRODUCTION19

SUSTAINABILITY REPORT20EUROPEAN REGULATORY AGENDA

21

DEVELOPMENTS NON -FINANCIAL REPORTING

23

SUSTAINABILITY POLICY23

ESG ECOSYSTEM

24

PARTNERSHIPS

24

WORKING GROUPS

25

GOVERNANCE MODEL

26

2021/2024 STRATEGIC PLAN

28

COMMITMENTS

30

UNITED NATIONS SUSTAINABLE DEVELOPMENT GOALS (SDG)

31

PRINCIPLES OF RESPONSIBLE BANKING (PRB)

32

MANAGEMENT OF ESG RISKS33

SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR)

34

APPROACH TO SUSTAINABILITY |RELATION WITH STAKEHOLDERS

35

STAKEHOLDER ENGAGEMENT AND THEMATIC MATERIALITY ANALYSIS37

SUSTAINABILITY MASTER PLAN (SMP) 2023

41

ECONOMIC AND GOVERNANCE RESPONSIBILITY42

SUSTAINABLE DEVELOPMENT GOALS (SDG)

44

MILLENNIUM NETWORK49

INNOVATION

50

INFORMATION SECURITY

53

DATA PROTECTION AND PRIVACY54

SHAREHOLDERS55

EMPLOYEES75

SUPPLIERS

76

ETHICS AND PROFESSIONAL CONDUCT88

PRODUCTS AND SERVICES99

SERVICE QUALITY

108

FISCAL POLICY

4

2023 SUSTAINABILITY REPORT113

SOCIAL RESPONSIBILITY114

SUSTAINABLE DEVELOPMENT GOALS (SDG)

116

PARTICIPATE AND SHARE

122

FINANCIAL LITERACY126

EMPLOYEE BENEFITS135

HUMAN RIGHTS138

BCP GROUP FOUNDATIONS138

MILLENNIUM BCP FOUNDATION150BANK MILLENNIUM FOUNDATION155

ENVIRONMENTAL RESPONSIBILITY158

SUSTAINABLE DEVELOPMENT GOALS (SDG)

160

SUSTAINABLE OPERATIONS

162

DECARBONISATION

165

ENERGY EFFICIENCY171

EUROPEAN UNION TAXONOMY172

CLIMATE AND ENVIRONMENTAL MATERIALITY ASSESSMENT176

TASK FORCE ON CLIMATE -RELATED FINANCIAL DISCLOSURES (TCFD)183

HIGHLIGHTS: RENEWABLE ENERGY PRODUCTION186

ACTIVOBANK195

ESG OBLIGATIONS - ALLOCATION AND IMPACT REPORT206

SUSTAINABILITY INDEXES

209

METHODOLOGY NOTES

213

EXTERNAL AUDITOR'S REPORT216

ANNEXES217

GRI TABLE - GLOBAL REPORTING INITIATIVE AND UN GLOBAL COMPACT

229

SASB TABLE - SUSTAINABILITY ACCOUNTING STANDARDS BOARD

233

UNGP TABLE - UN GUIDING PRINCIPLES REPORTING FRAMEWORK

236

TABLE OF ALIGNMENT WITH TCFD RECOMMENDATIONS

237

TABLE OF ALIGNMENT WITH THE REPORTING MODEL FOR DISCLOSURE OF NON -FINANCIAL INFORMATION OF CMVM

240

ALIGNMENT TABLE WITH PRB - PRINCIPLES FOR RESPONSIBLE BANKING

259

TABLE CSRD (CORPORATE SUSTAINABILITY REPORTING DIRECTIVE) AND ESRS (EUROPEAN SUSTAINABILITY REPORTING STANDARDS)

267

TABLE COMMITMENTS

270

TABLE EUROPEAN UNION (EU) TAXONOMY

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2023 SUSTAINABILITY REPORT

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2023 SUSTAINABILITY REPORT

Joint Message from the Chairman of theBoard of Directors and the Chairman of
the Executive Board
The year 2023 was marked by a favorable evolution in global economic activity, benefiting from the reduction in inflation levels, after
the strong increase observed in 2022. While the context remained complex, with macroeconomic and geopolitical uncertainties having
increased, Millennium bcp's activity was also influenced by favorable factors, particularly those resulting from the normalization of monetary policy, with the bank ending the year with a consolidated net profit of 856 million euros, corresponding to a return on equity (ROE)of 16%, and a robust capital position, reflected in a CET1 ratio of 15.4% and total capital of 19.9%.
The preparation and rigorous work in pursuit of the objectives outlined in the strategic plan, with the main targets reached more than ayear in advance, allowed us to achieve results that mark2023 as the end of the transition period and signal a progression to a new phase,with the return to normalization of the bank.
One of our hallmarks has been our commitment to Sustainability. In 2023, we once again stood at the side of people, society andcommunities in creating lasting and consequential social value, and in protecting the environment, climate and biodiversity, through a
corporate culture that is based on, and manifests itself in ethical, inclusive and responsible business practices.
Having as a reference framework the Strategic Plan "Overcoming 24", with Sustainability as one of its fundamental axes, and using the
Sustainability Master Plan, an aggregator of actions to be developed in the ESG (Environmental , Social and Governance) areas, as an
instrument of innovation, evolution and change, Millennium bcp has strengthened its governance model, as well as its risk, credit andsupply chain management policies and processes. It has renewed the solutions, products and services on offer, reflecting atransformative dynamic that allows the bank to respond to the growing requests, needs and ambitions of stakeholders and the
expectations of regulators.
On the business level, the bank continued to support companies and families, providing sustainable credit, investment and savings
solutions suited to their needs and financial capabilities. In terms of accessibility, Millennium bcp provides integrated platforms andinnovative electronic banking functionalities, in particular mobile banking, which is a strong contribution to inclusive banking, and istoday also a distinctive brand recognized by customers and users in the different geographies in which the bank is present.
Microcredit, a financing solution designed to encourage entrepreneurship and self-employment in Portugal which the bank has offeredsince 2005, enabled the creation, in 2023, of 42 new jobs, with more than 7,450 jobs attributable to projects financed since 2005 byMillennium bcp’s Microcredit.
Millennium bcp also promotes a culture of environmental responsibility, mitigation and adaptation to climate change and protection of
the surrounding environment and biodiversity. The preservation of natural resources and the rationalization of consumption remain
essential objectives of the bank's environmental impact policy. As a tangible result of this commitment, the production of renewableenergy from the two photovoltaic grids installed in Taguspark stands out. These represented, in 2023, 31.9% of local electricity
consumption and meant of 811 tonnes of CO2 were not emitted.
Millennium bcp is equally committed to equal opportunities, diversity and inclusion. Initiatives to support pregnancy and parenthood,conciliation between work and family, professional development and leadership opportunities for women, as well as involvement inprojects such as Nova SBE's “Commitment to Inclusion,” dedicated to life of people with disabilities, are examples and testimony of thesecommitments.

7

2023 SUSTAINABILITY REPORTAs part of the bank’s appreciation for and professional development of its emplyees, mention must be made of the investment in training,which allowed, in 2023, to deliver more than 6,000 actions in different formats.
Through the Millennium bcp Foundation, we maintained support for culture, promoting events aimed at different target audiences,holding thematic exhibitions to share the bank's art collection, promoting and recognizing creative merit and contributing to therecuperation of historical buildings and museum heritage, with special emphasis on the Rua dos Correeiros Archaeological Center (NARC).
Education, science and research are also areas in which the Millennium bcp Foundation continues to be present through an active andconsistent policy of supporting multidisciplinary projects and initiatives that stand out for their innovation, social and environmental
impact and ability to provide value to society.
In social support, we reinforced, among the communities we serve, the bank's commitment to the most disadvantaged, needy andvulnerable. In Portugal, as part of our Social Responsibility Plan, we maintained the partnership with the Food Bank and Entrajuda, as
well as promoting protocols, initiatives and support in favor of institutions such as EPIS, CASA, Brigada do Mar and BIPP/Semear,developing joint actions involving more than 200 Millennium Volunteers.
In Mozambique, the bank supported the “Banking Olympics”, a financial literacy program aimed at young people that is now in its 12thedition, as well as the partnership with Friends in Global Health (FGH) for the rehabilitation of 41 health centers in the province ofZambézia destroyed by Cyclone Freddy.
In Poland, highlights include the program of Bank Millennium and its Foundation "Our People'23: Save the Planet", which stimulated andenabled a set of proximity actions with social and environmental impact on the population, involving more than 200 Millennium
Volunteers . Additional mention should be made of “Financial ABC”, a program that, in its 10th edition, remains a local benchmark infinancial literacy initiatives for young people.
Millennium bcp also reaffirmed its commitment to the 10 Principles of the United Nations Global Compact - in a link that dates back to2005 and was renewed in 2018 - recognizing in the Sustainable Development Goals (SDGs) of the United Nations 2030 Agenda a unifying
and aspirational vision, capable of stimulating processes of change and evolution that the economic, social and environmental reality
imposes and requires. The Bank chose as priority SDGs: 4 - Quality Education; 7 - Renewable and Accessible Energy; 8 - Decent Work andEconomic Growth; 10 - Reduce inequalities; and 13 - Climate Action.
In 2024, we will continue to promote decarbonized and resilient economic development models, based on ethical, responsible businesspractices that foster the prosperity of families and companies in the countries where we operate, creating wealth and ensuring its fair
distribution, protecting 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.
We conclude by reiterating Millennium bcp's commitment to society and its different Stakeholders, highlighting that the normalization
path undertaken, embodied in the results presented for 2023, allow us to confidently assert that Millennium bcp is a bank prepared forthe future.

Miguel Maya

Nuno Amado

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

Chairman of the Board of Directors

82023 SUSTAINABILITY REPORTVALUECREATION

9

2023 SUSTAINABILITY REPORT

Value Creation Model
WHAT SETS US APART
International presence as a platform
for growthand market diversification

Largestprivately-ownedbanking
institution in Portugal

Growth anchored indigital/mobile banking,sustainability and innovation

OUR BUSINESS

Savings
and Investments

CreditInsurance

Accounts
andCards
Investment
Banking2023
Axes

Inputs

Outputs

Financial
BCP works to promote sustainable financial
services and to deliver attractive returns to

Customers Total Resources: 95.3 thousand
M€
Total credit: 55.2 thousand M€
Net profit: 856.0 M€

Interest paid on deposits and other resources: 882 M€
Taxes paid: 537.4 M€

Service
BCP works to offer a quality service
to customers, increasingly digital
and with greater security.

No. of customers: 7.4 M
No. of mobile customers: 5.3 M

Average resolution claims (1): 8 days
NPS (Net Promoter Score) (1): 70.4%
CSI Banca 2023 (Marktest) (1):Millennium bcp is No.3 in the ranking

Intellectual
BCP works to develop and improve
its offer and services, adapting
them to the latest trends
and customer needs.

Investment in R&D(1): 40.1 M€

Training hours: 728,681 (58% M, 42% H)
46 per employee

Human
BCP works with and for the people
who make up its workforce
and who guarantee a quality service
every day.

No. of employees: 15,688
Gender distribution: 55% M, 45% H Recruitment rate: 9.7%

Employee satisfaction: 75% (1)(2)
Employees with permanent contracts:
93.4% Employees with a collective labour agreement: 99.7% (3)Social
BCP works to support
the local communities, empowering
them and providing them withthe means to add social value.

Donations: 2.4 M€
Payments to local Suppliers: 90.3%
Social Bonds (1): 500 M€

Millennium bcp Foundation(1) supports
127 projects: 58% in Culture, 10%
in Knowledge and 32% in Social Solidarity (1)NatureBCP works to minimise negative impacts on
the environment, climate, and biodiversity,
both in its operations and in the support to its
customers.

Electricity consumed(4): 47,760 MWh
In Portugal and Poland, 100% from renewable sources.

0.75 tCO2 emitted / employee(5)3.04 MWh consumed / employee(4)shareholders and other stakeholders.

United Nations Sustainable Development Goals (6)(1) Includes only operations in Portugal.
(2)

average of global indicators.
Value reflects the operations in which this regime is applicable (PT and MZ).
Electricity - Public Grid.
(5)
Includes scope 1, 2 (market-based) and 3 emissions.
(6)
Review of priority SDGs carried out in the context of the 2022/2023 Stakeholder Consultation (PT).
(3)
(4)

10

2023 SUSTAINABILITY REPORTSUMMARY
OF INDICATORS

11

2023 SUSTAINABILITY REPORT

MAIN INDICATORSSUMMARY OF NON FINANCIAL INFORMATION

Unid.

2023

2022

2021

2020

2019

2018

Var. % 23/22

Total of Customers

Thousands

7 450

7 203

6 812

6 667

6 617

5 826

3.4%

Number of Active Customers (1)Thousands

6 701

6 478

6 143

5 705

5 598

Interest paid on deposits and interbank funding

Million euros

882

422

91

188

301

327

109.0%CUSTOMERS

Claims registered (2)Claims resolved

3.4%

Number223 172

201 828

172 753

172 674

136 562

108 244

10.6%

Percentage

93.9%

92.2%

93.4%

92.8%

92.2%

99.3%

1,7 p.p.

NumberACCESSIBILITIES
Branches

1 206

1 239

1 288

1 38

1 536

1 101

-2.7%

Activity in Portugal

399

407

434

478

505

546

-2.0%

International activity

807

832

854

902

1 031

555

-3.0%

Branches opened on Saturday

153

160

162

167

143

122

-4.4%

Branches w ith access conditions to people w ith reduced mobility

793

826

875

937

875

866

-4.0%

2 435 902

2 762 685

2 653 754

2 453 555

2 214 885

1 980 905

-11.8%
37.6%

Internet

Users number

Call Center

Users number

659 605

479 265622 735

491 969431 169429 982

Mobile banking

Users number

4 678 735

4 293 837

3 700 969

3 214 664

2 601 401

2 106 289

9.0%

Number

2 849

2 943

2 959

3 022

2 988

2 952

-3.2%

Portugal Employees

Number

6 242

6 252

6 289

7 013

7 204

7 095

-0.2%

International Employees

Number

9 446

9 495

9 731

10 32211 377

8 972

-0.5%

TOTAL

Number15 68815 74716 02017 33518 581

16 067-0.4%

ATM
EMPLOYEESLABOUR INDICATORS (3)Breakdow n by professional category

NumberExecutive Committee

24

23

28

28

28

28

4.3%

Senior Management

159

167

165

163

221

178

-4.8%

Management

1 648

1 468

1 735

1 874

2 157

1 728

12.3%

Commercial

8 842

9 147

9 048

9 949

10 664

9 446

-3.3%

Technicians

4 313

4 140

4 067

4 067

4 388

3 682

4.2%

702

798

973

1 250

1 116

1 027

-12.0%

<30

2 585

2 562

2 565

2 841

3 35

2 393

0.9%

[30-50[

8 320

8 647

7 919

9 872

10 648

9 318

-3.8%

4 783

4 534

5 532

4 618

4 583

4 35

5.5%

42

42

42

41

41

41

0.0%

Permanent

14 64914 45014 95615 96916 84

14 685

1.4%

Temporary

1 039

1 293

1 060

1 362

1 681

1 376

-19.6%

449
201
235

148
197
221

193
213
201

275
230
205

453
254
180

339
215
163

203.4%
2.0%
6.3%-3.1 p.p.

Other
Breakdow n by age

Number

>=50
Average age
Breakdow n by contract type

Years
NumberTrainees
Employees w ith w orking hours reduction
Disabled employees

NumberNumberRecruitment rate

Percentage

9.7%

12.8%

9.7%

6.4%

12.5%

12.3%

Internal mobility rate

Percentage

15.3%

14.7%

16.3%

20.7%

16.3%

16.6%

0.6 p.p.

Leaving rate

Percentage

10.2%

13.7%

17.5%

13.8%

11.9%

11.0%

-3.4 p.p.

Free association (4)Percentage

Employees under Collective Work Agreements

99.7%

99.7%

99.6%

99.8%

99.7%

99.7%

0.0 p.p.

Union Syndicated Employees

74.1%

74.0%

75.0%

77.0%

76.9%

78.6%

0.1 p.p.

Hygiene and safety at w ork (HSW)
HSW visits

Number

203

182

331

186

184

159

11.5%

Injury rate (5)

Index

1.95

1.85

1.99

2.19

2.42

1.99

5.4%

Death victims

Number

0

0

0

0

0

0

Absenteeism rate

Percentage

4.6%

5.1%

5.4%

6.3%

4.8%

4.3%

0.6 p.p.

Ratio

1.3

1.2

1.2

1.3

1.3

1.3

8.3%

tCO2eq

11 81312 71038 61149 30750 71450 588-24.4%

MWh

47 76046 46443 75059 21462 52759 664-10.4%

Production of w aste (7)

t

1 117

1 216

1 141

768

617

677

-9.8%

Water consumption (7)m3

201 017176 288

163 747

208 817276 46281 666-1.8%

Low est company salary and minimum national salary
ENVIRONMENT ( 6 )Greenhouse gas emissions (7)Electricity consumption (7)SUPPLIERS
Time of payment and time contractually agreed, in Portugal

Ratio

1

1

1

1

1

1

0.0%

Purchase from local suppliers

Percentage

90.3%

90.5%

92.3%

92.2%

91.4%

92.2%

-0.2 p.p.

DONATIONS

Million euros

2.4

2.3

2.7

2.0

2.1

2.0

4.3%

(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) 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.
(6) Data w ill include Mozambique in 2023 adjusted.
(7) In order to ensure proper comparability betw een indicators, for the purposes of calculating the 2023/2022 variation, the 2022 reporting scope w as maintained, i.e. Mozambique operations w ere not included..

122023 SUSTAINABILITY REPORT

Highlights
Distribution of employees by gender

Donations
Donations(Percentage)(Million euros)
2,7

55%

2,4
45%
2,3

Men

2021

2022

Women

2023

GHG Emissions*

Total of energy consumption*(TJ and MWh/employee)(tCO2e and tCO2e/employee)

100 000

4,5

90 0004,080 0003,570 000

2.9
3,0

3,5

3,4

60 0003,04

2,550 0002,0108

40 000

70

82

1,5

0.9

30 000251

20 000243

31 440

0

2022

1,0

2023

0,5

6 896

7 769
4 543

5 756
5 202

2021

2022

2023

10 000

2021

0.7

232

Direct Energy

Indirect Emissions (Scope 2 - Market-Based)

Indirect Energy

Direct Emissons (Scope 1)

Electricity consumption (MWh) by employee **Total emissions by employee* In 2023 Mozambique was included in the reporting scope.
** Public Grid electricity consumption per employee.

13

0,0

2023 SUSTAINABILITY REPORT

MAIN
EVENTS

Total energy consumption (1) GRI 302 -1

14

2023 SUSTAINABILITY REPORT

MAIN EVENTS 2023
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•

panels and plants with differentiatedconditions, promoting the transition to a
decarbonised and environmentally responsible
economy.

Bank Millennium, in Poland, is part of the
Warsaw Stock Exchange's WIG-ESG index, in
consideration of the work developed within theenvironmental, social, economic and corporate
governance dimensions;•

Inclusion, for the fourth consecutive time, in the
Bloomberg Gender-Equality Index, joining thegroup of companies that globally stand out inthe implementation of gender equality,
diversity and inclusion practices and policies;•

Bank Millennium, in Poland, recognised as a
"Climate-Conscious Company 2022" following
the Climate Consciousness Survey of Companies
listed on the Warsaw Stock Exchange;•

Innovation Awards 2023 award EDIGMA,
responsible for implementing the new museum
experience, the award for best project in the“Smart Building” category for the work
developed at the Rua dos Correeiros
Archaeological Center (NARC).

MARCH
•

The Millennium bcp Foundation supports the
Junior Achievement Portugal (JAP) Learning and
Venturing programme, encouraging theentrepreneurial spirit among more than 900
university students;•

Millennium bcp launches "Green CPI", a productaimed at promoting "green" property
construction or urban regeneration in line withcircular economy principles;•

BCP Group joins the "Supplier Engagement"
programme of the CDP - Carbon Disclosure
Project for the first time, in recognition of thework carried out with its suppliers to promoteclimate/environmental action in the supply
chain.

APRILFEBRUARY•

Millennium bcp, for the 3rd time, and now also
Bank Millennium, in Poland, featured in the"Europe's Climate Leaders" of the Financial
Times and Statista, as two of the 500 European
companies with the greatest reduction in CO2emissions;

Fundação Millennium bcp continues to support
the GOS - Management of Social Organisations
programme (25th and 26th editions), developed
by AESE Business School in partnership with
ENTRAJUDA (Lisbon and Porto);•

Millennium bim, in Mozambique, supports the“Biodiversity Wall” (Muro da Biodiverside), an
initiative which aims to promote the painting ofaround 40 murals about Mozambique's wildlife,
marine life and flora;•

Millennium bcp installs the 2nd photovoltaic
solar power plant on the TagusPark premises, aunit which, with its 1,834 modules, increases the
Bank's energy autonomy and avoids the annual
emission of 275 tCO2;••

Bank Millennium, in Poland, launches credit
products for the installation of photovoltaic

Millennium bim, in Mozambique, contributes toimproving the quality of the health system andsupports the “National Plan for the Screening
and Treatment of Children with Laryngeal
Papillomatosis”, implemented by Massala Associação de Médicos no Abraço aMoçambique.

•

Attribution of Rui Osório de Castro Award/
Millennium bcp by Fundação Millennium bcp(7th edition), honouring the development ofinnovative projects and initiatives in the area ofchild cancer;•

15

2023 SUSTAINABILITY REPORT

MAY

and self-esteem;•

Millennium bcp is once again associated withthe “Portugal Chama” campaign, an initiative of
the Portuguese State aimed at contributing to
the prevention of rural fires and raising publicawareness about risk behaviour;•

Bank Millennium in Poland, recognised again as"Best Employer 2023" in the 3rd Forbes andStatista rankings, ranking second in the financial
sector;

•

•

JULY
•

15th edition of the Millennium Festival ao Largo,
an annual free-of-charge initiative that presents
on stage, in Lisbon's Largo de S. Carlos, a variety
of symphonic music, opera and ballet
performances;•

Bank Millennium in Poland, one of the leading
companies in the management of Corporate
Social Responsibility policies and practices,
returns to the Top 10 of the Responsible
Business Forum's ranking of Socially
Responsible Companies in 2023;•

Millennium bcp creates a bicycle parking area
(BIKE Park) at its Taguspark facilities, with theaim of promoting smooth and sustainablemobility for its workers;•

Millennium bim, in Mozambique, supports an
initiative to rehabilitate 41 health centres in theprovince of Zambézia destroyed by Cyclone
Freddy, in partnership with the NGO Friends in
Global Health (FGH).

Millennium bcp, together with its Foundation,organises an action to collect donations infavour of UNICEF and the victims of theearthquakes in Turkey and Syria.

JUNE
•

•

•

•

Millennium bim, in Mozambique, is supporting,in partnership with the Khanimambo
Association, the painting of a mural as part ofWorld Albinism Awareness Day, an initiative toraise awareness of the challenges faced bypeople with Albinism in Africa.

Bank Millennium in Poland has joined the UN
Global Compact, a benchmark for responsible
business practices, incorporating its 10
Principles - human rights, labour relations,environmental protection and anti-corruption into its strategies, processes and operations;
For Global Finance magazine, Millennium bcp isagain the best Bank for Sustainable Finance inPortugal, in recognition of its leadership in
financing projects that fight climate change andimprove people's quality of life;
Bank Millennium in Poland awarded for theeight 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;

AUGUST•

Millennium bim, in Mozambique, in partnershipwith the Ministry of Education and the Helpo
Association, promotes learning activities formore than 600 vulnerable children fromdifferent regions of the country, encouraging
interpersonal relationships, respect, tolerance

Millennium bim, in Mozambique, promotes the
12th edition of the "Banking Olympics", afinancial literacy project that aims to contributeto the education and training of young
Mozambicans by presenting banking andpersonal finance management concepts, as wellas sustainability and entrepreneurship.

In 2023, we continued to work alongside local communities to create social value andprotect the environment and nature16

2023 SUSTAINABILITY REPORTSEPTEMBER•NOVEMBER•

Fundação Millennium bcp supports the 15th editionof the TODOS Festival - Caminhada de Culturas 2023,
an initiative of the Lisbon Municipality that promotes
an intercultural city through contemporary
performing arts.

Millennium bcp and the European Investment Fund
(EIF) sign a 405M€ InvestEU agreement to support
Portuguese SMEs in developing projects onsustainability, innovation and digitalisation, social
entrepreneurship and microfinance, culture,
education and competitiveness.

OCTOBERDECEMBER
•

•

•

•

•

Millennium bcp sees green financing highlighted as a“good practice” in the 2nd Report “Observatory of
the SDGs in Portuguese Companies”, by the Center
for Responsible Business & Leadership of the Católica
Lisbon School;
Millennium bim, in Mozambique, promotes the 16thedition of the Minibasket Tournament as part of its"Mais Moçambique pra Mim" (More Mozambiquefor Me) Social Responsibility programme, which took
place in 13 cities in the country, involving around
1,230 children aged between 6 and 11;
Millennium Volunteers, in the context of Millennium
bcp's annual Social Responsibility plan, this time with
Bipp/SEMEAR in yet another outreach initiative tosupport the integration and employability of people
with special needs;
Millennium bim, in Mozambique, delivers, as part ofthe "Mais Moçambique Pra Mim" (MoreMozambique for Me) programme, kits of school
materials to more than 1,000 children at Marrocane
Primary School, in Cabo Delgado, helping to improve
the teaching and learning conditions of displacedchildren and victims of the humanitarian crisis in theregion;Millennium bcp recognised for 18 years ofparticipation in the United Nations Global Compact which in 2005 was one of the first Portuguese
companies to join this global commitment - and for
its adherence to its 10 Principles.

•

Bank Millennium in Poland, was again awarded withthe title of "Europe's Diversity Leader 2024", aranking produced by the Financial Times and Statista,remaining in the group of European employers that
promote and support diversity in their organisations;•

Millennium bcp sees its Corporate Social
Responsibility (CSR) programme “Millennium
Solidário 2023” distinguished by the Fosun
Foundation as part of the sixth edition of “ONEFOSUN CSR Week”, an initiative that aims to publicise
and recognise the CSR programmes or actions ofcompanies owned or participated by Fosun;•

Millennium bank, in Poland, publishes the newedition of the "Millennium Eco-Index", a report thatsummarises the eco-innovation potential of Polishprovinces and their involvement in the country's
green transformation and the implementation ofsustainable development strategies;•

The "Millennium Solidário: Natal 2023" Social
Responsibility Campaign brings together the Bank's
employees and the Millennium bcp Foundation to
support people with cancer through donations to the
IPO - Instituto Português de Oncologia (Portuguese
Oncology Institute) and the ACREDITAR Association;•

For the 10th year running, Millennium bcp is taking
part in the six-monthly food collection campaigns
organised by the Food Bank, with more than 130
volunteers nationwide.

A benchmark bank - in Portugal, Poland and Mozambique - at the service of the economy,society and families

172023 SUSTAINABILITY REPORTINTRODUCTION

18

2023 SUSTAINABILITY REPORT

Introduction
Banco Comercial Português (BCP) 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 20th edition,
continues to offer a global and integrated vision oftheeconomic,socialandenvironmental
performance of the BCP Group, as well as details ofeach of its main operations in Portugal, Poland andMozambique.
Relating to the formats adopted and after the issueof autonomous Reports from 2004 to 2008, theBank decided, in 2009, to include in Volume I of theAnnual 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 thesustainable 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 supplementary 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 inthe Bank's Annual Report and it published again - ina separate and independent volume only available
in digital format - a voluntary document detailingthe 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 andinformation on diversity by certain large
companies, transposing the NFRF - Non-Financial
Reporting Directive of the EU, the Millennium bcp
kept, between 2017 and 2020, a dual format,
materialised in the summary information includedin the chapter of the Annual Report - Non-financial
Statement - and in the detailed information in the
Sustainability Report.
Given our interpretation of the trends andguidelines 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 toconcentrating all non-financial information andindicators in the Sustainability Report in 2021.

This document, which covers all the geographic
regions of the BCP Group, intends to continue tomeet the expectations of stakeholders, identified
through regular thematic materiality analyzes andthe continuous feedback received through theavailable platforms, channels and communication
flows.
This document was made in accordance with theprinciples set forth by the GRI (Global Reporting
Initiative), for the option “in accordance core” andrespective supplement of the financial sector, theprinciples of inclusivity, thematic materiality andresponsiveness of the Standard AA1000APS (2008)and verified by an external entity in c ompliancewith 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 theend of the report - under Methodology. The
complementary information reported, namely thetables relating to: (i) GRI indicators, including
correspondence with the United Nations Global
Compact Principles; (ii) Sustainability AccountingStandards Board (SASB) indicators; (iii) UN Guiding
Principles Framework (Ruggie Framework); (iv)alignment with the recommendations of the Task
Force on Climate Related Financial Disclosures(TCFD); (v) alignment with the Comissão de
Mercado de Valores Mobiliários (CMVM) (Securities
Market Commission) guidelines for non-financial
reporting; (vi) the European Union (EU) Taxonomy;(vii) the UNEP FI Principles for Responsible Banking(PRB); and now also, as part of the preparation for
the evolution towards the new reporting rules on
Sustainability matters applicable to the next annual
cycle; (viii) the relationship with the Corporate
Sustainability Reporting Directive (CSRD) and theEuropean Sustainability Reporting Standards(ESRS), 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) theMillennium bcp Annual Report, (ii) the Bank
Millennium Annual Report and Bank Millennium
ESG Report, (iii) the Millennium bim Annual Report,(iv) the Millennium bcp Foundation Annual Reportand (v) Bank Millennium, covers the disclosure, in
its different dimensions, of the relevant
information on the performance of the BCP Groupon the issues identified in the thematic materiality

192023 SUSTAINABILITY REPORT

matrix available in the chapter "Relationship with
Stakeholders".

sector;The BCP Group, a signatory of the United Nations
Global Compact since 2005, recognises theimportance of the Sustainable Development Goals(SDGs) and the United Nations Agenda 2030 and,
therefore, throughout this document the mostdirect contributions of BCP Group's activity to theirpursuit are identified.

•

EU Regulation 2019/2088 concerning
disclosure of sustainability-related information in the financial services sector (SFDR - Sustainable Finance Disclosure Regulation), adopted by the European Union in November 2019, whichaims 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 theSFDR, effective from January 2023, requires financial market participants todisclose information on the integration of "sustainability risks" into theirinvestment decisions and the "major
adverse impacts" of those decisions onenvironmental and social criteria, anddisclosure of financial products that
promote "E" and/or "S" characteristics
or have a sustainable goal. Also from2023, the reporting duty includes entity and product information, on thewebsite, in pre-contractual 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 consists of aclassification system for “green” activities that translates the European Union's (EU) climate and environmental
goals into objective criteria. The Taxonomy lists the economic activities
considered to be green or environmentally sustainable. These economic activities make a substantial contribution to one or more of the EU's climate
and environmental objectives: Climatechange mitigation, Climate Change Adaptation, Sustainable use and protection of water/marine resources, Transition to a circular economy, Pollution
prevention and control and Protection
and restoration of biodiversity andecosystems. Financial entities must report their alignment with the taxonomy in 2024 (compared to fiscal year2023), for the environmental objectives of Climate Change Mitigation and
Adaptation. One of the main indicators
to be reported is the GAR - Green Asset
Ratio, i.e. the proportion of assets that
finance and invest in economic activi-

European Regulatory Agenda
The national and European regulatory context on
Sustainability matters, including those related tosustainable finance, is today, as a result of anaccelerated legislative dynamic, more complex,
demanding and multidisciplinary. The set ofprogressively extended ESG (Environmental, Socialand Governance) guidelines and obligations with an
impact on the governance model, value propositionand corporate reporting practices on non-financial
information requires from organisations apermanent ability to adapt and adjust in order tomeet the new requirements and expectations ofstakeholders.
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 bylarge companies and groups of non-financial information and diversity information (NFRD - Non-Financial Reporting Directive), published in October 2014, which requires a set of organisations to report non-financial information, namely information on social and environmental performance,transposed into Portuguese law
through DL no. 89/2017;•

The Paris Agreement, promoted by theUnited Nations and signed in December 2015, is a climate change action
plan aimed at limiting global warming
to well below 2°C compared to pre-industrial levels and endeavouring tolimit the increase to 1.5°C, ratified by
all the countries of the European Union;•

Sustainable Finance Action Plan,
launched by the European Commissionin 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

202023 SUSTAINABILITY REPORT

ties aligned with the Taxonomy in relation to the total assets covered, which
will make it possible to assess the extent to which banks' assets contribute
positively to the Taxonomy's goals;
•

•

•

•

the report referred to in Article 98(8)of Directive 2013/36/EU. To this end,
the Bank is preparing for the annual
market discipline disclosure (with reference to December 2023) the response to the reporting obligations
contemplated in the Taxonomy regulation and, in the half-yearly disclosure,with reference to June 2024, the complete response to the Pillar 3 ESG disclosures that will reflect advances in
the measurement, management andmonitoring of climate, physical andtransition risks;The proposed Corporate Sustainability
Disclosure Directive (CSRD), publishedin its final version in December 2023
by the European Commission, replaces
Directive 2014/94 (NFRD) and now requires a wider range of companies topublish non-financial information on
their performance in accordance with
the European Sustainability ReportingStandards (ESRS), adopted in the formof a delegated regulation in July 2023.
The CSRD will require all large companies and listed SMEs to disclose how
sustainability issues can affect themand society/environment and also todisclose 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 theirdecision-making processes and that information on identified climate risks
should be reported;
Fit for 55 is a European Union package
proposed in July 2021 by the European
Commission. It is part of the European
Union's Green Deal strategy first presented in December 2019 and aims to
reduce the European Union's greenhouse gas emissions by 55% by 2030.
In the context of this plan, Millennium
bcp took part in an EBA climate stresstest exercise whose main objective is
to test banks' progress in terms of datacapabilities (and the comprehensiveness of available data); the final results of this exercise will be publishedby the end of 2024;
Risk disclosure - Pillar 3 Report - Disclosures on ESG risks - from 28 June
2022, large institutions that have issued securities admitted to trading ona 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

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 toprovide 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 inenvironmental, social and governance issues, atnational and international level, in line with theprovisions of the Non-Financial Reporting Directive(NFRD), transposed to the Portuguese legal system
by DL. no. 89/2017, and already anticipating theguidelines 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 thetargets defined under the United Nations SDGs,
adapting to the new European Union (EU) guidelinesonnon-financial
reporting,includingtherecommendations of the Task Force on ClimateRelated Financial Disclosures (TCFD), aligning w ith
the Regulations aimed at "Establishing a regime forthe 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

21

2023 SUSTAINABILITY REPORT(SBTi) and aligned with the Paris Agreement is also
under assessment.
The Bank considers that it plays a relevant role inthe compliance with the national and internatio nal
commitments, recognising the importance of theinvolvement and alignment of the financial sector
in the transition into a sustainable and inclusive
economic development model. In terms of climatechanges, 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. As far as ethical andresponsible 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 thescope of Human Rights, Working Conditions,
Environmental Protection and Anti-Corruption.

On issues related to Sustainable Finance, the Bank
monitors developments in the legal and regulatoryenvironment of the financial sector (namely the
diplomas resulting from the European Commission's
Sustainable Finance Plan and the guidelines definedby the European Central Bank and the European
Supervisory Authorities) and participates in various
national and international working groups on theseissues.
Additionally, BCP Group has been ensuring an increasingly effective alignment between its businessprocesses and support operations with the ESG (Environmental, Social and Governance) areas and thisis 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.

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, inPortugal, the CMVM. This report also includes
reporting on Human Rights in accordance with the
UN Guiding Principles Framework.

22

2023 SUSTAINABILITY REPORT

Sustainability Policy
The BCP Group pursues dynamic strategies adapted to the new challenges imposed by the several interested parties withwhich it establishes relations. The main objective 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, biodiversity and the environment.
Within this context, the Bank’s intervention is focused on three fundamental axes:▪

▪
▪

Environment - implementation of measures that promote a fair and inclusive transition to a decarbonised economic
development model, including the incorporation of the environmental component in the Bank's risk models andthe supply of products and services;
Social - involvement with the external community and with the internal community in the creation of lasting
relationships of proximity and cooperation and creating shared value;
Corporate governance - integration of sustainability principles into the Bank's decision-making processes and in thedefinition of its value proposal.

Thus, Group BCP assumes, as an integral part of its business model, the objective of creating social and environmental
value by developing actions to - and with - the various stakeholder groups, with the goal of contributing to thedevelopment of the countries in which it operates.

ESG Ecosystem232023 SUSTAINABILITY REPORT

Partnerships
Millennium bcp, aware of the importance of sharing good practices, public testimony and of an active participation in
the pursue of Responsible Business Principles, is an associate founder and a member of the corporate bodies(Management, Executive Secretariat and Advisory Board) in the 2022-2024 term-of-office of the BCSD Portugal Conselho Empresarial para o Desenvolvimento Sustentável, an association part of the network of the WBCSD - World
Business Council for Sustainable Development.
Since 2005, it has also, as a signatory to the Principles of the United Nations Global Compact, a member of the Global
Compact Network Portugal (GCNP) and, in a logic of proximity and support to the surrounding communities, of the Oeiras
Solidarity Programme (POS).
As part of the development and increase of the impact of its Corporate Social Responsibility (CSR) policy, Millennium bcp
and its Foundation maintain cooperation and partnership protocols, which allow, through voluntary actions, to createsocial and/or environmental value and contribute to the protection of the most disadvantaged segments or those withspecial needs of the Portuguese society, with the following institutions: (i) Food Bank; (ii) Entrajuda; (iii) C.A.S.A - Centro
de Apoio ao Sem Abrigo; (iv) BIPP - Inclusão para a Deficiência / Semear; (v) EPIS - Associação Empresários pela Inclusão;and (vi) Brigada do Mar.

Work and Reflection Groups
Millennium bcp also participates in a selected number of work groups and discussion forums on Sustainability andSustainable 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 evolution of the risk and business management
practices applicable to ESG issues, in what also represents an opportunity to re-assess impacts, anticipate trends andreinforcing competences and project future transformations.
Accordingly, 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)
Reporting and Sustainable Finance of BCSD Portugal, where it is one of the promoters of the website
www.sustainablefinance.pt, and (iv) the Specialised Committee on Sustainable Finance ISO/ TC 217 of the APEE Associação Portuguesa de Ética Empresarial and the ISO - International Organization for Standardization.
It also a member of: (v) the Technical Debate Group for Sustainable Financing in Portugal from the Ministry ofEnvironment; (vi) from the Specialized Committee for Sustainable Finance and Sustainability from AEM - Associação de
Empresas Emitentes de Valores Cotados em Mercado S.A., (vii) the Task Force on Taxonomy from APB and (viii) theInternational 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, the Bank joined the (x) Sustainability Working Group of the Business Roundtable Portugal Association (BRP) and,already in 2024, (xi) the APB Working Group on Prudential Treatment of ESG risks.

24

2023 SUSTAINABILITY REPORT

Governance Model
Material issue:

SUSTAINABILITY GOVERNANCE

In recent years, Millennium bcp has significantly
strengthened its governance model for the themesof Sustainability and Responsible Business.
In this context, in 2020, within the scope of the
Sustainability Master Plan (SMP) Millennium bcp
created the Sustainability Commission (Regulationsof the SC), a body with powers delegated by the
Executive Committee (EC) and chaired by the CEO,which is responsible for assessing, following up andmonitoring the implementation of Millennium bcp's
Sustainability strategy - which includes the
economic, social, environmental and climate change
dimensions - having, specifically, the following tasks:▪
▪

▪

Advise the EC in the integration of Sustainability principles (Environmental, Social and Corporate Governance) inthe Bank's decision-making and management processes;
Analysis and approval of the initiatives necessary for the implementation of actions aimed at materialising thestrategic axes and lines of action of the SMP in force, as well as other amendments or adaptations necessary forthe 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.

The Committee for Corporate Governance, Ethics and Sustainability (CCGES), within the scope of the powers delegatedby the Board of Directors and in accordance with its Regulations, is the 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 inmatters of corporate governance and sustainability and also for monitoring the evolution of the Sustainability andCorporate Social Responsibility Master Plans and issuing an opinion on the annual corporate governance andsustainability reports.
Likewise, the Committee for Risk Assessment (CRA), within the scope of the powers delegated by the Board of Directors
and in accordance with its Regulations, is responsible for monitoring the material management process of risks to which
the Bank is subject to, through appropriate indicators and metrics, including, among others, the new ESG risk factors,
which include climatic ones.
The Regulations of the CCGES and the CRA, updated as of 12/31/2023, are available on the Bank's website, on: Articles
of Association and main internal regulations of the BankTo ensure that the management bodies, namely the Board of Directors, have the appropriate knowledge for an effective
management of sustainability issues, in 2023, the training plan on these matters continued, of which we point out thecourse on Sustainable Finance, organized together with ISEG and lectured by Prof. Sofia Santos.

BCP Group also assumes, in an ongoing dialogue with its Stakeholders, a set of corporate policies and principles - most25

2023 SUSTAINABILITY REPORTof them revised in 2023 - namely:i. Sustainability Policy;
ii. Environmental Policy (v.2021);
iii. Social Impact Policy;
iv. Human Rights Policy;
v. Diversity and Equal Opportunity Policy;
vi. Occupational Health and Safety Policy (v.2021);
vii. Corporate Volunteering Policy;viii. Anti-Corruption and Anti-Bribery Policy;
ix. Principles of responsible financing: excluded and conditioned projects;
x. Sustainability Guidelines for Suppliers;
xi. Tax Policy.

More information about the organisational model of the 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 relatedwith sustainability and also managing the physical and transition risks of its portfolio, to assert itself as a reference in themarket. 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).
In addition, the Bank continues to explore partnership alternatives to enlarge 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 themin their green transition process.
Seeking to become the principal partner for the energy transition and mitigation of physical risks, 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 to achieve are in line with the aspiration to affirm itself as a reference inPortugal, in this domain, during the cycle of the 2021/ 2024 Strategic Plan: average of the ratings of the three mainindexes (CSA S&P, CDP and MSCI) above 80%, keep all its premises in Portugal operating with totally renewable energies(which has been happening since 2021) and reduce the exposure to sectors with a significant use of coal.

26

2023 SUSTAINABILITY REPORT27

2023 SUSTAINABILITY REPORT

Commitments
The BCP Group's position regarding the management of ESG issues is reinforced by the adherence and subscription to aset of external commitments and initiatives, through which efforts are maximized towards a common purpose - promotesustainable development.
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 establishing a set of values in what concerns Human Rights, Labour Conditions,Protection of the Environment and Anti-corruption.
In 2019, within the scope of the “Think tank on sustainable funding in Portugal”, promoted by the Ministries ofEnvironment, Economy and Finances (within the context of the Route to Carbon Neutrality in 2050), which had theparticipation from the major banks that operate in the market, supervisors and sector associations, two reference
documents were produced: (i) “Guidelines to accelerate sustainable funding in Portugal”; and (ii) “Engagement Letterfor the Sustainable Funding in Portugal” - subscribed by Millennium bcp -, that seek to highlight the importance, widelyconfirmed in the meantime, of including environmental, social and governance risks in the financial sector's decisionmaking and risk management processes and which continue to constitute guidelines for the Bank.
In 2020, Millennium bcp also subscribed to the "Lisbon European Green Capital Commitment", promoted by CML Municipality of Lisbon (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 tofoster a collective dynamic to meet the targets set by the Paris Agreement and accelerate the path to carbon neutrality.
In 2019, the Bank also joined the “Business Mobility Pact for the City of Lisbon”, a joint initiative from the Lisbon City
Council, the WBCSD - World Business Council for Sustainable Development and from BCSD Portugal, that aggregates ina 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.

282023 SUSTAINABILITY REPORT

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 promotionof the human rights in the organizations and in their value chains.
To further enhance its commitment with human rights and an ethical and inclusive management, in 2020, BCP signed
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 governancepractices, 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 civilsociety 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 Global Compact of the United
Nations, an important international platform for the promotion of gender equality that translates our long-term viewand the will to be part of - and encourage - a collective dynamics based on cooperation and trust. Since 2017, Millennium
bcp has also been part of iGen – Organizations for Equality Forum, an initiative that brings together private, public andsocial companies in the promotion of decent work.
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 clients, suppliers and by the society ingeneral for the adoption of 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.
In 2023, Millennium bcp subscribed to the Code of Ethics of APCADEC – Portuguese Association of Purchasing andProcurement, which brings together a set of values, principles and guidelines aimed at Procurement professionals.
A table identifying the main commitments, the proposed targets and their degree of achievement is available in Annex
9 of this Report.

Millennium bcp is committed to a fair and inclusive transition to decarbonizeddevelopment models in line with the Paris Agreement292023 SUSTAINABILITY REPORT

Sustainable Development Goals (SDG) of the United Nations

The Sustainable Development Goals (SDG) of the United Nations, approved in September 2015, represent the greatest
global voluntary commitment– adopted by all 193 UN member States in 2015 - and thrive at improving the quality of lifeof the world population in the social, environmental and economical components, until 2030.
Focusing on five fundamental pillars – Planet, People, Prosperity, Peace and Partnerships – the SDGs, established within
the framework of the 2030 Agenda for Sustainable Development, constitute an urgent call to action by all countries –developed and developing – for a global action partnership for a more sustainable future.
The 17 goals and the 169 targets that constitute them thus represent an opportunity to improve the quality of life ofsociety, through global mobilization to eliminate extreme poverty and hunger, provide quality education, protect theplanet and promote peaceful and inclusive societies.
Considering that its pursuit requires a joint effort bystates, civil society and private entities, including
companies, the Bank is committed to working actively
for sustainable, socially inclusive and environmentally
responsible development in all the geographies in which
it operates, in particular in relation to people, whether
they are workers, customers, partners or members ofsociety in general.
The justification for Millennium bcp's involvement inachieving the SDGs can be found, first and foremost, inthe Bank's matrix and values, in particular its relationshipof 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 ofservice to the Customer and to the communities in which
it operates.
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.
To be more effective in these matters, the Bank regularly reflects on the commitments advocated by the SDGs,
establishing priorities that take into account the impacts that arise from its activity and those that affect its potential forvalue creation. In 2023, in the context of carrying out the regular stakeholder consultation process, BCP reviewed theSDGs to which its contribution should be preferably directed. Thus, are now considered, as a priority for the
implementation of the 2030 Agenda for Sustainable Development, the SDG 4 - Quality Education, 7 - Affordable and302023 SUSTAINABILITY REPORT

Clean Energy, 8 - Decent Work and Economic Growth, 10 - Reduced Inequalities, and 13 - Climate Action.
This Report includes a vision of the Bank's effective contribution to the achievement of the SDGs and how the alignment
between its value proposition in the different operations and the needs and expectations of stakeholders is ensured.

Principles for Responsible Banking (PRB)
Within the context of Sustainability Master Plan (SMP), 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 theplanet. By joining UNEP-FI and subscribing to the PRB, Millennium bcp is committed to putting sustainability at the heartof its strategy, integrating these Principles in its value proposal, processes and operations, in the different business andgeographic areas.
In June 2022, the Bank formally joined the PRB and published a voluntary preliminary review of the application of the
Principles in the 2022 Sustainability Report. In the 2023 Sustainability Report, Millennium bcp publishes its first mandatory
report in response to the PRB, following the template provided by UNEP-FI - the Principles for Responsible Banking
Reporting and Self-Assessment Template (please see Annex 7).
In this 1st mandatory report, Millennium bcp details its contribution to the six Principles: 1) Alignment; 2) Impact and Target
Setting; 3) Clients and Customers; 4) Stakeholders; 5) Governance and Culture; 6) Transparency and Accountability. To
respond to Principle 2 (Impact and Target Setting), the Bank used the impact analysis tool provided by UNEP-FI - PRB
Portfolio Impact Analysis Tool (v.3) - and carried out an assessment of the positive and negative impacts of its activities in
Portugal. Based on this analysis, the Bank has identified three main topics of impact for its activities: Climate Stability,
Resource Intensity, and Housing.
In 2024, Millennium bcp will continue this analysis, defining additional targets and incremental evolution implementationplans for each of its main impact topics. The Bank intends to publish the disclosure reports proposed by the PRB, detailingtheir progress on each of the six Principles, in line with its annual non-financial reporting cycle.

Corporate social responsibility must be an accelerator of a new "social contract", fair andinclusive, which, by putting People at the centre, protects the planet, the climate andbiodiversity312023 SUSTAINABILITY REPORTManagement of ESG risks
BCP has an annual process to identify, assess and manage the main risks to which it is exposed to. ESG risk factors,
which have gained increasing relevance within the scope of the Bank's activity, both through the densification of thelegal, regulatory, and supervisory framework and requirements, and through the deepening of good practices in termsof risk management, are part of this process and are assessed in terms of their potential impacts on traditional risk
categories (such as credit, operational, liquidity, and market).
During 2023, the Bank renewed and strengthened its risk identification and assessment exercise with a focus on the
ESG component, having reviewed existing methodologies and followed the most advanced practices available in themarket – contemplating scenarios (thus ensuring a forward-looking view of the expected impacts), as well as the transmission of ESG risks to traditional categories (and the business) and, also, the inclusion of all the Group's exposures.
The results of the year are integrated into the Bank's day-to-day operations through the definition of actions for its
management and mitigation, and the identification of business opportunities that result from the dynamics of the transition to a low-carbon economy.
BCP's priorities and ambitions in terms of the management of social and environmental risk factors are addressed in its
Sustainability Master Plan, with lines of action and actions very focused on the integration of risks in the business,among which the following stand out:
▪

▪
▪
▪

Continue to assess the impact of climatic and environmental, physical and transition factors on the various
types of risk, using internal information that supports the adoption of quantitative models in the short/medium term;
Continue the implementation of a framework for the management and control of climate and environmental
risks;Develop tools that support the Balance Sheet alignment exercises (e.g., transition planning) and the projection of the respective business impacts and risk appetite;
Operationalize the capacity for scenery and climatic stress tests.

More detailed information on climate, nature and biodiversity-related risks is presented in the chapter "Environmental
Liability".

The risk management policy is being adapted and improved, reflecting thestrategic priority that the Bank attributes to ESG themes322023 SUSTAINABILITY REPORT

Sustainable Finance Disclosure Regulation (SFDR)The Sustainability and ESG factors are becoming increasingly relevant for society, Customers and for our business. Inline with the commitment to promote a culture of environmental, social, and financial responsibility, namely in the fightagainst climate change and social inequalities, BCP Group has been working to disclose relevant information 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).
The SFDR sets out transparency rules requiring financial institutions to disclose information on the integration of sustainability risks into their processes and products, and to consider the principal adverse impacts of their investment
decisions.
In relation to financial products, with the entrance into force of this regulation on March 10, 2021, it is now mandatory
to disclose information related with sustainability on the websites of the entities and on the pre-contractual documents
and on periodical information.
The Bank has been involving the different areas of the organization in the full implementation of this regulation, frombusiness to risk and processes, and has developed a governance model for monitoring and follow-up of compliancewith the thereto related legal requirements.
It is our ambition to continue to be an active protagonist of this change and, in this sense, we continue to be committed
to providing financial products that promote environmental or social characteristics (art. 8) or may even have a sustainable objective (art. 9).
As providers of Portfolios Management and Investment Advising services, we will continue to include the risks in termsof sustainability and to consider the main adverse impacts on sustainability factors in the processes for the selection of
products used in the construction of portfolios.
Within the context of the One-off Counselling we will continue to take into account the main adverse impacts on sustainability factors in product selection processes.
In cases where, in terms of investments, the main adverse impacts on sustainability factors are not taken into account,
we ensure their respective disclosure (Interfundos).
The remunerations policy of BCP includes information on the inclusion of risks in terms of sustainability. For that purpose, it includes a set of rules of good governance, 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 theinterests of all its stakeholders, not promoting an incentive to risk-taking at levels higher than those defined by BCP,
avoiding the creation, or a contribution to the creation, of situations of conflict of interest and, contributing to the
ethical and sustainable development of the Company. In the case of the variable remuneration of the Executive Committee and of 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. With regard to the Employee Remuneration Policy, Sustainability
Risks, including climate risks, are also foreseen in corporate and individual KPIs. The qualitative assessment of Employee
performance, which considers a set of behaviors and practices, includes the Sustainability dimension.
Group BCP promotes the transparency of the reference framework applicable to ESG risks, disclosing on its institutional
website the Corporate Policies and Principles on sustainability, which seek to positively influence the long-term valueof the organization, contributing to the well-being of people and communities and to the preservation of natural resources, the environment and biodiversity.
The BCP Group is evaluated by the most relevant ESG indices and analysts (see chapter Sustainability Indices) and wecontinuously work to improve our policies, processes and operations, in order to achieve a positioning, which we want
to be a reference, in the most relevant sustainability indices.
Detailed information on the disclosure of non-financial information according to SFDR is available on the website ofMillennium, on Institutional/Sustainability/SFDR.

33

2023 SUSTAINABILITY REPORTApproach to
Sustainability |Relation with
Stakeholders

342023 SUSTAINABILITY REPORTApproach to Sustainability | Relation with Stakeholders
The BCP Group manages sustainability-related issues according to a strategic approach, integrated into its business modeland defined according to the challenges imposed on it.

Stakeholders Engagement
The Bank believes that its ability to create value depends on the establishment of strong and lasting close relationships oftrust and respect with all its stakeholders. Hence, it promotes a systematic engagement with all stakeholders, which allows
it to listen, understand and integrate their concerns, needs and expectations into the strategic business approach.

To understand the perception of its stakeholders regarding the significance of the impacts arising from the Bank's activities
and operations, a new consultation process was carried out in 2022/2023, via an online questionnaire, with arepresentative sample of the main stakeholder groups. This exercise also allowed the Bank to understand its main needs
and expectations regarding the organization's performance in terms of sustainability and served as a basis for the(re)definition of Millennium bcp's material themes, reflected in the Sustainability Master Plan (SMP).

Thematic Materiality Analysis
The sustainability thematic materiality analysis process is carried out by the Bank every two years, with the purpose of
assessing the environmental, social, economic and governance issues on which its actions should be prioritized. The
findings of this analysis guide not only the information it disseminates on these aspects, but also the development ofpolicies, strategies and action plans.
The thematic materiality analysis carried out in the 2022/2023 period followed the main regulatory guidelines, resulting
from the Corporate Sustainability Reporting Directive (CSRD), regarding double materiality, crossing the two perspectives– impact materiality and financial materiality. The process included four main stages:

352023 SUSTAINABILITY REPORT

Thematic Materiality of Millennium bcp

Size

GovernanceGovernanceGovernanceGovernanceGovernanceGovernanceGovernanceGovernanceGovernanceGovernanceGovernanceSocialSubjects

Cyber-security, privacy
andinformation
protection
Innovation
anddigitalisation
Ethics, conduct andcompliancePreventionofcorruption and money
laundering
Transparency of theinformation provided
tocustomersonproducts and services
Sustainability
Governance
Resilience of thebusiness model
Risk management
Satisfaction
andcustomer experience
Management of thebrand and reputation
Economic
performance
Attracting, developing
and retaining talent

Upstream
Subject with
impacts
upstream of
the BankBank
Subject with
impacts on
the Bank

Downstream
Subject with
impacts
downstreamof the Bank

⚫

⚫

⚫

⚫

⚫

⚫

⚫

⚫

⚫

⚫

⚫
⚫
⚫

⚫
⚫

⚫

⚫

⚫
⚫

36

Financial
Materiality

Impact Materiality

2023 SUSTAINABILITY REPORTThe identification of material issues also allows the recognition and characterization of opportunities for improvement,
which constitutes a relevant contribution to a swift strategic adaptation to new realities, challenges and impositions.

Sustainability Master Plan
Material issue:

RESILIENCE OF THE BUSINESS MODEL

Millennium bcp's approach to Sustainability in Portugal is embodied in the commitments, goals and actions defined andformalized, until 2023, in the Sustainability Master Plan. The structuring of the lines of action and the identification of theactions that make up the SMP are the result of a broad reflection on the management of relevant material issues, available
resources and the regulatory, economic and market framework.
Established for the first time in 2009 for the 2010/2012 three-year period (later extended to 2013), the Sustainability
Master Plan is frequently revised – SMP 2014/2015 (extended until 2018); SMP 2019/2021; and SMP 2022 – which ensures
greater compliance and responsiveness in the face of the context experienced at any given time.
In 2022, following the completion of the new stakeholder consultation and thematic materiality analysis process, theresults of peer benchmarking, the interpretation of external analysts' recommendations and the evolution of theregulatory framework, the SMP 2023 was defined and approved, which guided Millennium bcp's performance insustainability matters and under which the Bank implemented a large number of concrete initiatives and actions, part of
the following lines of action:
Action LineSize
i. Management of ESG risks
ii. Remuneration Policies
iii. ESG Strategy

a. Positive impact through a
responsible and sustainable
management

iv. Corporate policies and commitments
v. Sustainable Purchases
vi. Analysis of the corporate ESG performancevii. ESG Complianceviii. Senior Management's training and development
ix. Knowledge
x. Management of resourcesb. Positive impact through asustainable offer

i. Responsible and Sustainable investmentii Development of ESG productsiii. Management of the offer ESG risks

c. Positive impact on environment

i. Climate change and energy transition
ii. Reporting regulations and frameworks
iii. Training and environmental awarenessi. Training and development

d. Positive impact on people
and communities

ii. Corporate volunteer Actions
iii. Human Rights
iv. Financial Literacy
v. Partnerships for Sustainability…

…

The needs and expectations of stakeholders identified during the thematic materiality analysis process are, therefore, also
through the Sustainability Master Plan, reflected in the following goals:

372023 SUSTAINABILITY REPORTObjective
2023 Material Issues

Origin/source/

Indicator

report2022
baseline

2023
interimevolution

2024
targetEconomic performance

ROE (Group)1

Superação 24

0.04

0.055

≈ 10%

Ethics, conduct and complianceInternal Control System (ICS scoring index) (PT)2

RAS

2.2

≤ 5.5

≤ 5.5

Global Satisfaction 1st Bank NPS (Private
Customers PT)3

BASEF

Top 2

Top 2

Top 2

Satisfaction with Main Bank NPS (Corporate Customers PT)4

DATA E

Top 3

Top 4

Top 2

> 740

> 740

> 740

> 780

> 780

> 780

> 740

> 740

> 740

Satisfaction and customer experience

Cyber risk security rating (PT)5Cyber-security, privacy, andinformation protection

Cyber risk security rating (PL)5RAS

Cyber risk security rating (MZ)5
Risk management

Difference between BCP P2R and the average of comparable peers (Group)6

Sustainability Reporting

13

12

≤6

Sustainability Governance

Annual execution level of the Sustainabil- Sustainability Reity Master Plan (SMP) (Group)7
porting

0.94≥ 0.85≥ 0.85Innovation and digitalisation

Proportion of mobile customers (Group)8

Superação 24

0.63

> 65%

> 65%

Prevention of corruption andmoney laundering

No. of customers with low/medium AML
risk per 100k (PT)9

RAS

0.5

≤2

≤2

Transparency of the information provided to customers Customer complaints (BdP claims) (PT)10
about products and services

RAS

Top 6

Non-Top3

Non-Top 3

Resilience of the businessmodel

Cost-to-revenue ratio (Group)11

Superação 24

0.37

~ 40%

≈ 40%

Management of the brandand reputation

Reputation - NPS (PT)12

BASEF

Top 1

Top 1

Top 2

52

54

54

Sustainability

Attracting, developing, and reTraining (PT) 13
taining talent

Reporting

The Bank's approach to ESG issues is not, however, limited to Portuguese operations. In Poland and Mozambique, there
are multiple actions and initiatives within this framework that, articulated in the context of the BCP Group, have been
implemented over the years.

1 Excludes non-recurrent items.
2 Ability of the Bank to implement the internal control recommendations of the AAR (Annual Self-Assessment Report on the Internal Control System) each year.
3 Ranking the ‘Global Satisfaction Score 1st Bank NPS’, from the BASEF study. Values referring to the end of the year. Top6 banks (CGD, BPI, BST, NB and Montepio).
4 Ranking in the ‘Degree of Satisfaction with the main NPS Bank’ (PT Companies) from BFIN DATA-E. Annual values. Top 5 banks (CGD, BPI, BST, NB and Montepio).
5 Score of the BitSight (safety procedures, practices, and incidents).
6 CET1, Tier 1 and TCR. Variation of the annual difference BCP P2R vs. average of peers (diversified creditor).
7 Level of global execution of commitments of the SMP in terms of the Group and locally.
8 Ratio of mobile customers versus total customers.
9 Ratio between (i) SARs (suspicious activity reports) reported in the month to the authorities for low and medium risk AML customers (3-month moving average)and (ii) total low and medium risk AML customers).
10 Index that measures the relative position of comparable companies (CGD, BPI, BST, NB and CCAM) in terms of customer complaints (current accounts, consumer

credit and mortgage loans) based on data from the "Synopsis of the Behavioural Report" of Banco de Portugal.
11 Operating costs divided by net operating revenues. Excludes non-recurrent items.
12 in the ‘1st Bank Recommendation Score – NPS’ of the BASEF study. Values referring to the end of the year. Top6 banks (CGD, BPI, BST, NB and Montepio).
13Average of annual training hours per employee.

382023 SUSTAINABILITY REPORT

To maximize the efforts employed by the BCP Group in minimising negative impacts and enhancing positive ones, theSustainability Master Plan approved for 2024 foresees, for the first time, a common actions component, to which are added
the components of local actions in Portugal, Poland and Mozambique.

GROUP BCP: SUSTAINABILITY MASTER PLAN 2024

1.
2.
3.
4.
5.
6.
7.

GOVERNANCE

SOCIALENVIRONMENTAL

Transversal Actions

Transversal Actions

Transversal Actions- Inclusion of ESG criteria in the selection of suppliers;- Definition, structuring and executionof corporate social responsibility initiatives;- Implementation of a process formonitoring a set of environmental
KPIs, including consumption and emissions profiles as an "organization";- Monitoring of human rights management and reporting of the process, including identification of vulnerabilities
and improvement actions.

- C&E materiality analysis: implementation of the annual update exercise;- Sustainability Reporting: 2024 Sustainability Report;- Sustainability Reporting: other reporting requirements;- C&E materiality analysis: integrationof results in the Risk Identification Process and in the Risk Appetite Statement;8.

- Create a dashboard to monitor the
implementation of the SMP 2024
across the Group, geography anddepartments;

9.

- Prepare and approve the SMP 2025;- Setting targets and portfolio alignment exercise in accordance with Pillar
3 and science-based requirements;- Review and, if necessary, update andpublication of Policies and Principles,in accordance with the regular review
period every 2 years.

- Definition and implementation of theBank's transition plan;- C&E metrics: selection of KRIs and
KPIs for the relevant portfolios andlines of business;- Preparation of the mandatory Taxonomy reporting in 2024, in reference to2023.

In addition to the initiatives transversal to the BCP Group, the PDS 2024 includes action plans, equally distributed by theEnvironmental, Social and Economic and Governance dimensions, adapted to the reality, needs and specificities of each of
the geographies that make up the BCP Group's consolidation perimeter and that reflect its local commitments.

39

2023 SUSTAINABILITY REPORTIn the following chapters, the main actions carried out, initiatives implemented, their results and the performance achievedby Millennium bcp, during the year 2023, in the Environmental, Social and Economic and Governance dimensions, arepresented. Specific information on the themes of Governance Model, Risk Management and Shareholder Structure canbe found in the 2023 Annual Report in the Governance (and Corporate Governance Report), Risk Management and BCP
Action sections, respectively.

40

2023 SUSTAINABILITY REPORT

Economic andgovernanceresponsibility

412023 SUSTAINABILITY REPORT

Economic and governance responsibility

In all geographies where it is present, BCP Group has been developing its activity in a responsible manner towards
Employees, Customers, Shareholders, Suppliers and remaining Stakeholders, always guiding its performance by thecompliance with internal principles of rigour, the applicable legislation and the regulations issued by the supervision andregulatory authorities:

Main highlights 2023

POLAND:
Number of Employees: 6872
Training hours 335 393
Trainees: 7.324 (4.683 M, 2 641 H)
Local Suppliers: 94.1%
PORTUGAL
Number of Employees: 6242
Training hours 335 674
Trainees: 6.077 (2.727 M, 3.350 H)
Local Suppliers: 89.5%

MOZAMBIQUE:
Number of Employees: 2.574
Training hours 57.613
Trainees: 2.558 (1.363 M, 1.195 H)
Local Suppliers: 67.6%

SDG

Our objectives

Our contribution in 2023
Stimulate training actions and skills development
Initiatives:•

Developing employees'
personal and professional skills•

LEAD Development Program - integrated management program (postgraduate) developed by ISCTE in partnership with Millennium bcp for leadership development, addressing themes such as: Servant Leadership, Assertive Communication, Agility and Change,
Sustainability, Artificial Intelligence and Cybersecurity;
Millennium Campus - Bank Millennium's knowledge and skills development program,which aims to support the growth of innovation throughout the organization, through aseries of lectures. In 2022/2023, the sessions were focused on the topic of security.

Results:•••

6,258 training sessions
728 thousand training hours
46 training hours per employee | Group BCP

42

2023 SUSTAINABILITY REPORTSDG

Our objectives

Our contribution in 2023
Promoting gender equality
Initiatives:

Strengthen the Bank's
position regarding thepromotion of genderequality and non-discrimination•••

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
Stimulate discussion and reflection cycles aimed at women.

Results:•••

55% women in the total of employees
31% women on the Board of Directors
41% of women in Management positions (Executive Committee/Senior Management andManagement):o
24% in Portugalo
54% in Poland
o27% in Mozambique

42 jobs generated in Portugal in 2023 by offering microcredit
Initiatives:•
Promote financial inclusion products that support productive activities, the creation of jobs
and entrepreneurship

SAF packs (Financial Advisory Service) - contemplates solutions for restructuring and consolidation of credits, with the purpose of preserving the financial stability of individual
customers.
• Microinvest and Invest+ credit lines - to support investment projects for the creation ofcompanies by the unemployed;• KFW credit line - aimed at Mozambican Micro, Small and Medium Enterprises (MSMEs),
to finance investment in improving productivity and competitiveness and for job creation.
Results:• 61 entrepreneurs supported under the support lines for business start-up projects by the
unemployed.
Promotion of a safe and secure workplace
Initiatives:Protect labor rights andpromote safe work environments for all employees••

Medical units and a dedicated medical staff on the premises;
In-House Medical Services, with specialties such as Nutrition, Clinical Psychology andPhysiotherapy.

Results:•

203 visits by occupational safety and health officers to the premises

43

2023 SUSTAINABILITY REPORT

Millennium Network
The BCP Group has its decision centre in Portugal and is the largest private Portuguese bank, counting in 2023 around 6.7
million active Customers served by a network of 1,206 branches. The international activity of Group Millennium is carriedout 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 807 agencies.

Active Clients

Geographical decomposition of Branches(thousands)(Number of Branches)

Poland
2 757

Portugal
2 703

612
Poland399
Portugal

Macau
2

195
Mozambique

Mozambique
1 239

Active Clients: 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 an international presence by means of representation offices, branches, businessprotocols and business promoters.

In 2023, Millennium bcp registered 6.7 million active customers, of which 2.7
million in Portugal

442023 SUSTAINABILITY REPORT

Accessibilities45

2023 SUSTAINABILITY REPORTThe BCP Group seeks to be close to its Customers, providing diversified distribution channels – Branches, Internet, Call
Centre, Mobile Banking, ATM (Automated Teller Machines) and POS (Point of Sales) – in order to respond effectively,
flexibly and with proximity to the needs of Customers' contact with the Bank.

REMOTE CHANNELS AND SELF-BANKING (active users)
Internet

Call Centre

Mobile Banking

ATM (*)POS (**)

Portugal

486 476424 462

1 381 654

1 878

97 145

Poland

1 935 879

233 374

2 442 272

506

3 986

13 5471 769

854 809

465

9 496

TOTAL INTERNATIONAL

1 949 426

235 143

3 297 081

971

13 482TOTAL OF THE GROUP

2 435 902

659 605

4 678 735

2 849

110 627

MozambiqueNote: 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 AtivoBank.
(*) 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 alsoprivileged access channels for disabled or blind persons.
In Poland, the programme "Banking without Barriers" continues tobe one of the main social programmes carried out by Bank
Millennium. The idea of a bank without barriers, with products andservices accessible to all, without exception, is not only a Corporate
Social Responsibility programme, but also a philosophy of theorganisation and an important component of the Bank's businessstrategy. It is with this reference framework and the use ofinnovative technological solutions that Bank Millennium has tried
to eliminate infrastructural, digital and physical barriers, in accessto financial and non-financial services.
Facilities at Bank Millennium for customers aimed at preventing the financial inclusion of people with disabilities:
Bank Millennium's website, Millenet's internet banking system and Bank Millennium's mobile application are constantly
adapting to meet the needs of blind and visually impaired people. The contents of these websites are written in simple
language that is easy for the user to understand and can be read by automated text readers. A visually impaired user canuse the site with a keyboard - no "mouse" is required to navigate the website. In addition, the website has a text zoom
feature and is designed for high-contrast reading.
This content, in line with the plain language index (PLI), is continuously monitored, and for digital content, the standard PLI
is 60%.
Users with suitable devices can log in to the mobile app with a fingerprint or face scan. In 2023, customers also gained theability to confirm transactions requested on the mobile app through biometrics. Our mobile app is tailored to the needsof blind and visually impaired people due to its compatibility with access-enhancing services such as Google TalkBack(Android) and VoiceOver (iOS) that allow the presentation of information through speech. Customers can also count on
the help of a chatbot in the Bank's app.
Our 24/7 auto attendant can also serve as a valuable guide for daily banking. Customers can count on Milli's support on
Bank Millennium's mobile app. It is able not only to greet and answer various questions, but also to make requests, suchas sending an electronic transfer. The bank is working on solutions that use generative artificial intelligence, with the aim

46

2023 SUSTAINABILITY REPORTof meeting the standards set by market-leading voice assistants such as Siri and Alexa.
The Bank conducts educational activities in the area of cybersecurity. The communication is addressed to a variety of clientgroups, including seniors, adolescents, parents of younger children, risk groups selected on the basis of risk profiles createdat the Bank. On the website and other electronic channels, the Bank publishes alerts about new methods used by digital
criminals. Besides educational activities, technical solutions are also being introduced to further protect customers fromcybercriminals. In the fourth quarter of 2023, the Bank in Poland implemented a solution whereby a Bank Millennium
employee can confirm their identity and verify that of the customer in the Bank's app during a phone call.
ATMs and deposit machines - people with motor disabilities can use the numeric keypad instead of the function buttons
next to the screen, which means they don't need to reach very high. In addition, the ATM's numeric keypad makes it easierfor visually impaired people to use the device as well. After the headphones are connected to the ATM, the user will beable to enter instructions via voice messages. In addition, people with visual impairments can use a special black-andwhite screen mode to improve the contrast and readability of the messages displayed. 100% of Bank Millennium's own
ATMs are customized to meet the needs of people with disabilities. In April 2023, the network of deposit machines
expanded by a further 5,000 machines from the Euronet and Planet Cash networks.
Access to points of sale with architectural barriers - about 70% of the Bank's branches are accessible to people withdisabilities. By modifying and modernizing its branches, the Bank is attentive to the elimination of architectural barriers,
such as the chair-accessible service stations in these new Bank Millennium facilities.
Telephone service - customers using the Bank Hotline can use the voice command feature during the call, instead of using
the telephone keypad.
Customers with special needs are entitled to receive the general terms and conditions of contracts and articles ofassociation in formats that make it easier for them to familiarize themselves with their content, for example: a document
prepared in large font, an audio file or a file prepared in Braille.
The Bank is also extending the idea of a barrier-free world to other areas in which it operates, i.e. in the patronage ofculture. During Millennium Docs Against Gravity, Poland's largest documentary film festival, cinema films with audio
description were made available to facilitate the visually impaired to access the world of culture.
Bank Millennium is not only a financial services centre for Customers. It is also the first integrated access channel to otherservices, 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.
Ukrainian citizens, residing in Poland, can find information in Ukrainian on the Bank's website and use a special hotline
number, where they will be served in their language. Furthermore, they can fill out an online application for family benefits
and receive communications in Ukrainian about important matters such as application deadlines and cybersecurity notices.
In the BCP Group, Mobile banking solutions, which in the whole of the BCP Group already have more than 4.6 million users(4.2 in 2022), continue reinforcing their role as the preferred channel for access to products, services and financialtransactions.
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 andrequirements. Within this scope, we highlight the Branches that give access to disabled individuals, which correspond to
86% of the total network in Portugal and to 56% in the remaining countries. In Portugal, 131 branches have differentiatedoffice hours going from 8.30 a.m. to 7.00 p.m. In Poland, the number is 137 branches (it was 84 in 2022) and in Mozambique
27 (28 in 2022). We must also mention the opening of Branches on Saturday, extended working hours that, abroad, can befound at a total of 153 branches (5 less than in 2022) representing in the case of Mozambique more than 40% of total.

47

2023 SUSTAINABILITY REPORTIn Portugal, Millennium bcp continues
transforming its branch network. The Customer
Branch Experience 2.0 of Millennium bcp is aninnovative approach focused on the client, madethrough a cultural change, the re-design ofproducts and processes and the integration ofdigital channels.

Branches accessibilities(Number of branches)
1 288
1 239

875

2021

1 206

826

793

270

270

295

162

160

2022

153

2023

Total
With access conditions to people with reduced mobility
Open on Saturday
Differentiated schedule

In this new generation of Branches, paper
continues to no longer be used and theformalization documentary of agreements is
replaced by digital signatures through tablets; thetreasury activity is available 24 hours a day with thesmart transaction machines, the first to allow the
automatic payment of cheques at any time, as wellas withdrawals and deposits of coins. Thisequipment can also be used without a Multibancocard. The client only has to use the multichannel
code provided by the Bank.

Apart from the technological innovation, theBranches 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 the client 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 thecontext of the global renewal and modernization of the Branch Network, will be pursued during the next few years.
In addition, and since one of our commitments is the continuous improvement of access to digital information and use of
online banking services for people with special needs:▪
▪

▪

We have organized training on accessibility and its application on websites and Apps. These trainings
were aimed at employees with digital-related functions;
We continued with the accessibility assessment in the Millennium bcp Individuals App, with the aimof detecting points that need to be corrected in order to achieve compliance with the WCAG 2.1
double (AA) and maximum triple (AAA) criteria and, this way, facilitate the use by people with special
needs;
We observe accessibility principles based on WCAG (Web Content Accessibility Guidelines) in
Millennium bcp's email communications, in order to facilitate the reading of customers with visiondifficulties.

Also in Mozambique, as part of the initiatives to improve accessibility for people with physical limitations, Millennium bim
has adopted specific measures, which include, in the branches, the installation of access ramps and doors and spaces sized
to facilitate the movement of people with reduced mobility and, in the central services, the provision of dedicated toilets
and elevators that allow access and mobility in these Bank buildings.

48

2023 SUSTAINABILITY REPORT

Innovation
Material issue:

INNOVATION AND DIGITALISATIONThe relationship between Customers and their Bank, and with Banking in general, has been changing significantly. Thischange has several origins and explanations, of which technology and the emergence of new players that open up new
possibilities and options to bank Customers stand out.
The opportunity cost of not being part of this evolution 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 strategicplan 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.
2023 was a year during which we continued to improve the mobile-focused digital experience, with increasingly efficientand innovative digital journeys, with new features and services and, reinforcing the communication strategy, increasingly
personalized and targeted. The consistent investment that has been made in the App has allowed the consolidation of thischannel as a central platform in the banking relationship with the Customer. The materialization of this option is reflectedin the recurring leadership in the evaluation of banking Apps (IOS and Android), in which App Millennium scores 4.8, on ascale of 0 to 5, in both stores.
In Individual Customers, we kept the growth trend of the Digital Assets base, with a variation of 7% compared to the same
period of the previous year, to which the growth of 11% of users of the App channel, which already represents around 86%of the total Digital Customers, contributed decisively.
This vision of the Bank's digital transformation includes different priorities, worthy of note in 2023:
•
•

•
•

•

•

•

•

•

Accounts | it is now possible, through the App, to send a request to the employer with the account where theCustomer intends to receive his/her salary; additionally, Customers can also subscribe to the salary anticipation;
Digital Mobile Key | i) we made available the data update journey, with information collection via digital mobile key;ii) we have also made it possible to register in the App using the digital mobile key; and iii) we have improved thejourney and enriched the offer when opening an account with a digital mobile key;
Cards | new journey for ordering and issuing credit, debit and prepaid cards online with the availability of a digital
version for immediate use;
Mortgage Loans | i) launch of a new Mortgage Loan simulator, in which the advantages of applying for credit forsustainable properties are communicated. We reimburse 25% of the value of the dossier and set up fee (in the credit
for purchase or construction), as well as the cost incurred in obtaining the new energy certificate (in the credit forworks); ii) possibility of joining the 0% spread campaign;
Manage | A new area has been created that allows a detailed view of cash inflows and outflows over time, withtransactions organized into categories and information on future payments, for more effective management offinances and day-to-day operations;
Investment & Savings | i) launch of the automated investment solution in the App, which represents a significant
milestone in terms of sustainability. This product consists of an open unit-linked insurance and the investment in thefunds that constitute it will favour those that aim to make sustainable investments or that promote, among others,
environmental or social characteristics, or a combination of these, provided that the companies in which they invest
respect good governance practices. Direct investment will follow a responsible investment process defined in such a
way that the product contributes to a positive environmental or social impact or limits/mitigates negativeenvironmental or social impacts; ii) with Apparte, Customers can make financial reserves for objectives that they
define or to prepare for an unforeseen event and define the investment profile and the amount to be invested, with
the Bank ensuring all investment management;
Insurance | Móbis - Simulation and online subscription with availability of the provisional certificate at the time andthe possibility of, at any time, being able to consult all information about the insurance; ii) Pétis - Simulation andonline subscription of protection insurance for the pet dog or cat;
Re-engineering of processes | 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. Currently, the existing
service catalogue has about 771 services, of which 346 are used on a recurring basis. There are about 40,000 monthly
requests that result in 150,000 individual tasks;
Robotic Process Automation (RPA) | use of these technologies for the main credit operations, with a strong impact49

2023 SUSTAINABILITY REPORT••on energy consumption;
Reducing local printing and digitizing processes | start of operations, with opening and registration directly in 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. In 2023, the impact was highlighted by the following indicators:✓ more than 4,100 active users;✓ over 550,000 questions answered;✓ 58% automation with answer on the first question;✓ more than 7,4000 chats served, with a churn rate of only 1%;✓ NPS with a service quality rating of more than 93 index points, out of a total of about 25,000 evaluations.

Continuation of the development of the ESG Data Platform project, which aims to implement a platform for aggregating
the data underlying ESG reporting (e.g., Green Asset Ratio) and that also allows addressing business needs in thesustainability field (e.g., potential differentiation of communication or commercial conditions for operations that promotesustainability). This platform, which is based on an architecture that ensures a correct updating and centralization of data
and will have a component available for automatic report generation, eliminating the need for manual intervention, will
be launched in the first quarter of 2024.
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 make HCE, Apple Pay, Garmin Pay, Fitbit Pay and BLIK contactless payments. In 2023,
this offer was complemented with Google Wallet and the availability of these solutions was expanded, including theavailability of BLIK contactless payments to new customer groups (children and micro-businesses), and activation
campaigns were organized. Customers can also withdraw cash from ATMs using a BLIK code.
Convenient and secure online payment methods have also been made available. The Bank's customers can pay for theirpurchases online with a BLIK code, by debit card and by defined transfer. In 2023, Bank Millennium, together with Polish
Payment Standard, continued to work on a new service in the area of deferred payments - BLIK Płacę Później. Customers
who shop online can take advantage of a purchase cashback program.
In 2023, customers gained additional BLIK services based on transfers to a phone number. This way, they can more easily
settle accounts with family and friends thanks to the BLIK transfer request and invoice splitting feature.
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 insales and acquisition processes (opening of individual and corporate accounts).
Customer experience is increasingly the factor that determines the advantage of one solution over others. For this reason,
the Bank involves its Customers in the process of developing the design of digital solutions. The solutions that customers
use on a daily basis in the mobile app and online banking system are also continuously improved.

Information Security
Material issue:

CYBER-SECURITY, PRIVACY, AND INFORMATION PROTECTION

The information security programme implemented at the Millennium bcp is oriented towards the protection of
information, taking into account its confidential nature, integrity and its availability, in accordance with legal andregulatory requirements.
Information is protected in a manner that is consistent with its importance, value and sensitivity so as to increase the BCP
Group's resilience and ensure the protection of stakeholders, reputation and the activities for the creation of value.
The information security policy establishes the guidelines for the implementation and maintenance of the information
security programme of Millennium bcp. It is based on a structured set of policies, rules of procedures and standards, alignedwith international good practices, namely the regulation ISO/IEC 27001 - Information security management systemsRequirements and with the guidelines EBA/GL/2019/04- EBA on ICT and security risk management. The information
security policies are approved by the Executive Committee (EC) and are revised every two years, or earlier if there are50

2023 SUSTAINABILITY REPORT

changes in the internal environment that justify it.
This information security programme is oriented towards information security risk management and is supported by aset of fundamental general principles aimed at information protection, namely information security governance, humanresources security, information security awareness, classification, protection and handling of information systems andcommunication 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. An information security risk management model is implemented with
the integration of the results of the annual exercise into the Bank's operational risk framework, adapted to the Bank's
business processes.
The Bank has an Operational Resilience Commission, dependent on the EC, that meets every two months with the objectiveof 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, theattempted 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 theinformation systems that support the business. Despite the high number of security events that are detected daily, during2023 no information security incidents were recorded.
The Bank has a vulnerability management process that is supported in the execution of intrusion tests in continuous mode
on websites and Apps exposed to the Internet and monthly vulnerability scans on the internal network, with the objectiveof 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 themain information security policies and the risks and threats the Bank is subject to on a daily basis, within an approach basedon practical examples of e-mail, Internet and phishing. In addition, simulated phishing and social engineering attacks arecarried out aimed at Employees and outsourcers, to assess and reinforce the maturity level in information security, in orderto build a more resilient and secure organisation. All new employees are targeted by the regular information security
awareness programme.
The 2019/2022 strategic plan for information security was defined in order to strengthen the security defence bases andprepare the Bank to respond to the challenges that are expected, whether technological (e.g. AI) or regulatory (e.g. TiberPT). Subsequently, the activities for 2023/2024 capitalize on the solutions implemented or consolidated in the previous
strategic plan, (e.g. Next-Gen SIEM, Full EDR, Vulnerability Management, PAM, MIP & DLP; Security Awareness; Red
Teaming) as support to obtain a more effective response and improve the Bank's resilience by leveraging on: i) advantagesof artificial intelligence for automated threat detection and investigation by machines, simplifying complexity andaccelerating responses; ii) understandable and actionable metrics through the generation of valuable information, whichallows predicting situations, thus leading to more correct decisions in the area of information security; and iii) use resilience
as a competitive advantage, through the concept of Minimal Viable Bank raising digital resilience and crisis simulations andwargaming (e.g.TIBER-PT and ECB Cyber Resilience Stress tests).
To reinforce the existing monitoring mechanisms, Millennium bcp joined the BitSight platform. This platform collects andanalyses, in an ongoing manner, data on security behaviour and the implementation of the security measures of theassociated companies, identifying signs of compromise (e.g. Infected machines, inappropriate configurations, incorrect
behaviour by the users), 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 2023, Millennium bcp consistently maintained one of thebest cybersecurity ratings (790) of Portuguese banks.

51

2023 SUSTAINABILITY REPORTThe evolution of Millennium bcp's BitSight security rating over 2023 was as follows:

Additional reference to the business continuity management systems implemented in the BCP Group, through which theavailability of the most critical business support processes and systems is ensured.
Main initiatives to increase security with data and operations carried out in digital channels:- Several internal and external communication initiatives and practices were adopted, sending push notifications throughthe App, external emails, Bancomail and making available in the Bank's homebanking and internal portal, whenevernecessary, alert articles for frauds/scams that are occurring at the time. In these communications, we address the form ofattack, topics related to the safe use of Millennium bcp's digital channels, publish fake pages, fraudulent emails or SMS
that aim to capture personal data, access and authentication codes, and provide a detailed explanation of how ongoingthreats work;- We produce short videos related to the safe use of digital channels explaining how cyber attacks can occur, how they
spread, their common/usual characteristics, the behaviour they can adopt when accessing a banking website and the result
obtained;- We monitor a public fraudulent message box, of emails forwarded by customers and non-customers, which allows theidentification and control of possible attacks, which are analysed by the internal areas responsible for security andinformation and allow the identification of phishing, fraud and scams and whether they affect the user's access to our
digital channels, homebanking or App.
- We analyse phishing attacks and activate measures to mitigate fraud, implement security limits and blocks, in order toensure the security of customers' assets in the use of digital channels;- We collaborate with various external entities, such as the Associação Portuguesa de Bancos, Banco de Portugal, theJudiciary Police, the National Centre of Cyber security or Europol, in awareness campaigns on the security precautions
to be adopted while using devices with an Internet connection in order to prevent frauds;- We maintain an internal security awareness policy, which includes periodic training for the Employees of the Contact
Centres to raise awareness on the theme "Security" in the internet, procedures to be adopted reported in fraud contacts
and identification of needs and improvements to be adopted in the services made available by the Bank.

52

2023 SUSTAINABILITY REPORT

Data protection and privacy
CYBER-SECURITY, PRIVACY, AND INFORMATION PROTECTION

Material issue:

Millennium bcp considers essential that its Stakeholders are aware of the rights they have for the protection of theirpersonal data and the way according to which the Bank processes them.
The main instrument of this exercise is the Privacy Policy, which translates the Bank's commitment to (i) communicate ina transparent manner on the personal data it processes and under what conditions; (ii) ensure the security of personal
data and the privacy of data subjects; (iii) provide the appropriate mechanisms for the exercise of the rights of personal
data subjects; (iv) comply with the provisions of the General Data Protection Regulation ("GDPR") - and other applicablelegislation, including national legislation that complements the GDPR; and (v) comply with the confidentiality duties arisingfrom the Legal Framework of Credit Institutions and Financial Companies.
The processing of the personal data allows, among other purposes, the development and direct sale of products andservices in order to better tailor the communications that are addressed to each Customer.
To this end, using mathematical and statistical models, we process personal data generated by the use of the Bank's
products and/or services (e.g. data on contracted products or related to financial transactions and transactions carried out
with means of payment made available by the Bank), with the purpose of assessing the profile of Customers and building
consumption patterns based on their transactionality in any of the Bank's channels, thus determining the propensity ofCustomers towards such products and/or services - and also towards other products and/or services of a similar nature with the aim of customizing the offers communicated to them according to their preferences, in the context of the financial
activity and insurance mediation that the Bank pursues.
- Internal Communication
Aware of the vital importance of the proper use, control and security of the data we manage, we have developed a set oftraining initiatives aimed at our Stakeholders, in particular the Bank's employees. Hence, in 2023, we maintained ourinternal dissemination and awareness initiatives on topics related to Privacy, Security and Data Protection, of which wehighlight: (i) the regular publication of universal informative content, for all employees, or functionally directed, for thecommercial areas, on corporate communication platforms; (ii) the launch of another edition of the "Learn and Win"
competition, a pedagogical challenge on essential aspects of Data Protection; and (iii) sending a quarterly newsletter topublicize ongoing projects, opinion articles, testimonials, tips and good practices and other related news.
- Mystery Client
In the course of 2023, 4 waves of “Mystery Client” took place, with a total 1,391 visits to Millennium bcp branches. These
actions aim to evaluate the behaviours in the Customer service in the branch, within the scope of Privacy, being examplesof aspects under observation the following:
Were there any documents in sight that exposed customer data or other information, unrelated tothis service?
Was the monitor used by the Employee visible at any time, exposing information from other customers or other information not related to this service?
Has the Employee ever been absent leaving the computer unlocked?
During servicing, did the Employee have parallel conversations, face-to-face or by phone, exposing
information on third-party matters (customers or not)?
Have you been asked for unnecessary personal information regarding the topic of the service provided?
In addition to the aspects mentioned above, was there any behaviour on the part of the Employeethat felt to jeopardize the privacy (yours or others') during the service?

53

2023 SUSTAINABILITY REPORT- Training
As part of formal learning processes, the Data Protection Course(e-Learning), in its 2023 edition, in Portugal, allowed to strengthen
and update the skills in these matters of 7,088 employees andoutsourcers.

In 2023, in Portugal, 7,088 employees and outsourcers received training on Data Protection

In the reinforcement of the skills of the members of the Team responsible for managing the theme at Millenmnium bcp,
we should underline the IAPP (International Association of Privacy Professionals) certifications, such as: (i) Certified
Information Privacy Professional - Europe Regulation (CIPP - E); (ii) Certified Information Privacy Professional Manager(CIPM); and (iii) Fellow of Information Privacy (FIP).
Also in this process of continuous training, the GPDP participated throughout the year in training events and knowledge
sharing forums. These opportunities to acquire and share information allowed the reinforcement of the knowledge andthe increase of the Team's skills, ensuring the ability to respond to the strong evolution of trends and applicable legislation,
as well as preparation for new challenges and approaches, such as Artificial Intelligence, namely:
▪
▪

▪
▪

EU Digital Markets - Technology, Business and Regulation - Católica Faculty of Law, multidisciplinary course that
integrates the latest developments in the technological, economic and regulatory fields;
European Data Protection Congress 2023, promoted by the International Association of Privacy Professionals - IAPP,
data protection professionals gathered to share knowledge on the latest developments in data protection legislationand operations;
AI Governace Global 2023, the first global event on AI governance, promoted by IAPP;
TrustWeek Tour, promoted by OneTrust, a provider of applications to support data protection activity, todisseminate new features and solutions, share experiences and disseminate good practices.

Within the framework of the reference corporate regulations, we approved and published in 2023 the Principles of
Personal Data Processing and Protection/Privacy Policy, which can be consulted here:
https://ind.millenniumbcp.pt/pt/Institucional/sustentabilidade/Pages/cod_internos.aspx

Shareholders
At Millennium bcp, the Investor Relations Division is the unit responsible for ensuring an honest, transparent andcontinuous relationship with the Bank's Shareholders and Investors, Analysts and Rating Agencies, as well as with financial
market participants in general and respective supervisory entities.
The activity of the Investor Relations Division is characterized by:
▪

▪
▪

▪

ensuring a rigorous, effective, and accessible relationship with investors and analysts, as well as with the financial
markets in general and the respective regulatory authorities, especially in relation to the disclosure of inside
information and other mandatory information, including the production of the Bank's Annual Report;monitoring updates in the composition of the shareholder structure;
managing contacts established with the Rating Agencies, including the preparation and provision of regular
information relevant to or related to significant events, as well as clarification of issues on profitability, asset quality,
capitalization, funding and liquidity, among other;
represent the Bank in conferences and other types of events targeted at investors in shares or BCP debt.

In 2023, as in previous years, the Bank carried out extensive market communication activity, in accordance with applicablelegislation and in line with the regulator's guidelines. Millennium bcp has published more than 220 notices to the market,
including the publication of more than 75 notices in the CMVM's information dissemination systems (now the Electronic
One-Stop Shop), on Euronext Lisbon and also on the institutional website, in the Investors area. Of these, about 30 referto privileged information.
To comply with the legal requirements for financial reporting, the Bank discloses information relating to its earnings andactivities, including the Annual Report and Accounts, the Half-Year Financial Statements and the Interim Reports andFinancial Statements. Together with the Annual Report, the Corporate Governance Report, under the responsibility of theCompany Secretary Office, and the Sustainability Report, produced by the Sustainability Division, are also approved andpublished.
Millennium bcp provides a space to its shareholders, the "Millennium bcp Shareholder", through which it intends to be54

2023 SUSTAINABILITY REPORT

closer to the holders of stakes representing its capital. Through the Millennium bcp Shareholder, the owners of shares of
Banco Comercial Português, 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 accessto benefits and discounts agreed with the Bank's partners.
In 2023, 297 discount vouchers were issued within the scope of the 154 established offers/ partnerships.
The access to Millennium bcp Shareholder is free of charge and is hosted in a specific area of the website millenniumbcp.pt.

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

Material issue:

ATTRACTING, DEVELOPING AND RETAINING TALENTGRI 405-1
CGroup BCP gives to all its employees a fair and equal
Breakdown by gender
treatment, with equal opportunities, promoting(Percentage)
meritocracy in all stages of their professional careers,
defining the remuneration of the employees inaccordance with his/her category and degree ofcompliance with the established goals and the salaryratio of 1:1 between men and women withcomparable functions, levels of responsibility andprofessional paths.
The general principles ruling the BCP Group containvalues and performance guidelines applicable to all
employees resulting in an express orientation so that,45%
regardless of their hierarchical level or
responsibilities, all Employees act in a fair mannerrefusing any discrimination but also in thereaffirmation of the alignment with the ten Global
Compact Principles, according to which the Group
Men
Women
recognises and supports the freedom of associationand 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.

55%

In the context of Human Rights, the BCP Group prevents the risk of violations of these rights, among other mechanisms,
by making it compulsory for its employees and partners to subscribe to the Code of Conduct, in which this issue is regulated,
as well as allowing anonymous reporting of violations in this regard (see "Human Rights" section).
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/Institutional/sustainability/Pages/internal_cod.aspx
Within the scope of the gender diversity of the Board of Directors, in 2023 BCP had 31% women in its composition.

55

2023 SUSTAINABILITY REPORTAge breakdown by gender

Professional category by gender(Percentage)

Percentage

>=50

61%

Total

45%

55%

Others

46%

54%

52%

48%

39%

Technicians[30-50[36%64%Commercial
Management

<30

40%
Man

60%

38%

62%
57%

SeniorManagement

Woman

43%
77%

Man

23%
Woman

Still within the scope of gender diversity in Management functions (Executive Committee/Senior Management andManagement) in 2023, globally, 41% of these functions were performed by women - 24% in Portugal, 54% in Poland and
27% in Mozambique. In commercial functions, this figure increases to 62% in the Group, i.e. 50% in Portugal, 75% in Poland
and 61% 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 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. In fact, since 2017 we have actively participated in thevarious actions of the iGEN Forum, namely in the monthly meetings of the Task Force and the 2 working groups (GT) to
which we belong (GT2- Gender Equality Measures and GT4-ADN iGen).

In 2020, 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.
Bank Millennium, reaffirming its commitment to respect and promote diversity among Customers and Employees, is oneof the companies signing the Diversity Charter of the European Union, coordinated locally by the Responsible Business
Forum, having integrated, in 2023, the "Europe's Diversity Leader 2024", a ranking prepared by the Financial Times andStatista.
▪
▪
▪
▪
▪
▪

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 Leadershipcompetences;
Recruitment of new employees using gender diversity and wage equality criteria; andWork-Life balance support.

For the tenth consecutive time, Bank Millennium was awarded the title of Reliable Employer of the year. The award isgiven to companies that care about safety and working conditions, as well as the development of employees. The objectiveof this program is to select the best employers in Poland, that is, business entities with an exemplary Human Resources
policy, which translates into high quality of products and services provided in the demanding Polish market.

562023 SUSTAINABILITY REPORTIn 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 interms 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 incompanies.
As part of the strengthening of proximity mechanisms between employees and senior management, in addition to visitsby members of the Executive Committee to branches and central services, regional meetings were held with Employees.
In Portugal, we once again carried out the Organizational Climate Questionnaire, aimed at all employees of the Groupworking in Portugal and representative offices, which in 2023 registered a record participation of 88.4%, which reflects thestrong involvement of employees in the life of the Organization.
The average of the Global Indicators reached 75 points and satisfaction with the area where he/she works stood at 78
points. In terms of satisfaction with the hierarchy, the excellent evaluation achieved of 83 points stands out, as a result of
the investment that has been made in Leadership programs.
In Mozambique, in order to measure the levels of satisfaction and motivation of Employees, an online survey"Organizational Climate Questionnaire" was also carried out, one of the main instruments of the Employee Satisfaction
Management System, which once again had a high participation rate (91%).
There was an improvement in the vast majority of global satisfaction indicators, with a significant increase in satisfaction
as a bank employee (+6 points), which reached 70 points. Also noteworthy are the good results of the satisfaction indiceswith the hierarchy and with the Organic Unit, with 78 and 74 points, respectively.

Portugal
Employee management and recruitment
Millennium bcp's Human Resources Management focuses on providing the organization with the appropriate talent forthe organization's strategic initiatives, so in 2023 the priority was to ensure that the purpose of leading the transformationof the business in Portugal, in a very demanding regulatory context, is accompanied by the reinforcement of thesustainability, technology and digital teams, as well as control areas.
From an approach point of view, the Bank remains committed to recruiting young people with high potential to train anddevelop as a way to ensure sustainability in the rejuvenation of teams and the transfer of critical business knowledge.
In addition to attracting and developing young talent, the Bank has made a strong investment in the requalification of its
staff in order to ensure a lifelong learning of each Employee, leveraging their experience.
Consolidating a culture of meritocracy is a permanent objective in the management of people, and the Bank has continued
to recognize those who stand out for their performance, responsibility and potential.

572023 SUSTAINABILITY REPORT

Talent Attraction
According to the new cycle of Millennium bcp's Strategic Plan, which includes the mission of accelerating thetransformation and strengthening the positioning for the future, preparing to face and overcome the challenges inherent
to the macroeconomic framework and the competitive context of the sector, attracting and retaining talent continues tobe a priority. In this sense, throughout 2023, the Bank built an integrated value proposition aligned with the interests ofuniversity students with a vocation for innovation, critical thinking and a taste for banking.
We have carried out in-house and on-campus events and partnerships that have strengthened the commercial areas andespecially the STEM (Science, Technology, Engineering and Mathematics) areas, contributing to achieving the goal ofleading the transformation of the business in Portugal and strengthening the Bank's control areas. In 2023, Millennium bcp
carried out 225 external recruitments, with an average age of 27.1 years, which signals the attractiveness that the brandhas with the younger workforce.
These actions make it possible to build the bridge between the academic world and the business reality in the developmentof critical skills for the future professional life of students, regardless of the path they may take, and we believe that it isthrough a privileged and close contact with the Universities, where the generations of the future are "manufactured", that
Millennium bcp launches and establishes the connection with the talent it intends to capture. It is also a cause of social
responsibility to the extent that, by establishing synergies and partnerships, through Education, with Higher Education
Institutions that share common objectives, it allows to open doors to the development of skills and knowledge in a realcontext.
Among the initiatives carried out in 2023, we highlight:
-

-

-

-

The most notable event was the first edition of Make IT - a datathon (data science marathon) with the aim of
positioning the Millennium bcp brand in the IT/Data Science market as an attractive employer - which took 42
students from 4 different universities to the final at the Bank's facilities: Universidade de Lisboa, Universidade de
Coimbra, Universidade Nova de Lisboa and Universidade do Porto, from where the winning team came out (see moredetailed information in the section on Training);
Also for the first time, Millennium bcp became a partner of Magma, which allowed it to participate and preferentiallyaccess the profiles of participants in 10 events with relevant higher education institutions, such as Instituto Superior
Técnico, Faculdade de Ciências e Tecnologia da Universidade Nova, Instituto Superior de Economia e Gestão, among
others;Finally, the Bank once again participated in the FEP Master Challenge and in the events with students of QTEM
(Quantitative Techniques for Economics and Management), of which it is a corporate partner, and which has allowed
contact for selection purposes with students from Faculdade de Economia do Porto for various positions, namely inthe areas of control and related;
Direct and punctual actions with the Professional Opportunities Offices of some of the Faculties that allowed, forexample, the realization of short-term and professional internships.

The new employees identified under several of the initiatives mentioned above are subject to the selection process that
promotes, from the outset, equal opportunities and respect for inclusion.

Career Development Programs
In addition to investing in training and skills development listed in the Training section, the Bank has invested in monitoring
young talents in a close and personalized way, reflected in several dimensions.
From the outset, we have a careful onboarding process from the point of view of communication, from the selection
process to the 24 months of seniority at the Bank, allowing for a positive and consistent employee experience.
Employees and Interns with the greatest potential are monitored by their Human Resources Manager in a regular andsystematic way, which implies regular individual meetings in the first two years within the organization, allowing to alignexpectations and provide a faster and more successful integration.
Finally, in 2023, the Bank relaunched the figure of the Patron, with the aim of being a reference figure and a source ofinspiration for the Employee, who can share his/her vision and help to better understand the Bank's main challenges.

Inclusion and diversity programs
In 2022, Millennium bcp and APSA - Associação Portuguesa de Síndrome de Asperger (Portuguese Association of58

2023 SUSTAINABILITY REPORT

Asperger's Syndrome) signed a protocol for the inclusion of their members in the labour market, which remains active.
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 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.
The Inclusive Community Forum (ICF) is a Nova SBE initiative dedicated to the lives of people with disabilities, in which
Millennium has an active participation, both through the working group meetings and the "Vencer no Mundo do Trabalho”(Winning in the World of Work) Training.
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.

Gender Equality
The promotion and guarantee of equal opportunities, particularly on gender parity, embodied in both the Gender Equality
Plan that the Bank publishes annually and the "Superação 24" Strategic Plan, is present in all the actions developed by the
Bank.
Since 2017, we have actively participated in the different actions of the iGEN Forum (Forum of Equality Organizations)promoted by CITE (Labour and Employment Equality Commission), namely in the monthly meetings of the Task Force andthe 2 working groups (WG) to which we belong (WG2- Gender Equality Measures and WG4-iGen DNA).

PolandWhereas in Bank Millennium the recruitment processes are based on internal regulations 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 carriedout 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.
Employer Branding activities are a crucial part of the Bank's activity and are dedicated to 4 groups of potential employees:▪
Students and Master's/PhDs;▪
IT specialists;▪
Sales force;▪
Experts and back office specialists.
We are constantly working to reach the widest possible audience of talented external candidates, which is why we arepresent at selected universities, conferences, job fairs, recruitment websites and social networks.
For candidates with no work experience, we offer internship opportunities through our Summer Internship Program. It is
important to us that young people entering the labour market and focusing on professional development are able to realise
their plans at our bank and build competence capital for the future. The aim of the programme is to promote the Bank as
an employer and to increase interest in banking careers. In 2023, Bank Millennium guaranteed 36 students and recent
graduates selected in the recruitment process to carry out internships of 2 or 3 months during the summer holidays. Interns
learned new skills in 14 different divisions. The internship program was preceded by carefully planned promotional
activities that strengthened the Bank's position as an attractive employer. In addition to receiving attractive salaries andindividual development guidance from their supervisors, the trainees were invited to participate in trainings and, after theend of the internship, some of them received a job offer at the Bank.
In 2023, Bank Millennium continued its cooperation with renowned universities, including the Warsaw School of
Economics and SWPS University 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.

592023 SUSTAINABILITY REPORTThe Bank's employees regularly and actively participate in academic events such as job fairs, conferences, debates orworkshops, where the Bank presents itself as a stable and modern organisation.
Once again, the Bank has become a partner of the 2023 edition of "Pontes Económicas” (Economic Bridges), a nationwide
project implemented by the SGH Student Government and the Economic Universities Forum. The main objective of the
project is to integrate the academic communities of business schools in Warsaw, Kraków, Wrocław, Katowice and Poznań
and to build partnership relationships between academia and business. The projects offer students the opportunity toparticipate in workshops, case studies, inspirational talks, and to meet with experienced entrepreneurs.
Between March and May, the Bank participated in seven trade fairs in Warsaw, Wrocław and Kraków, organized, among
others, by Absolvent Talent Days, Pracuj.pl, Warsaw University of Life Sciences, Warsaw IT Days, Warsaw University Facultyof Management and Gdańsk. Recruiters share information about internships or jobs, present a wide range of career
opportunities in a variety of fields, and talk about the recruitment process itself.
The Bank enjoys sharing its knowledge and has had the pleasure of taking on the role of partner and conference attendee
to gain knowledge and find professional inspiration. In 2023, Bank Millennium participated in two conferences dedicatedto Java software and the Microsoft Azure cloud. The meetings were aimed at architects, researchers, Cloud and Big Data
experts, as well as university students and young people interested in the IT industry. Our experts were speakers at theconference. The main objective of the presentation was to show modern Java programming techniques and Microsoft
Azure "cloud" solutions. Attendees were able to see how the Bank uses modern technologies and modern programming
best practices.
The Bank takes advantage of the communication opportunities provided by social networks, such as LinkedIn andGoldenline, and popular image and recruitment portals, to reach candidates efficiently, with information about thebenefits of working for the Bank and a more effective promotion of job offers.

MozambiqueMillennium bim also recognizes that employees are one of the fundamental pillars of the business and sustainability
strategy. Active talent management is crucial and, therefore, policies and practices are implemented that promote theprofessional growth of employees and contribute to a productive, sustainable and ethical work environment.
In 2023, Millennium bim hired 236 Employees, with a balanced distribution between genders: 114 Women and 122 Men.
In terms of attraction, recruitment and selection of talent, the 5th edition of the People Grow Program stands out, which
included 11 young talents, recent graduates and high potential finalists. This program combines hands-on learning withrotations in various areas of the Bank and specific training, fostering a diverse talent base that is prepared for futurechallenges.
In 2023, Millennium bim reinforced its commitment to teaching in Mozambique, by offering summer curricular internships
for students and recent graduates, and establishing partnerships with Universities, which resulted in the awarding of prizes
for students who completed courses with distinction in various educational institutions. At the same time, Millennium bim
has strengthened its links with the main universities.
These initiatives demonstrate our strong commitment to education, diversity and professional development, a key
component for organizational and social sustainability.
In 2023, as part of the Employees' management and career development strategy, programs focused on the accelerated
development of skills and leadership were launched, of which the following stand out:-

"Talento Millennium bim" | Millennium bim, in partnership with Nova SBE, trained 27 high-performance and highpotential employees through an accelerated skills development program for about 18 months and more than 200
hours of training. This initiative aims to prepare Employees for the new paradigms, reinforcing our organizational
resilience.

-“Líder MBIM 4.0” | this program, which in previous years covered top management and Employees with first andsecond line functions, was extended in 2023 to Employees with branch management functions and team coordination
at the level of central services.

Recognizing the importance of employee motivation and involvement in the Bank's success, in 2023, a series of initiatives

60

2023 SUSTAINABILITY REPORT

aimed at increasing employee satisfaction and commitment were implemented at Millennium bim:✓✓✓

To promote team cohesion and reinforce the sense of pride and identification, end-of-year get-together events wereorganized in all provinces, from North to South of the country. These events included dinners and moments of cultural
entertainment, providing employees with the opportunity to celebrate the year's successes together, thus strengthening
team spirit and involvement with the organization;
With a significant percentage of female employees, we promote the celebration of diversity, through specific actions for
Mozambican women, emphasizing our cultural values and recognizing the vital role of women in the leadership and growthof organizations;
We reinforce our commitment to employees' families by offering activities and programs that involve their children. These
activities, which include solidarity actions and donations to orphanages, in addition to the offer of children's books, aim tostrengthen ties with the community and transmit the values of Mozambican culture.
These initiatives are an integral part of our commitment to creating a motivating and inclusive work environment, where
every employee feels valued and an essential part of Millennium bim.

The BCP Group aims to lead the digital and sustainability transformation of the banking business, through (best) talent61

2023 SUSTAINABILITY REPORT

Training

GRI 404-1

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 withthe strategic goals defined by the organization. Seeking topromote excellence in the relations established with
Customers, the Bank recognises the importance of ongoingtraining to ensure business sustainability and endeavours toprovide its Employees with the tools necessary for the
execution of their activities.
In overall terms, in the Group, 6,258 training actions were ministered, corresponding to more than 728 thousand hours of
training, with an average of 46 hours (45 in 2022) per employee. Throughout 2023, the training effort maintained its focus
on the commercial areas, but also on the technical, operational, sustainability, compliance and team management areas.
In Portugal, Millennium Banking Academy continued its development and training programs with the intention of
supporting the Bank in its mission and in the progress of the strategic plan.
The main objective was to develop a new pace of transformation in the organization, which requires a strong capacity foradaptation and innovation, essential aspects to continue to thrive. To keep up with these changes, an agile, collaborative
leadership mindset and a people-centered leadership culture are essential.
On the other hand, it is necessary for each employee to acquire a very clear vision of the organizational purpose, and at
the same time be able to define their individual purpose. We supported leaders in managing teams, strengthening socialand emotional skills to ensure effective collaboration and developing resilience in employees.
Thus, we gave special emphasis to Leadership Development Programs, boosted training in the areas of digital and invested
in strengthening the Talent Integration and Development Programs. We also continued to invest in training in the technicalareas of sustainability, compliance, auditing, legal and normative in light of the sector's demanding regulatory framework.

✓✓✓

To promote a culture of learning and co-responsibility of all employees in their own development, we have implemented
several initiatives, namely:
we redesigned the user experience of the learning platform, making it simpler, more intuitive and with easier access totraining courses;
we launched a new App that allows all employees to take training courses via mobile devices; andwe have expanded the training offer available with new online learning platforms.
Through the Digital Academy, launched in 2019, we also sought to expand the ability of employees to work in a digital
environment and develop technical and cognitive skills, such as problem-solving and critical thinking, which ensure thatthey respond to the need to redesign processes and innovate. The total number of training hours carried out by headcountemployees in 2023 was 335,674 (+2.4% compared to 2022).
By adapting the demand and supply to the different groups in the universe of the Bank's Employees: the Tech - from theareas of development, architecture, cloud, security and data -; the Business - from the areas that develop new businesssolutions -; the Ingenious - young people from the technical areas - and the Millenniums - all the other Employees -, we
continue to invest in the appropriate behavioural and technical training for the different needs, (i) to increase digital
literacy (learning for all), we launched the DigitalMente section (30-minute videos on the Bank's technological projects andon the latest digital developments in the market), new e-Learning and webinars on how to use and monetize current digital
tools (Smartphones and Office 365) and (ii) to increase technical skills and expertise in core topics and technological ones,
we have started a partnership with UDEMY - an online learning platform with a wide range of courses in the different
technological and behavioural areas - all so that our Employees are even more capable to respond to current and futurechallenges.

622023 SUSTAINABILITY REPORTTRAINING
2023

2022

2021

VAR.% 23/22

In-person

14,719 (W 59%, M 41%)

58,45338,878-74.8%

E-learning

417,291 (W 65%, M 35%)

409,711482,801

1.9%

Remote83,081 (W 57%, M 43%)

47,54559,88274.7%

In-person

82,783 (W 59%; M 41%)

176,784

124,408-53.2%

E-learning

402,731 (W 58%, M 42%)366,785

447,928

9.8%

Remote208,122 (W 58%, M 42%)

117,053

154,06177.8%

46 (W 58%, M 42%)

45

45

2.2%

NUMBER OF PARTICIPANTS (1)NUMBER OF HOURSPER EMPLOYEE(1) The same Employee may have attended several trainings.

Development Programs
LEAD Program
In October 2023, we started the LEAD Development Program at ISCTE with 21 Employees. It is an integrated management
program (postgraduate) developed by ISCTE in partnership with Millennium bcp for leadership development. The LEAD
Program (Lead, Understand, Act and Decide) includes 12 modules in a total of 140 hours of training and addresses topics
such as: Servant Leadership, Assertive Communication, Agility and Change, Sustainability, Artificial Intelligence andCybersecurity. In 2023, the trainees participated in 5 modules of the Program, representing 1,057 hours of training.
Líder Millennium Program
The Millennium Líder Program, which began in November 2022, continues to run with the aim of supporting Leaders intheir role and challenging them to develop the necessary leadership skills to keep up with the new pace of transformationand the demand for adaptation and innovation.
The Program is aimed at all hierarchies of the Bank (Commercial Network and Central Areas), with modules adapted todifferent needs and sharing of good practices on topics that address (i) Giving Feedback, (ii) Conducting Conversations with
2, (iii) Motivating, (iv) Delegating Effectively, (v) Being Accountable, (vi) Recognizing and (vii) Managing my time between
people and business. To reinforce these themes, 7 webinars (MLíder Talks) were held, with external experts: “Quebrar ossilos. Liderar a transformação” (“Break down the silos. Leading transformation"), “(Re)carregar motivação” (“(Re)charge
motivation”), “Conseguir resultados: Influência” (“Obtain results: Influence”), “Why Mindset?”, “Diversidade: Gerações
side by side” (“Diversity: Generations side by side”), “Desafiar o nosso futuro” (“Challenge our future”) and “Comunicar é
criar ligação” (“Communicating is creating a connection”). Between June and October, 4 leadership workshops, lasting 1
day, on Emotional Intelligence, and 1 workshop on Generational Diversity "Building Bridges", were held, in partnershipwith Nova SBE University.
A total of 1,008 leaders participated in this program, corresponding to a total of 4,767 hours of training.
inGenious Program – young talent development
In January 2023, the closing session of the 4th edition of the inGenius Program took place, training especially aimed at thedevelopment of young talents, with the presentation to the Executive Committee of the projects developed by these teams
to respond to challenges across the organization.
In September, we started the 5th edition of the program, which featured 88 young talents from the Bank's technology,
analytics, investment and financial areas. An initial session was held with the hierarchies of the participants to present the
program, and a workshop on generational diversity, "Building Bridges", in partnership with Nova SBE, with the objective of
demonstrating the complementarity between the different profiles existing in the organization. The inGenious program
will last for 9 months, at the rate of 1 week per month. From October to December 2023, inGenious young people had theopportunity to get to know the bank's main areas, develop their networking and behavioural skills, in areas such as63

2023 SUSTAINABILITY REPORT

Emotional Intelligence, MBTI and Design Thinking. The
multidisciplinary projects, fundamental to the Bank's activity,
were also initiated, which in this edition will be developed in
the Design Thinking methodology, with the support ofconsultants. Until June 2024, they will continue to develop theirsoft and hard skills, with technical training appropriate to eachprofile.
Between October and December 2023, a total of 3,022 hours of
training were invested in the program.
Digital Academy
The objective of this front is to build a business-oriented digital vision, in specific areas, and to train the employees of theCommercial Networks in the new tools for interaction with Customers.
The Digital Academy was launched in 2019 to respond to the training needs with a view to reskilling and upskilling
employees, and was structured to adapt the training offer to different groups of Bank employees with different needs:
Tech - from the technology areas (development, architecture, cloud, security and data) -; Business - from the areas thatdevelop new business solutions and Millenniums - all remaining Employees.
To respond to the emerging challenges of these populations, in 2023, we continued to invest in behavioral and technicaltraining appropriate to the different needs, to increase digital literacy (learning for all) and increase technical skills andexpertise in core and technological topics.
Throughout the year, we held (i) 4 new webinars under the heading DigitalMente, on the Bank's technological projects andon the latest digital developments in the market, (ii) we increased the number of accesses to the online learning platform
UDEMY Business, which offers a very comprehensive range of courses in the areas of technology, we continued to carryout training actions, namely in the areas of microinformatics, data, development and also in agile work methodologies,
through Scrum certifications.
SAS Academy
As part of the development of technical skills necessary for the function, training courses are held in SAS, with theopportunity for certification for Bank employees who are part of areas of high technical demand in the area of data.
The SAS course includes sessions in e-learning format, mentoring, live web and certification exam. In 2023, 39 trainees
completed 1,072 hours of training.
Microsoft Information Protection (MIP)
Microsoft Information Protection (MIP) is a Microsoft technology solution that aims to classify and protect information.
MBA made an e-learning course available to all employees, interns and outsourcers in order to make known the MIP tool,
its various labels and how to apply them. This one-hour training, of a mandatory and transversal nature, corresponded to
5,644 hours of employee training.
Thus, in 2023, in global terms, at Millennium bcp, 43,853 hours were invested in training in the digital area (20,931 hours
in 2022), with a total of 6,077 participants registered in training initiatives, mostly in format and -learning.

Onboarding Programs
In order to integrate and ensure the appropriate training for each person at the right time, the Millennium Banking
Academy continued to invest in onboarding programs to reinforce the behavioral and technical skills needed by those whoarrive or change functions.
Leadership Onboarding
Preparing the Bank's future leadership remains one of the priorities, taking into account market demands, in times of highvolatility and high turnover. At the beginning of their role, we give the opportunity to the new Leader to develop their
behavioral skills, through self-knowledge and effective knowledge of the team (Myers-Briggs Type Indicator - MBTI), toknow and develop the behaviours that are expected of them as a Leader, “Ser Líder Millennium” ("To Be a Millennium

642023 SUSTAINABILITY REPORT

Leader"), and to prepare for the moments of interaction with their Employees, “Momentos de Verdade” ("Moments ofTruth"), through the sharing of experiences and good leadership practices.
After the initial training, the participant joins the Millennium Leader Program and the specific training programs,
appropriate to each segment.
In 2023, 60 new Leaders (47% women; 53% men) were trained, for a total of 966 hours.
Onboarding New Retail Network Functionsa)Branch Managers

As part of the Leadership Training Program, and for the hierarchies of the Retail Commercial Network, the Onboarding
Training took place in March 2023 with specific content of a behavioural nature, culture of rigor, commercial systematics,
Customer experience, pricing decision and risk analysis (Individuals and Business). There were 11 recently appointed
Branch Directors who valued the applicability of the themes, the proximity of the trainers and the exchange of experiences.
b)Prestige Platform (Customer Managers and Branch Managers)

We have created a training roadmap for those who arrive in the segment with immediate availability of courses in elearning format on the most relevant topics for the role, complemented with face-to-face training moments on: 1.
Programação para o Sucesso (Programming for Success) (NPL); 2. Escrever com persuasão (Write persuasively); 3.
Propósito e Felicidade (Purpose and Happiness).
Two editions of this program took place in 2023 (March and November, with a total of 49 participants). Evaluation of
excellence on the usefulness and applicability of the contents, as well as on the intervention of the trainers.
c)Business Platform (Customer Managers and Business Branch Managers)

This program has a segment-specific technical training component on specialized credit products, digital offer andcustomer risk analysis and a behavioural component. In 2023, an edition of this program was held in March, involving 13
new Business Managers.
d)#1 Customer Experience Certification Program (Prestige & Business)

This program addressed the pillars of customer experience and service choreography (ROUTE), included a training day andan individual certification role play for the application of the knowledge acquired. It takes place at the beginning of eachyear.
In 2023 we involved, in addition to the new Managers, other employees who had not yet completed this training, namely
Branch Managers. Thus, between January and April, we had a total of 88 participants, of which 30 were Branch Managers.
At the end of the program, a synthesis of the strengths, areas to be developed and recommendations was made, very
useful for the development of the business and employees.
New Employees Onboarding
Continuing the onboarding process for new employees (permanent or intern), in 2023 we carried out:-

Three Welcome Sessions in the face-to-face format and with the presence of the Executive Committee, where new
employees are invited to learn more about the Bank's strategic vision and values, and challenged to some group
activities highly valued for the conviviality and exchange of experiences they provide. In February, May and
September, we gathered a total of 262 new employees and interns.

-

The training for the Commercial Network that involves the Employees who are part of the branches and Pontos Ativo(Ativo branches) has a total of 7h30 divided into: 1. Customer Service and Sales; 2. Phone Sales; 3. IT Applications. The
objective is to provide interns with technical and behavioral skills for interaction with the Customer. In 2023 we had
a total of 5 editions (February, April, June, September and November) to which was added a specific one for Summer
Interns. In total, 260 employees and interns participated.

In addition to these sessions, all employees and interns must also complete a training course transversal to all Employees,
Millennium bcp Training, which includes several training courses in e-learning format that includes the courses Code of
Conduct, Sustainability, Safety and Hygiene at Work, Data Protection, Information Security, Importance of Data
Governance, Anti-Money Laundering and Counter-Terrorism and Microsoft Information Protection (MIP).

65

2023 SUSTAINABILITY REPORT

Employees of the Commercial Networks also have a specific path that includes courses in e-learning format necessary forthe performance of their duties, including certifications in Mortgage Credit, Insurance, MiFID and Credit Intermediation for
the employees of the ActivoBank Commercial Network.
Also noteworthy is the creation of e-learning training on PAB, an application to support treasury transactions of the Retail
Network, and the review of the remote course on Good Treasury Practices.

Welfare and Social Responsibility
Training within the scope of Inclusion
In 2023 Millennium bcp held Vencer no Mundo do Trabalho (Winning in the World of Work) Training sessions for two moreclasses, 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 withdisabilities. In these sessions we train good practices with exercises that contribute to personal and professional successof the trainees. The training is given two people: people with disabilities and the technicians who accompany them. In thetwo classes held, the associations Novo, Pais em Rede Delegations of Aveiro and Sintra, Casa de São Francisco de Assis(former Casa do Gaiato de Lisboa), APSA, CADIM, CMC Dep. Employability were represented. A total of 17 trainees werecovered (and respective 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, thetraining includes a practical section on preparing for a job interview.
Happiness Training
The subject of Happiness has aroused more and more interest in the organization, as it allows to strengthen the social andemotional skills of Employees with a reflection on the well-being and performance of the teams.
Thus, as of May 2023, we started the Purpose and Happiness module in a face-to-face format, with a duration of threehours for the Central Areas distributed over 12 training classes.
We also introduced the Purpose and Happiness module in the Prestige Onboarding Program in the 2nd half of 2023, having
held two training sessions aimed at Prestige Branch Customer Managers and Managers.
The weblive Happiness module continued to be worked on within the scope of the Ingenious Program and at the beginningof 2023 in the B#1 Prestige Program aimed at Branch Managers, Customer Managers and Assistants.
334 Employees participated in the Happiness Training sessions, totalling 889 hours of training.

Legal Certifications
MiFID II Certification
In 2023, we continued the process of training and certifying the knowledge of Employees for the provision of investment
information and advice, within the scope of the Markets and Financial Instruments Directive II.
This directive entered into force on 3 January 2018 and introduced changes in the functioning of the markets, aiming atgreater investor protection, more transparency in the sale of financial instruments and the elimination of conflicts ofinterest. This training aims to ensure that all Employees of the Commercial Networks and some of the support areas havethe appropriate knowledge for their activity.
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 noless than 30 hours, in the case of those who provide investment advisory services or portfolio management services onbehalf of others, or 20 hours, in the case of those who provide information to investors.
In 2023, the renewal of MiFID II certification was carried out during the 2nd 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 MiFID II Certification - Provision of Information, it corresponded to the courses on66

2023 SUSTAINABILITY REPORT

sustainability impact in MiFID II, basic notions of Macroeconomics, financial markets, financial intermediation activity andinvestment services, ethics and conduct in the marketing of financial instruments, market crimes and preventive control
and mitigation measures, prevention of money laundering and terrorist financing and sustainable finance and MiFID II,with an estimated time of 20 hours of training.
Regarding the annual renewal of the MiFID II Certification – Advice (Investment Advisory), it corresponded to the same
courses chosen for the provision of information, plus the courses on disclosure of information on sustainability in thefinancial services sector, product governance and sustainable finance, duty of adequacy and portfolio management theory,
with an estimated time of 30 hours of training.
The total number of employees involved in the MIFID II Certification and Annual Renewal processes was 3,731, whichcorresponded to 96,719 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 involvedin the preparation, sale and conclusion of credit agreements and the associated services usually offered.
A total of 2,234 hours of training were carried out in the scope of the certification of Mortgage Credit Commercialization
and Credit Intermediation by 112 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 Employeeswith PDEAD - People Directly Involved in the Activity of Insurance and Pension Fund Distribution. In this context, 58,470
hours of training were carried out for 3,628 employees.
Euro Banknote and Coins Knowledge Course
Millennium bcp conducts e-learning training courses on the euro banknote and coin and their security features, aimed at
employees who handle cash, courses that fully meet the training requirements and objectives required by Banco dePortugal.
The course on euro banknotes has a 6-hour duration and includes the following modules: Characteristics of banknotes;
Genuineness checks; Fitness checks and damaged banknotes. 1,346 employees completed this training, for a total of 8,076
hours.
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. 873 employees completed training, for a total of 1,746
hours.

Other Training Programs and Actions
Code of Conduct
In November 2023, MBA made available a new version of the e-learning "Code of Conduct", aimed at all employees,
outsourcers and interns. This course aims to recall the set of fundamental principles and values of professional ethics that,on a daily basis, should govern our performance. By December 31, 2023, 2,930 employees had completed the "Headcount"course, corresponding to as many hours of training.
B#1 Prestige
Started in April 2022, the B#1 Prestige Program, aimed at employees in the Prestige segment, ended in April 2023. The
objective of this initiative was, based on a diagnosis of individual needs, to develop skills and techniques and behaviours
with a focus on the Customer, and 14 themes were made available throughout the year, including e-learning andsynchronous training in teams. The final balance was very positive: more than 600 employees involved, 4,000 courses
completed and 6,000 hours of training.
M Mais Forte (Stronger M)

672023 SUSTAINABILITY REPORTTo reinforce the knowledge of employees in the commercial areas, a knowledge test is carried out in each commercial
cycle (4 times a year) that addresses ongoing campaigns with visibility, priorities by business segment and topics related todigital channels, complaints and customer experience. In 2023, 2,896 Retail Network Employees took the knowledge test,
for a total of more than 10,000 hours.
Goodhabitz
In order to boost and develop a culture of continuous learning, take advantage of micro-learning and the advantages of
online learning, in February 2023 we made available to ActivoBank the Goodhabitz learning platform that offers more than
100 courses in the area of personal development. Throughout the year, we developed several initiatives to launch andpromote the courses on this platform. The final balance, both in terms of the number of users and the comments collected,
led to the decision to extend the platform to all Millennium bcp employees, which will occur in early 2024. In 2023, 128
courses were held on this platform, corresponding to 421 hours of training.
Duties of Assistance and Information to Consumers in Mortgage Credit
In compliance with a determination by Banco de Portugal, in October we launched an e-learning course aimed at the entire
Commercial Network, which is mandatory and aims to strengthen employees' knowledge of the obligation to comply with
the Mortgage Credit Information Duties. In total, 2,661 employees completed the course, which is now part of the training
paths for the different functions of the Network.
SelfBankers Certification
With the motto 'Todos somos SelfBankers” (“We are all SelfBankers”) and the objective of making the most of and keeping
the Network's machine park operational, training began in June 2023 for the first group of employees selected to take the
SelfBankers Certification. The Program took place between June and October and had several phases: 1. Training in elearning; 2. Self-assessment test of knowledge; 3. Preparation meetings; 4. Final Certification Test. A total of 1,779
employees of the Mass Market Network completed the certification course, corresponding to 17,790 hours of training.
Higher Education Incentive Program
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 2023, 26 Employees participated in this program.
Control Areas Training (DAU/ROFF/COFF)
The Bank's Control areas participated in various technical trainings, namely on internal fraud, operational risk and SREP
(Supervisory review and evaluation process). These trainings aim to respond to a demanding training plan and comply withguidelines from supervisory entities and corresponded to 931.5 hours of training.
Board of Directors Training
In 2023, the training plan for the integration of new non-executive Directors was continued. At the same time, training
was held on Remuneration Policies, Sustainability and Cybersecurity, aimed at all members of the Board of Directors. These
training sessions allowed 100 hours of training to be carried out.
Other Initiatives
BUSINESS ROUND TABLE PORTUGAL - PRO_MOV – Lab Sales
The labour market is changing radically. A change accelerated by the green and digital transition, which is calling into
question many of the existing professional functions and requiring new skills. To face this challenge and get a place in thejob market, the Portuguese, like millions of workers around the world, will have to update their skills (upskill) or convert
their knowledge by acquiring new qualifications (reskill).
The PRO_MOV Program is one of the lever programs in the requalification of unemployed people with a professional
qualification/experience less adjusted to the current needs of a changing labour market. This Program has the active
participation of recognized companies in various sectors of economic activity in Portugal. Millennium bcp is present in two

68

2023 SUSTAINABILITY REPORT

laboratories: Sales and Digital.
In 2023, we continued our participation in the Skills Reskilling Program PRO_MOV through the Sales Lab. We received
three trainees for on-the-job training for three months, one of whom stayed to work at DBD (Direct Banking Division). It isplanned to scale this initiative in 2024, substantially increasing the number of participants in this program.
MAKE ITIn 2023 we bet on a new initiative, a Data Science competition for finalist students from four of the best Portuguese Data
Science Universities. This initiative had two main objectives - Brand Awareness (to reinforce the Millennium bcp brand in
the IT/Data Science market as an appealing and attractive entity) and to Attract Top Talent (to attract talent in Data
Experts). 36 teams and 128 students competed in the university phase, with a €1,000 Prize for the Winners. In the grandfinale, held at Tagus Park, with a data science challenge to solve in 24 hours, 12 Teams competed (the 3 best teams fromeach University),in which the winning team received a prize of €5,000 and prizes of €2,500 and €1,500 were also awarded
to the second and third place teams respectively. With this initiative, the Bank was able to create a strong impact on young
university students and leave a positive mark on their academic career, and in the meantime, several participating
members have joined the Bank in Professional Internship and some have already assumed contractual functions.

In 2023, at Millennium bcp, in Portugal, pursuing a strategy that always guarantees more and better training, but alsothat accompanies the Bank's digital transformation, the objective was to increase the reinforcement of skills on digital
topics (more than 5 hours of training per worker).
With an average of 7.0 hours of training per employee on digital topics recorded in 2023, which compares to theaverage of 3.5 hours in 2022, we increased training effort by 110%, achieving the objective proposed for 2023.
In 2024, the objective will be to continue to ensure an average of more than 5 hours of training per employee on digital
topics.

In Poland, the bank also continued to invest in the training of its employees always with the purpose of developing technicaland behavioural competences, able to improve quality and efficiency in the work developed and in the compliance withthe goals of Bank Millennium, always in line with its corporate values.
Bank Millennium continues to organize training and coaching programs, which cover all employees, with actions focused
preferably on responding to internal or external regulatory requirements, such as topics such as health, safety and hygiene
at work, data protection or information security, as well as promoting training programs on management, sustainability,
leadership and various conferences.

692023 SUSTAINABILITY REPORT

Most relevant trainings held in 2023:
Millennium Campus
Knowledge and skills development program aimed at supporting the growth of innovation across the organization. The
participation offer in this program is aimed at all employees, allowing them to look at many issues from a different
perspective. The lectures are held online, while the recordings and supports are made available on the training platformand via intranet within the scope of the "Millennium World". In 2022/2023, lectures related to safety topics were held.
Development Fridays
Program that aims to enable the exchange of knowledge and experience among Bank’s employees. Speakers include
experts who share their knowledge and experience through lectures, content that is available online.
Training for employees of the Corporate Banking Division
Employees working in the area of corporate banking have participated in several training courses with the aim of updating
their qualifications and expanding their knowledge on the evolution of products and procedures, including sustainability
matters. The most important trainings focused on the investment credit process, a new module of the credit process
management system and changes in the conditions for opening and operating accounts.
Training for employees of the Direct Banking Division
In this segment, mention is made of the following trainings: 1) specialized introductory training for new employees; 2)
Quality Philosophy workshops; 3) sales techniques: “Oferta ativa” (“Active offer”), “Trabalhando com números” (“Working
with numbers”); 4) consolidation loans to improve product knowledge and sales; 5) insurances “APK em conversa com ocliente” (“APK in conversation with the customer”); “Empréstimo sob proteção” “(Loan under protection”); 6) customer
service workshops: “Júniors”, “Jovens adultos”; (Young adults); 7) "Torne-se um Mentee” (“Become a Mentee”)
development - a course that prepares experienced employees to provide support through a dedicated internal line - ; and
8) “Academia de Talentos” (“Talent Academy”) project - use of MS Office and CC tools in a manager's work, “Planeamentode trabalho - cronograma” (“Work planning – schedule”), “Feedback eficaz” (“Effective feedback”), “Execução deworkshops” (“Workshops execution”), “Linguagem simples” (“Plain language”).
First Aid Training
In 2023, we organized a series of first aid trainings. Interested employees had the opportunity to participate in on-site firstaid training (at the Bank's headquarters in Warsaw, Gdańsk and Wrocław) and short online briefings conducted by qualified
rescue teams cooperating with SEKA. In addition, we also proposed workshops for the children of our employees. The
project was received with great interest and aimed to spread knowledge on how to safely administer first aid in life or
health-threatening situations.
In 2023, several training sessions were also carried out for employees of the Branch Network, Regional Directors andCorporate Banking Account Managers.
Managers Certification
Training program for the managers of the sales outlets in the Bank's own network. The following stages are part of thisprogram: The ABC of the manager contemporary, Targets, Development, Motivation and Team Training.
Development training for point of sale managers
A training programme has also been carried out to support managers in further developing their skills. In 2023, the first of
the scheduled training actions - "Autogestão no Tempo” (Self-Management in Time) - was launched.
Overall, in 2023, Bank Millennium, in Poland, provided 335,393 hours of training, more than half in the form of e-learning
sessions, and 7,324 employees were trained (4,683 Women and 2,641 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 is marked by the 6th 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

702023 SUSTAINABILITY REPORT

learning and sharing of knowledge, professionals with an ethicalsense, with a technique of excellence and rigour in action.
Training is also a strategic pillar at Millennium bim, with 57,388
hours of continuous training invested in 2023 (equal distribution
between men and women). The year was marked by a focus on
operational rigour, through mandatory training on subjects suchas code of conduct, money laundering, cybersecurity andoperational risk.
The training of the Employees of the Commercial Network wasalso one of the fundamental pillars, having carried out several training actions on products and services, as well as
behavioral training, which aim to leverage excellence in Customer Service.
In addition, digital training stands out, where the collaboration with technological partners in the provision of
approximately 1,000 hours of specialized training, aimed to promote innovation and sustainable competitiveness. Thisinitiative has allowed a greater dynamization of the learning process of the employees of the technology teams, enabling
the realization of training actions more adjusted to their needs.
The onboarding of New Employees is also one of the vectors of the Millennium bim Academy, with the aim of ensuringknowledge of the guidelines that guide the banking activity from the moment they join the Bank. In 2023, 195 new
employees participated in the training. In this initial training, the following topics stand out: Operational rigour; Products
and Services, Excellence in Customer Service, as well as training on the essential tools to carry out your daily work.
This investment not only drives innovation and competitiveness, but also fosters a culture of continuous learning, which isessential for the sustainability of Millennium bim.

Evaluate and recognize
At BCP Group, the individual performance assessment models, based on a process of counselling and guidance towards
the development of skills, gives rise to opportunities of dialogue between the senior staff and their Employees, enabling
the further deepening of a culture of personal accountability for the development of their careers.
In Portugal, the individual performance appraisal system implemented by the Bank - M Performance - is based on an annual
system, with the following steps:- Definition of Objectives, taking place at the beginning of the year, where the objectives for the year ahead are agreed
between managers and employees;- Mid-term Meeting, to be held in September and October, where an analysis of the degree of achievement of the defined
objectives is carried out, and the actions that are necessary to correct any negative deviations that may exist are defined.
At this stage, objectives that have become inappropriate due to the evolution of the function and tasks performed by theemployee since the beginning of the year can also be adjusted;- Annual performance evaluation, a stage in which the employee carries out his/her self-evaluation and the manager
performs the evaluation, followed by the advisory meeting with the employee, where he/she presents and justifies his/herevaluation and suggests improvement actions. After the meeting, the employee should indicate their agreement or
disagreement with the evaluation and, if desired, record the comments. Evaluations that merit disagreement from
employees are reviewed by the next level manager and reported to the Director in charge of the area. This evaluation
system has two components: one for the evaluation of behaviours, including those related with sustainability, which isequal for all Employees and is worth 30%, and another for the evaluation of objectives, personalized, which is worth 70%.

71

2023 SUSTAINABILITY REPORTAt the same time, a quarterly evaluation model was developed with the 360-degree methodology that is applied in theareas of digital development, where each employee evaluates their team co-workers and his/her manager. The manager
evaluates all members of the Team and is also evaluated by his or her own manager. At the end of the process, each
employee receives information with the average rating of their team co-workers and the rating of his/her manager.
Managers receive information with the average rating of their team's employees and their manager's rating. The
dissemination of this information aims to identify each employee's strengths and points for improvement, in order todefine and execute improvement plans, in a logic of continuous development. This evaluation system is exclusively
behavioural, that is, it only evaluates behaviours and not objectives.
The performance appraisal cycle (M Performance) completed in 2023 continues to deserve a good level of appreciation by
the vast majority of stakeholders, evaluators and evaluated, evident in the satisfaction rates with the process.
Evaluators

Evaluated

Total Responses

833

4,174

Very satisfied

33.97%

28.94%

Satisfied

50.78%

49.74%In Portugal, along with performance evaluation, the M
Development, which already has 5 editions, continues to be afundamental tool for employees to express their professionaldesires and aspirations and actively contribute to theirdevelopment. By means of this tool, the employees express
their training needs or development of specific skills, dependingon the professional development they envision. Sharing thedesires for change or evolution allows promoting a more
efficient management of employees' expectations.

Promotions(Number of Employees)
Mozambique
707
Portugal
2 000

Together with a constant attitude of encouraging theappreciation of workers, excellent performances are stimulated
Polandand rewarded, among other ways, via i) merit-based
1 347
promotions; (ii) distribution of commercial incentives; and iii)
attribution of annual variable remuneration. It is always weighted the balance between the stimulation of individual
performance and the recognition of an excellent result and the harmony with a sustainable risk profile, in the present andin the future.
The identification of the performances to be rewarded is based on the performance evaluation or on commercial objectivesof 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 indicatedcriteria (Investment Banking, Treasury Markets & International, Credit Recovery, Specialised Recovery, Real Estate Businessand Specialised Monitoring) and consists in assigning a variable remuneration based on the contribution for the earnings.
Besides, and together with the incentives systems of the commercial networks associated with business results and thevariable remuneration in central areas, Millennium bcp keeps a transversal recognition program, denominated Millennium
People.
In 2023, 21 Employees were recognized in the annual categories, 21 Employees in the Millennium Impact category, 67
Employees in the Millennium Excellence category and 3 Employees in the Millennium Trainer category.
Millennium Impact:
The Millennium Impact award honours Employees with hierarchical functions at the first and 2nd level of the structure
who have led projects and or teams in a decisive way for the Bank's success in the period under analysis. It is the Executive
Committee that selects the Employees to be rewarded.
Millennium Excellence722023 SUSTAINABILITY REPORTThis category rewards individuals who have made exceptional contributions and who, due to their attitude, have had a
relevant impact on the results of the teams in which they are inserted. The selection is made by the Coordinating Manager
and the eligibility criterion is to be at the top of the performance evaluation in the last two years.
Millennium Trainer:
This category intends to value and recognise the Bank's Employees who make exceptional contributions as Instructors at
the Millennium Banking Academy, making a sustained contribution to the sharing of knowledge, good practices anddistinctive attitudes. Among the trainers who contributed the most to the hours of training provided, in class or via elearning, will be identified and awarded the three instructors best evaluated by the trainees.
In addition to the Recognition Awards, with an impact on the motivation and visibility of the best performing employees,
at the end of 2023 Millennium bcp, in Portugal, carried out another wave of the employee satisfaction survey, which
registered a record response rate of 85%. The dimensions of leadership and commitment record very favourable indicators,
but Divisions with scores that show opportunities for improvement will be challenged throughout 2024 to develop actionplans with specific initiatives to address team feedback.
In Mozambique, Millennium bim, 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 thenecessary information to be obtained for effective coaching.
In 2023, with the involvement of several areas of the Bank in this country, we implemented significant improvements inthe process, making evaluations more objective and based on clear criteria, which is essential for the development andgrowth opportunities of employees.
In Poland, the 7th edition of the IMPAKT recognition program was held, in which employees reward their co-workers. The
program integrates the community and builds a culture of cooperation and mutual appreciation. In 2023, 50 employees
were recognized for their commitment, quality improvement, innovative solutions, and acceptance of challenges to inspireothers.
Once a year, the best employees and managers are awarded the President Award for their professional achievements. In
2023, the awards were delivered to 14 employees.
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 refer to attitudes of cooperation, efficiency,
quality and level of commitment in the execution of the tasks entrusted to them, taking into account risk mitigation andthe application of best banking practices. Depending on the group and the tasks performed, employees are evaluatedmonthly, quarterly or semi-annually.
At Bank Millennium, variable remuneration is an additional motivational component of overall compensation, shaped
through differentiated incentives whose objective is to motivate employees to achieve their business and organizational
plans. Millennium's award systems and periodic evaluation criteria have been adapted to the specificity of the work
performed by employees in the various areas of the Group. The rules for awarding bonuses are defined for individual
groups of employees in the performance appraisal rules and regulations and conditions for awarding awards.
The amount of the bonus pool always depends on the overall results and the general condition of the Bank. Bonuses arepaid monthly or semi-annually in the Bank's commercial network and in the other headquarters units involved in serving
private customers or quarterly for employees at the Bank's Headquarters.
The BCP Group continues to bet on the ongoing improvement, believing in the value that can be generated by theinnovation processes, stimulating creativity and the sharing of experiences by all Employees.
In the Table GRI (Annex 1), the indicator 404-3 breaks down the number of employees evaluated in Group BCP.
The internal programmes for the generation of ideas – Mil Ideias ,– in Portugal,- Call 2 Action-, in Poland and – Ideias que
Contam– Ideas that Matter in Mozambique are based on the recognition that the Employees are a creative force thatgenerates 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.

732023 SUSTAINABILITY REPORTIn Mozambique, with the "Forum- Ideias que Contam (Ideas that Count), a space for sharing and discussing ideas, which
throughout the year involved 164 Employees, who were responsible for 240 ideas or comments, 9 ideas are being
implemented and 102 are under analysis.
These programs, which are still being re-evaluated in Portugal and Poland, have the potential to support the improvementof the organization's internal processes, the increase of the value proposition in the offer of products and services to
Customers and the ability to adapt quickly to new realities, namely those resulting from the transformation dynamics
imposed by sustainability or digital. It also creates a context that favours the identification of good practices that can beextended to the entire organisation.

Workforce evolution
In 2023, the number of Employees of the BCP Group decreased by 0.3% (55 fewer Employees) compared to the previous
year. Around 60% of the Group's Employees BCP worked in international activities.

EMPLOYEES
2023

2022

2021

Var. % 23/22

TOTAL IN PORTUGAL

6,242

6,252

6,289

-0.2%

Poland

6,872

6,987

7,079

-1.6%

Mozambique

2,574

2,504

2,648

2.8%

TOTAL INTERNATIONAL

9,446

9,491

9,727

-0.5%

TOTAL FOR THE GROUP

15,68815,74316,016-0.3%

In Portugal, the reduction in the workforce compared to 2022 is not significant, with a decrease of 10 employees.
Resignations and retirements are the reasons with the greatest weight in the total number of departures. Resignations
decreased compared to 2022. The retirements showed an increase associated with the natural evolution of the average ageof employees (49 years) combined with the Bank's efforts to rejuvenate the workforce.
In terms of admissions, Millennium bcp maintained its strategy of strong investment in the recruitment of candidates with
distinctive and agile skills, namely in the fields of digital, technology and analytics. Also in the field of risk control, auditing
and sustainability functions, special attention was paid to the profiles recruited in order to ensure the maintenance of thelevels of rigor, excellence and ethics that characterize us.
In Poland, the number of Employees of Bank Millennium was reduced by approximately 1.6% (115 fewer Employees than in2022) to 6,872, most of whom are women, who represent 66% of the bank's total Employees, with an average age of 39
years.

74

2023 SUSTAINABILITY REPORTIn Mozambique, Millennium bim ended
2023 with 2,574 employees (2.8% more thanin 2022), with 236 new employees hired (151
to fill functions in the commercial area and74 in the central services), with genderbalance (114 Women and 122 Men).
Workers in this country have an average ageof 36 years and 10 years of seniority.

Employees Turnover and Mobility(Numeber of Employees)

2 800
2 161
2 609

As a result of the recruitment policy, thepercentage of employees with a degree
continued to rise in 2023, now representing
64% of the workforce.

1 607
2 3…

2 405

2 015

1 550

1 524

The BCP Group sees mobility as anopportunity for the Employees to develop
2021
2022
2023
their professional careers and their skills, andtherefore fosters their contact with different
Leavings
Recruitment
Internal mobility
realities of the Bank whenever possible.
Accordingly, the internal mobility processes
assume a strategic importance for Millennium since they enable the strengthening of critical thinking and the search for newopportunities for improvement , contributing for the reinforcement of more collaborative models.
In 2023, 15.3% of the Group's Employees were involved in internal mobility processes,particularly in Mozambique where
43.5% of its Employees moved from their areas/ departments.

Suppliers

GRI 204-1

At the BCP Group, the process for selecting suppliers mainly
obeys to criteria of global competence of the company, functionality, quality and flexibility of the specific solutions to acquire,continuous capacity of providing the service and compliance withsustainability criteria. In all the Group's operations, it is given
preference to purchasing from Suppliers of the respective country, registering 90.3% in payments to local suppliers.

Payments to local Suppliers(Percentage %)
92,3%

90,5%

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

90,3%

Since 2007, Group BCP, especially in Portugal and in Poland, in2021
2022
2023
cludes, as an attachment in its contracts with suppliers The Sustainability Guidelines for Suppliers which include various aspects
such as legal compliance and ethical conduct, human rights, environmental and labor practices, prevention, health and safety, and the application of these principles in the contracting of third
parties.
Since the beginning of 2022, in Portugal, we have developed and started sending to the largest suppliers (in 2023 contracts over
50,000 Eur) the Sustainability Questionnaire for Suppliers, a due diligence process that aims to understand the alignment of
supplier companies with sustainability requirements and with the Guiding Principles of Sustainability for Suppliers defined by
the Group, An instrument that has helped to evaluate, so far, 110 suppliers, with an average evaluation of 0.6 (on a scale of 0 to
1).
The Millennium bcp’s suppliers are also subject to a quality and adequacy 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. This evaluation of the quality
and adequacy of suppliers is also made by the application of a specific performance questionnaire which includes parameters
related to the level of compliance with the Supplier Principles. In 2023, 490 suppliers were evaluated, and the average score was
4.41 (in a scale of 0 to 5).
In Portugal, Millennium bcp participates in the Commitment to make Timely Payments from ACEGE, an initiative that intends to75

2023 SUSTAINABILITY REPORT

encourage the timely payment to suppliers, being an ethical exercise, which contributes not only for the entrepreneurial successbut also to enhance the economy’s competitiveness. The ratio payment/deadline agreed in Group BCP is 1.
Millennium bcp also subscribed the Charter of Principles of
BCSD Portugal- Conselho Empresarial para o Desenvolvimento Sustentável.
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.
At the same time, the Bank subscribed to the Code of Ethics of APCADEC – Associação Portuguesa de Compras e Provisionamento, which brings together a set of values, principles, and behaviours that Procurement professionals must follow, thus allowing to reinforce a posture of professionalism and transparency, leading to a reduction of financial, operational and reputation
risks of organizations.
In Poland, Bank Millennium's supplier relations are governed by the Guiding Principles of Sustainability for Suppliers, also using
the Sustainability Questionnaire for Suppliers in the supplier selection and evaluation process, like what happens in Portugal. In
addition, 100% of new contracts signed have a clause that obliges suppliers to apply the principles of the Bank MillenniumGroup's Code of Ethics.
In Mozambique, a process is underway to introduce the Sustainability Questionnaire for Suppliers to ensure compliance in procurement activity with Human Rights and other sustainability requirements.
In this country, all service contracts also have an evaluation process, which allows the quality of goods and services to be assessed, and annual surveys are carried out on the Satisfaction of Services provided by suppliers, which includes the evaluationof service levels; management and governance practices; environmental, insurance, price and quality, among other evaluation
attributes. The survey aims to measure the overall user satisfaction rate in the Bank and recommend improvement actions when
the indicators are below 75%.

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, firstand 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 LAUNDERINGThe 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 (internal and external) 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 actions of the Compliance in terms of prevention of money laundering and financing of terrorism

Within the scope of the Prevention of Money Laundering and Terrorist Financing (AML/CFT), the performance of the compliancefunction, in 2023, based on a risk-based approach, focused on attention to compliance with the following duties:76

2023 SUSTAINABILITY REPORT

▪

▪

▪

▪

▪
▪

▪

Identification and diligence for the appropriate prevalidation, substantive and formal, of the opening andmaintenance of entities and accounts and credit
operations, in a context of increased risk, highlighting theeffect of the war in Ukraine, with the issuance of
successive packages of sanctions;Examination of operations, namely the filtering oftransactions, an essential process to guarantee thecompliance with the sanctions and embargoes declaredby the national and international competent authorities,
as well as their monitoring to detect and prevent
potentially irregular situations;Control - improving the IT systems and monitoringmechanisms, adapting them to new regulatory
requirements and new risk factors, contributing to the effectiveness of the AML/CTF risk management model;
Communication, by adapting governance and processes so as to timely inform the competent authorities whenever there issuspicion 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;
Collaboration with all entities responsible for the supervision and supervision of the activity of BCP and its Subsidiaries in Portugal;
Of Cooperation with the Directorate-General for Foreign Policy of the Ministry of Foreign Affairs and with the Planning, Strategy,
Evaluation and International Relations Office of the Ministry of Finance, ensuring compliance with the regulatory and legal
framework in terms of restrictive measures;
Training - through the compliance with a training and communication plan.

This functional perimeter, based on dedicated technological solutions, also foresees the definition and management of risk models
according to the evolution of the various competing variables to establish scorings to be applied to operations. Also worth noting isthe development of new, more efficient solutions, based on automation processes for analysing the risk factors underlying new accountopenings and the screening of transactions, and the effort to update internal rules in order to align them with recent changes in thelegislative environment.
Of the various initiatives undertaken in 2023, we point out the following:
▪

▪
▪

▪
▪

▪

The implementation of automated processes related with filtering of transactions in order to ensure an ongoing and timely
compliance with sanctions and embargoes enacted by the several international organisms, within a more demanding
international context, resulting from the war in Ukraine;
The reinforcement of the control of the risk ML/TF in the customer onboarding component on the segments and jurisdictions
involved in the business relations;
Reinforcement of the integrated vision model of the Customers in the business relationship with the Bank and the inherent risk
factors, in order to strengthen the effectiveness in the fulfilment of AML/CFT duties, mainly identification and diligence, control,
examination and communication;
Continued development of automated solutions that promote alignment and cooperation between the Bank's first and secondlines of defence in the fulfilment of the various AML/CFT duties;
Reinforcement of controls over Correspondent Banks, ensuring a timely periodic review of their AML/CTF practices and policies
according to their risk, the evaluation of which now includes a set of new risk factors, in compliance with the recent regulatorychanges and restrictive measures related to the war in Ukraine;
Ongoing strengthening, training and specialisation of the Compliance Office teams within the scope of the AML/CTF, in its various
dimensions.

As for the update of internal regulations, in 2023, we must point out, among others, the reinforcement of its regulatory framework
regarding the opening and maintenance of Customers and current accounts to ensure full alignment with the new regulatory
guidelines.
-

Anti-corruption measures, prevention measures, reporting of irregularities and the Bank's and the Group's actions in thesesituations

During 2023, the BCP Group strengthened its regulatory framework on the subject of corruption prevention, now having a Plan for theprevention of risks of corruption and related infractions of the BCP Group entities in Portugal, defining, among other provisions, thegovernance model, prevention mechanisms, corruption prevention training and culture, corruption circuits and reporting and772023 SUSTAINABILITY REPORT

evaluation system.
As foreseen in the above-mentioned plan evaluation system, in 2023, the Annual Report on the Implementation of the Internal Control
System to Fight Against Corruption was issued and is available in the public.
The Anti-corruption and Anti-bribery Policy is included within the scope of the set of policies related to sustainability, and defines thatany act of corruption and bribery is illegal, unacceptable and contrary to the values and principles of ethics, integrity and transparencyof the Group, which rejects completely and 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 ensuringbusiness 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 activities of BCP Group are performed around fundamental principles of compliance with the law and internal regulations in force,as well as with the highest standards of ethics, responsibility, transparency, rigour and professionalism.
The BCP Group ensures that its activity, in the various countries where it operates, is conducted not only in compliance with the legal
requirements imposed in the fight against corruption and bribery, but also following the best practices applied in this field, making
sure 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 Global Compact Principles proposed by the United Nations, the Group is committed to complying with the principles laid down,
including combating corruption in all its forms, namely bribery, extortion and facilitation payments (Principle no. 10). The AntiCorruption and Anti-Bribery Policy supplements the principles and rules of conduct established 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 in line with the principles of other internal regulations of the Bank, namely the Related Parties Identification
regulations, 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 corruption
and/or bribery practice, potential or real, or very strong suspicions must be immediately communicated to the Audit Committee via
the communication system of irregularities defined in the Regulation on the Communication of Irregularities, so that this Committee
can determine the appropriate measures to be applied.
The communication of irregularities may be undertaken by Employees, lawyers, agents, or any other persons who provide services tothem, either on a permanent or occasional basis, in any entity of the Group, or by shareholders or any other persons. The insufficiency
of information, evidence or proof does not exempt a worker from the duty of reporting. The Audit Committee is responsible formanaging the system for reporting irregularities and ensuring the confidentiality of communications.
-

Cooperation with Authorities

Compliance with the duty of communication and interaction with the competent authorities with regard to transaction
communications and the response to requests for information is ensured, obtaining the appropriate authorizations from third parties,
when applicable.
We should mention that, in the context of the war in Ukraine, the exercise of the duties of collaboration and cooperation has been
important to allow compliance with the sanctions and embargoes on sanctioned jurisdictions, decreed by international bodies.
-Internal mechanisms for dissemination and training of Employees

In 2023 the fostering of the compliance culture was one of the Bank's important initiatives, both through the regular development of
the Training Plan and through outreach communication programmes to all areas of the Bank, in particular the commercial networks.
The headings "100% Compliance", "Expedients", "10 Commandments of compliance", "Better to prevent" and "Compliance Express"
are the most visible faces of the transformation that began in 2019, where through weekly items aimed at all Employees andcommercial structures of the Bank, it is sought to make known, clarify and support employees regarding the most important aspects
to be considered both in terms of the risk of financial crime, as in the other risks of compliance and regulatory compliance, with asimple but informative and formative language. Innovative solutions were also employed, which included the participation of
Employees from the Bank's 1st line of defence on a broad spectrum of compliance and conduct risks.
In these various sections, themes related to, among others, were addressed:782023 SUSTAINABILITY REPORT

▪

▪
▪
▪

PBC/FT (precautions to be taken when opening an account depending on the type of Customer, the importance of updating
Customer data and KYC - Know Yor Customer, information on beneficial owners, the specific risks of PEPs, mule accounts andtrade finance operations); Code of conduct (conflicts of interest, corruption, gifts and communication with external entities);
Code of conduct (conflicts of interest, corruption, gifts and communication with external entities); Sanctions and embargoes;
Sanctions and embargoes;Internal Control

Good practices in the sale of financial products were profusely addressed.
Also noteworthy is the availability of a specific page on the Compliance Office Intranet that allows Commercial Networks to track, in a
simple and quick way, which Customers have outdated identification data.
The most important training actions include:
▪
▪
▪
▪
▪
▪
▪
▪

▪

Course, by electronic means, on the Code of Conduct for all the Bank's Employees;
Course, by electronic means, on AML/CTF for all the Bank's Employees;
A set of training actions that ensure the necessary certifications in the Markets in Financial Instruments Directive (MiFID II);
Set of trainings that ensure the necessary certifications in the sale of insurance in the Bank's Networks;
Training by remote means to the commercial networks of the Bank on the importance of the document Know Your Customer andof the need to properly know the ultimate beneficial owners (UBO);
In-person training addressed to the commercial network on the requirements for the opening of a digital account;
Training session, via remote means, addressed to Employees in the communication and marketing areas, dedicated to thecompliance in advertising campaigns;
Specific training for Compliance Office employees: internal and external training, face-to-face and remote, aimed at ensuring andupdating regulatory, legislative and internal knowledge on topics inherent to the functions performed, among which we highlightthe following themes: Advanced Training in Compliance, Fraud (face-to-face training and provided by na external entity), MiFIDII Certification and Sustainability;
Integration training and InGenius programme in compliance matters: participation in the training programme for new Employees.

•

TRAINED EMPLOYEES (1)GRI 205-2

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

2023

2022

2021

VAR.% 23/22

Activity in Portugal

10,244

18,86645,816-45.7%

International activity

65,29545,81630,299

42.5%

TOTAL

75,53964,682

76,115

17.3%(1)

Attendance at training courses.

Within the context of internal communication, it should also be noted, in the application of Notice No 3/2020 of Banco de Portugal,
which regulates the governance and internal control systems and defines the minimum standards on which the organisational cultureof the entities subject to Banco de Portugal's supervision must be based, and in compliance with Article 63 thereof on thesystematisation of information, the Compliance Office ensured, in 2023, the availability, in an integrated and up-to-date manner, of
the information regarding the matters provided for in the Annex to the aforementioned Notice, in a format accessible 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;792023 SUSTAINABILITY REPORT▪

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 ofcompliance with the requirements of the internal rules regulating the process of sending proposals for the creation, change,
reintroduction and elimination of products/services.
In 2023, the internal regulations for the approval of new products were changed, including the concept of "Pooled Approval" forInvestment Funds and ETFs, a review of the concepts of Investment Product and Target Market (positive and negative), scenario
analysis of financial products and structured deposits produced by the Bank detailed in the regulations, and also the obligation tosubmit concrete quantitative data on sales outside the positive target market, i.e. within the negative target market of the product in
the formal annual Monitoring process, among other small improvements to strengthen the process.
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 and initiated a quarterly reporting process to the Compliance and Operational Risk Commission.
-

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

In pursuit of the alignment of strategies and priorities in the risk management of the Group's Operations, the effort to update theGroup policies, also applicable to International Operations, continued, ensuring the absence of overdue documents and highlighting
the adoption of Group policies related to the Code of Conduct and Conflicts of Interest.
In addition, the Compliance Office reinforced its monitoring of the Compliance function's activity in those operations, implementing aseries of initiatives, of which the following are of particular note:▪

Continuation of the effort to adapt the response capacity of the Group's entities to the challenges that compliance and regulatory
issues have been posing, namely by promoting training actions with local Compliance teams;
Consolidation of control procedures, namely on new business relationships and high ML/TF risk products;
Monitoring and collaboration in the resolution of control deficiencies identified by external auditors;
Collaboration in the implementation of new IT platforms to reinforce AML/CFT;
Reinforcement of the process of sharing information on risk clients, within the scope of AML/CFT, for greater harmonization of theirrisk classification, promoting the effectiveness of the duty of examination and completeness of information in the exercise of the
duty of communication.

▪
▪
▪
▪

The issuance of monthly analysis reports on the transactionality of high-risk customers was ensured.
We must mention the Issuance of Self-Assessment Reports on the adequacy and effectiveness of the organisational culture andgovernance and internal control systems of the Group's various operations, within the scope of the requirements defined in Notice3/2020 of Banco de Portugal;-

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

In 2023 the Bank joined several working groups within the Portuguese Banking Association (APB), in which it contributed to theidentification and development of several initiatives and actions aimed at strengthening the ML/Tf prevention system and internal
control of the Portuguese banking market.
-

Lobbying

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.

802023 SUSTAINABILITY REPORTAs for contributions to Political Entities, the BCP Group does not grant any type of monetary or financial donations to political partiesor 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 andrevised in 2023.
Summary of changes/improvements to the current version of the Code of Conduct
In 2023, the Bank updated the Group's Code of Conduct, with the following most significant changes:
▪
▪
▪
▪
▪

▪
▪

Two general principles of conduct have been added for entities covered by the Code: sustainability and confidentiality;
Strengthening corruption prevention practices by formalising new internal regulations on the prevention of corruption andrelated offences in line with the latest practices in the sector;
Adjustments to the criteria related to "gifts", making them more demanding, seeking to differentiate gifts according to social
usages and strictly prohibited gifts correlated with the Bank's activity;
Added a point on training, so that employees always seek to be up to date through the training and internal dissemination
provided by the Bank;
A new provision on the price list of each product has been added, namely that it must be drawn up on the basis of public
information, reinforcing the prohibition of any practices typified in the law that have the purpose of distorting or restricting
competition in an significant way;
The way in which communications with Customers and other external entities should be carried out has been reviewed;
Adjustment of the requirements of exclusivity in the provision of work, aligning the Code with article 129 of the Labour Code.

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 2,720 communications to local Judicial
Entities and replied to 347 requests.

COMMUNICATIONS TO LOCAL JUDICIAL ENTITIES
2023

2022

2021

VAR.% 23/22

Activity in Portugal

1,636

427

339

283.1%

International Activity

1,084

1,223

1,444

-11.4%

Activity in Portugal

226

200

174

2.7%

International Activity

121

1,484

2,073

-91.8%

3,067

3,334

4,030

-8.0%

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

GRI FS-15

OWN INITIATIVERESPONSE TO REQUESTSTOTALThe Code of Conduct (internal reference GR0021), foresees in its Article 24 the protection of Customers' assets, which stipulates that
the Group must ensure, through all legal and regulatory instruments at its disposal, the protection of 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 executedwith diligence, rigour and transparency.

812023 SUSTAINABILITY REPORT

Product and service design policies
The Policy for the Approval of New Products (internal reference 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 objective manner, determining also
the products whose sale is prohibited.
This PANP- Process for the Approval of New Products, has the following main objectives:
i.

ii.
iii.

Promote the best risk management and control practices associated with the launching and trading of new products andservices 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;
Promote a culture of compliance with the duties of satisfying the Customer’s needs ensuring that the new developed andtraded products are appropriate to the financial needs, knowledge and profiles of the segments target of the new products;
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.
ii.
iii.
iv.

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;comply with the rulings and recommendations of supervisory authorities and regulators;
Meet, in terms of features and information, the Customers’ needs and rights;
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 (internal reference OSO027), must obey 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:--

Customer protection - ensuring that customers have access to transparent, clear and complete information that identifies thecharacteristics and risks of the different types of services/products made available, so that the customer is able to make an informed
decision;
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;
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 ofits customers.
In 2023, this service order was revised to increase the competences of the DESC (Economic Studies, Sustainability and Cryptoassets
Division) in the process of development of products and services. . Hence, it is now stated in that internal regulation that the DESC
analyses whether the products and services are aligned with the policies and principles related to sustainability (internal references
GR0046 and GR0047), as well as validates all product documentation, considering the information requirements arising from theregulation on ESG products, ensuring that in the pre-contractual information there is an explanation as to whether the product orservice takes into account the main negative impacts on sustainability factors and how it does so.
Regarding approval procedures for new investment products consisting of transferable securities or whose rate of return is dependent
on changes in securities, the Bank shall ensure that the securities in question do not contravene the principles of responsible financing,so that the new products do not finance, invest in or be associated with projects or companies whose main activity is carried out in
excluded or restricted sectors.

822023 SUSTAINABILITY REPORT

Most of the investment products that make up the Bank's distribution offer, namely investment funds, financial insurance andcertificates, have been reclassified in accordance with the provisions of SFDR (Regulation (EU) 2019/2088 of the European Parliamentand of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector), allowing for easy
apprehension of investment products containing:

i.
ii.
iii.

Transparent pre-contractual information regarding the integration of sustainability risks or why they are not relevant (Article
6 of the SFDR);
Pre-contractual information with transparency with regard to the promotion of environmental or social characteristics, nothaving sustainable investment as the main objective (Article 8 of the SFDR);
Pre-contractual information with transparency with regard to the main objective of sustainable investment (Article 9 of the
SFDR).

To complement the training requirements for employees who can provide investment services to clients, in addition to the training
administered by the Institute for Banking Training (IFB) and the mandatory training provided for in MiFID II, the Bank has created astandard report for the international investment funds it distributes, which aggregates sustainability information provided by therespective producer and Morningstar. This new model incorporates information on environmental and social factors, namely withregard to the risk and ESG involvement of the portfolio and the main negative environmental and social impacts, allowing employees
to better clarify customers on these matters for each product.
The sustainability questionnaire (QESG) was also developed for customers who use investment services, which is presented wheneveradvisory or portfolio management services are at stake. This questionnaire is a variation of the suitability test and allows us to ascertain
the environmental, social and governance preferences of customers. Although recent, QESG is constantly evolving to meet the
expectations of the supervisor, the market and investors.
Within the scope of banking products and services, in 2023 several ESG characteristics and objectives were incorporated.
In terms of digitalization, the account opening service through a digital mobile key was implemented, through the ActivoBank app, theMillennium app or an online page for this purpose, accessible on the public website of Millennium bcp companies. Using this tool,
individual and corporate customers can open an account in a fast, simplified and dematerialized way, using automatic data collection,authentication and digital signature of contractual documents.
The digital follow-up process in Mortgage Credit processes was also approved, to include the possibility for the customer to attach all
the documents related to their credit process and accept the respective approval letter. This new functionality allows the customer tosubmit the necessary documents as well as issue and accept letters through digital channels, without having to go to the branch andreducing the consumption of the Group's material resources.
Regarding housing credit for acquisition or construction, a campaign was implemented to return the dossier commission and theformalization commission in cases where the financed property has an energy certification of at least B. With regard to housing credit
for works, it is possible to obtain benefits if the property has energy certification A or A+ or, in the case of properties with a lower
energy rating, which as a result of the works improve their energy class by at least 2 levels.
Regarding benefits for companies, real estate development credit services for sale or income, exempt the promoter from the paymentof the study fee and the contracting fee, in cases where the developer presents a BREEAM certification with a Very Good or Excellent
or Outstanding rating, and/or a LEED certification with a Gold or Platinum rating. To ensure that the granting of the benefit remainsaligned with the pursuit of environmental objectives, the promoter shall restore the value of the discount applied if it is found that,after the completion and obtaining of the definitive certificates, the criteria inherent to the initial certifications have not been applied.
Within the scope of personal loans, ActivoBank has developed a new product for the acquisition of energy efficiency solutions, namely
electric and conventional bicycles, scooters and mini scooters, sustainable appliances A+ or higher, placement of more efficient
windows, thermal insulation of roofs, walls or floors, entrance doors, water efficiency, boilers, biomass recuperators and more efficient
lighting systems.

832023 SUSTAINABILITY REPORT

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. These entities must guarantee and adapt their activities to the riskthat the business presents to the parties involved, as well as to the legally admissible exposure. Risk management in the BCP Group isbased on a strong culture of rigor, 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 capitalmanagement, 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 applicableregulations (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 the guarantee of the compliance with the legally defined price andcontractual conditions.
Aiming to comply with the applicable regulatory requirements and guidelines issued by national and European institutions, the service
order 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 in Macao. As a result, the requirements and procedures specifically applicable to eachloan granting are created according to the level of risk associated with it, the type of counterparty and whether it is classified as aGroup Related Party, or not. Additionally, the document determines the procedures applicable to loan recovery.
In 2023, in the attribution of the customer’s Credit Strategy, in addition to factors intrinsic to it, more transversal factors began to beconsidered, such as the assessment of sectoral risk and ESG impacts (periodically reviewed with the support of the DESC - Economic
Studies, Sustainability and Cryptoassets Division).
It is also now provided that medium and long-term credit proposals to customers who, under the terms of the rating standards in force,must have a risk rating assigned by the Rating Division, must be accompanied by a business plan of the individual companies and/or
the economic group in which they are integrated. as well as information that allows us to assess the respective ESG rating, and/or the
ESG risks that result from the nature of the business, namely in financing such as CLS loans, equipment or real estate leasing, credit forreal estate development and investment credit, commercial paper and bond loans.
In March 2023, a new group code dedicated to the principles of management and control of environmental, social and governancerisks was created, which sets out the ESG management model of the BCP Group according to the model of three lines of defence andthe responsibilities of the different bodies and commissions involved. In relation to credit risk policies, GR0047 has integrated
sustainability principles into all stages of the credit granting and monitoring process, especially considering climate and environmental
risks, highlighting the following:-

identification, management, and mitigation of the physical and transition risks that may directly affect customers' ability
to pay and the security of the Group's assets;
implementing due diligence to understand customers' vulnerabilities prior to granting credit;
consideration of ESG risk factors in credit reviews and assessments;
incorporation of a promotional pricing policy based on criteria established by BCP's Green Taxonomy;large companies are now subject to an internal ESG risk analysis process in the ordinary credit risk analysis process.

In the December review, the responsibilities of each of the Stakeholders were increased, namely the monitoring by the Credit Division(DCR), the Risk Office (ROFF) and the Economic Studies, Sustainability and Cryptoassets Division (DESC) of the number and total amountof transactions involving excluded, restricted or sensitive sectors or activities, in accordance with the Sustainable Finance Principles
defined by the Bank.
We must underline the development of a model for integrating ESG risks into the credit granting process, which involves the Rating
Division (DRAT), DCR and DESC and promotes the involvement of clients in the sharing of data on climate, environmental and social
aspects related to their activity, through the standardization of questionnaires aimed at them, as well as by automatically screening
the data collected in order to obtain ESG scores that reflect the exposure and vulnerability of companies to risk factors, thus filteringout customers and transactions that need a more in-depth analysis of ESG risk factors. In this context, enhanced due diligence
involves analyses at the company level, verifying the financial viability or the amount of exposure of the company to this category ofrisks, and at the transaction level, ascertaining whether the projects to be financed correspond to sectors or activities excluded or
conditioned by the principles of responsible financing or whether they may result in reputational damage to the Bank.

84

2023 SUSTAINABILITY REPORT

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:•

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.

•

In case conflicts of interests occur, the Group must act in a way that guarantees that the client is provided equitable andtransparent 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" that the principles, governance model andfundamental 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, aredefined. 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. In addition, 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 offunctions, information barriers and the specific process of deciding on transactions with "Related Parties", in order to defend theinterests of the stakeholders, of the Bank and of the Group. In addition, it specifies the internal responsibilities regarding themanagement 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", which is based on the International Financial Reporting Standards(IFRS)/International Accounting Standards (IAS), namely IAS 24 - "Related Party Disclosures", complemented by national legislation, inparticular 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 arisingfrom 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 theGroup’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 entities legally 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 theentities 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 andenvironmental 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 operationsof Group Banco Comercial Português. For that purpose, it provides assistance to the Group in achieving its objectives, through asystematic and disciplined approach, oriented towards the assessment and strengthening of the effectiveness of risk management
processes and governance and internal control systems.

852023 SUSTAINABILITY REPORTThe 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 - thesuitability 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 governedby the guidelines of the Institute of Internal Auditors (IIA), including the Definition of Internal Auditing, the Code of Ethics, theInternational Standards for the Professional Practice of Internal Auditing and the principles of internal auditing defined by the IIA, ofwhich the following stand out: integrity and professional competence, confidentiality, independence and objectivity.
The Internal Audit carries out integrated audits to the risks and controls of the processes defined at the Bank, in an end-to-end
perspective. The audit programmes include the assessment of behavioural issues, the compliance with the legislation and with all theremaining rules and codes of conduct, the proper use of the delegated competences and the respect for the performance principles inforce in what concerns the relations established with the Clients, internal and external.
In the course of 2023, the Audit Division monitored the status of implementation of the action plans following the recommendationsof the audit carried out in 2022, focused on the management of environmental and social risk factors (ESG) of Banco Comercial
Português, which assessed the adequacy, completeness, implementation and monitoring of the Sustainability Master Plan, itsconnection with the Overcoming 24 Strategic Plan and the adequacy of the risk factor management model ESG. In 2024, the Audit
Plan includes actions to monitor and certify the implementation of developments in policies and procedures related to ESG risk
management and the Bank's process of assessing the materiality of climate and environmental risks. Especially in what concerns theaudit programs addressed to networks, we must point out the procedures for the prevention and detection of practices eventuallyshowing 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 distributionof resources allocated to the Audit Division. Furthermore, all the claims, complaints or denouncement of situations that show sociallyinappropriate behaviours by the Employees, either among themselves or relating to Customers, are also assessed and investigated andwill originate disciplinary proceedings whenever deemed justified.
In 2023, the preventive controls carried out and the subsequent individual assessments of potentially irregular situations as well as ofsituations reported by other organic units of the Bank originated 107 preliminary investigation proceedings. In the same year, 7
disciplinary proceedings were concluded against the Bank's employees in Portugal, and no proceedings were kept in progress at theend of the year. None of the cases concerned situations of corruption, and one of the cases concerned an employee who, according to
the investigating authorities, was part of a network dedicated to money laundering.

DISCIPLINARY PROCEEDINGS FOR BREACH OF RULES

GRI 2-27

2023

2022

2021

VAR.% 23/22

6

19

24

-68%

1

0

0

-

7

19

24

-63%

Activity in Portugal
Internal Rules
External Rules
TOTAL

The Coordinating-Manager of the Audit Division is also the individual in charge for coordinating the internal audit function in all thesubsidiary companies of Group Banco Comercial Português, namely with its own internal audit team, within which he participates in
the respective Audit Committee’s, 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

862023 SUSTAINABILITY REPORT

procedures and criteria and the sharing of knowledge, namely by collaborating in the preparation and execution of audits relating tomatters 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 theyears 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 theGroup operates
Accordingly, in 2023, the Bank's Audit Division carried out audits in all those subsidiaries, selecting its scope based on the issues andrisks 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 2023, the Audit Division had a staff of 55 Employees.

872023 SUSTAINABILITY REPORT

Products and Services
Material issue:

TRANSPARENCY OF THE INFORMATION PROVIDED TO CLIENTS ON PRODUCTS AND SERVICESGRI 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 translated into a 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 maintains its commitment to Microcredit activity,with its value proposition still being recognised in the Portuguese market as analternative for the funding and of promotion and feasibility of entrepreneurial actions, continuing to perform a relevant role as an effective instrument in the fightagainst unemployment, poverty, and social exclusion.
Millennium bcp continues to be a reference bank in the support of Microcredit
projects, with lines with European guarantees, namely from the European Investment Fund, available for these operations.
The year 2023 saw a decrease in demand for these operations, which can be justified by the good economic performance and the low unemployment rate in Portugal.
In this context, the activity for the year 2023 was reduced, registering 27 operations, for a total of approximately half a million euros of credit and the creation of
42 new jobs. The volume of active credit granted to the334 operations in the portfolio, on 31 December 2023,
totalled 3,018 million Euros.

Microcredit loan activities

8(Thousand
000 euros)

1 200

6 000

4 000

5 300

2 000

3 018

552
433

334

2021

Likewise, in a period when this type of project has little
expression, Millennium bcp was not sought for promotional actions by national entities linked to the usual dissemination of these opportunities.

700

4 199

2022

Outstanding principal

200

It should be noted that Millennium bcp is a participant in
the European Microfinance Network, with which it maintains regular contact to monitor European issues related

2023

Number of operations

to Microfinance.
Millennium bcp's Microcredit, created in 2005, is recognised as a comprehensive service providing permanent support to theCustomer throughout the duration of the funding contract. Since 2005, 7,452 jobs were created resulting from projects
funded by Millennium bcp's Microcredit.

Financial Advisory Service (FAS)
Millennium bcp, with the objective of continuing to support Customers in financial difficulties, 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 Individual Customers with ongoing liabilities. The Bank's concern continues to be proposing to Customers the solution more adequate to their budget, so

882023 SUSTAINABILITY REPORT

that they can keep meeting their liabilities by reducing costs with the credit payments.
In this context, in 2023, the total value of restructuring amounted to 158 million Euros, compared to 90 million in 2022.
In Poland, Bank Millennium provides a debt consolidation loan, with the option of amortization of debts to other banks, tocustomers looking for an opportunity to reduce the costs of servicing in their current liabilities. In addition, customers canbenefit from the deferral of the payment of an instalment of a demand or consolidation loan (credit holidays), which is an
important help if the funds earmarked for an instalment in a given month are to be used for other purposes.
In the event of credit default or the customer reporting potential repayment problems, the Bank offers customers the possibility to negotiate the establishment of new mutually convenient payment terms. The conclusion of an annex or restructuringagreement containing, in its contents, amendments to the terms and conditions of reimbursement of existing liabilities,
adapted to the client's financial situation and capabilities, is possible in any form - both during a visit to the Bank's premises
and through electronic banking channels (online). The Bank offers clients a wide range of possible restructuring solutions,
including, inter alia, reducing the value of instalments paid, extending the term of the loan, changing the payment date.
Several online solutions are also implemented in the Retail area, allowing the customer to start self-help activities. Dependingon the customer's situation, the Bank allows and offers individual groups of customers the possibility, among other things, tochange the repayment schedule on their own (online).

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

Continuing the work implemented during the Portugal 2020 community framework, in 2023 the Bank developed several
initiatives to proliferate practical information and share knowledge with Clients and Stakeholders (informative emails, clarification sessions, meetings), on the investment support opportunities arising from the Recovery and Resilience Plan (RRP), as
well as the Portugal 2030 Community Framework. It should be noted that investments supported by EU funds have as atransversal concern the minimization of environmental impact, being in some cases specifically and directly aimed at thispurpose - case, for example, of support for the decarbonization of industry.
In this context, Millennium bcp has a specialized team dedicated to the permanent monitoring of the financial needs of customer projects in the implementation phase, having carried out around 800 support operations, totalling 382 million euros
contracted in the year.
In the dimension of the events organized by Millennium bcp, the highlight is the Millennium Talks Alentejo initiative, which
took place under the motto "Innovation for Sustainability". The 6th Millennium Talks conference brought to the center ofthe discussion issues such as the financing of small businesses, but also how they can grow under sustainable foundations,both in environmental, social and economic terms, and brought together more than 400 people at Arena d'Évora.
As part of the creation of an offer of Green/Sustainable products for Company Customers, the dedicated Business Marketing
Team participated in several events on Sustainability, organized by National and International entities, such as: European
Investment Bank Group, Qorus, PwC, aicep Portugal Global, Portuguese Chamber of Commerce and Industry, ICC Portugal,
Leaseurope, ALF - Portuguese Association of Leasing, Factoring and Renting, among others.
Portugal- Corporate Credit Lines
Millennium bcp is a pioneer bank in the market in the intermediation of financial instruments to support economic agents,
coming from national and European government entities.
The year 2023 was a year of particular relevance in strengthening the Sustainability offer through this type of action.
Amongst the solutions provided, we highlight the Guarantee Lines of the European Investment Fund (EIF) under the newEuropean InvestEU Programme for the period 2023 to 2027, namely regarding Sustainability, Digitalisation, Innovation andSocial. Millennium bcp has signed a guarantee agreement with the EIF for a loan portfolio worth €310 million.
These new credit lines will facilitate access to finance for SMEs (ENI, Microcredit, SMEs and Mid capitalization) and PublicCompanies. Eligible projects are included in the Sustainability domain, making the transition path to ESG criteria. This way,
the Bank promotes and fosters accessibility to services, products, infrastructures, and technologies, making companies andtheir facilities more inclusive and decarbonized.

892023 SUSTAINABILITY REPORT

Other areas covered by the InvestEU Programme concern Innovation and Digitalisation, as well as social entrepreneurship,
microfinance, cultural and creative sectors, training and education, and SME competitiveness.

Mid Cap and Large Corporate companies, with investments in the field of Innovation, were supported through the protocol
signed with the European Investment Bank (EIB), covering all economic sectors.
As part of protocols signed with the Portuguese Development Bank (BPF) and the Mutual Guarantee Societies (SGM), theBank launched the Social Sector Financing Line in the context of environmental transition, new projects or the requalificationof social facilities.
For the tourism sector and under the protocol established between Millennium bcp and Turismo de Portugal, the Bank continued to provide the credit line that enables companies to invest in projects aimed at the re-qualification of tourism undertakings and the creation of new ones, of restaurants and leisure activities, with a minimum overall score of 40 points in thetwo measures: environmental management and accessibility.
With the Decarbonization and Circular Economy Line and with special emphasis on applications to support the decarbonization of industry, the Bank is supporting the financing of projects to reduce energy consumption or the transition process to acircular economy.
Regarding support for the Agriculture and Fisheries Sector, the year 2023 was marked by a significant reduction in the credit
lines made available by the main institutional agents in the sector, namely those that are more cyclical, such as those in
Fisheries, or those of extraordinary support that seek to respond to situations of Extreme Weather or Forest Fires.
In this context, the Bank maintained the possibility of financing under the protocols signed with the Institute for the Financingof Agriculture and Fisheries (IFAP), through the Short Term IFAP Credit Lines, and with AGROGARANTE, the Mutual Guarantee
Society (SGM), through the General Protocol. A total of 131 operations were closed, with a financing value of more than 11
million euros.
- Corporate Credit products and activities
In 2023, steps were taken to create conditions for the offer of new Green/Sustainable products for Customers and projects
classified as sustainable to meet the needs of the Market and Customers and continue to increase Sustainability in Millennium
bcp's corporate credit business.
Real Estate Development
Within the scope of Real Estate Development projects, Millennium bcp supported Sustainable/Green projects, with international LEED and WELL certifications, such as "Orient Green Campos" in Parque das Nações, as well as affordable housing
projects, framed in the Controlled Cost Housing regime, as is the case of "BeLiving" in Loulé, and projects with a sustainableapproach, essentially based on the energy efficiency of the installed systems; a good example is the "Miraflores Garden" inOeiras.
% of documentary operations made in the corporatewebsite100%

Trade Finance
In Trade Finance, Millennium bcp continued to intensify the digitization of document operations on the company portal, contributing significantly to the sustainability of this business area,
improving the level of service, and reducing the administrative
burden for Customers and the Bank.

80%
60%
40%
20%
0%
2014

2016

2018

2020

2022

At the end of 2023, Millennium bcp has around 80% of the total
operations carried out digitally.

90

2023 SUSTAINABILITY REPORT

Some products are already completely dematerialized, with completion rates on the portal higher than the total, such as thediscount of allowances (86%) and the opening of import documentary credits (81%).
Factoring & Confirming% per product of operations opened on the website(Dec 2023)

Also, the online contracting process for Factoring and Confirming
operations on the companies website, has allowed the growing
digitization in the contracting of 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 areduction in physical visits to Branches, an increase in the levelof service for Customers, as well as a reduction in the administrative burden for Customers and for the Bank.

86%
69%

RDEX

81%

68%

RDEX Descontos RDEX Abonos

CDI

At the same time, the transactionality associated with Factoring & Confirming operations is carried out mainly through theuse of automatic channels, namely the company portal, contributing to the significant dematerialisation and simplification ofprocesses.
In transactions and/or instructions such as sending Confirming Remittance files, Factoring Credit Assignments and requests
for anticipation of revenues, there has been a growing use of the online channel, with usage rates of around 90%.
In 2023, the analysis of the process continued in relation to the development of an offer of new Sustainable Factoring &Confirming products for Clients whose economic activity (PPA) is on the BCP Green Taxonomy list, which allow to meet theneeds of the Market and Customers within the scope of the energy transition and/or development of projects with purposesaligned with environmental practices, and corporate governance (ESG).
- Leasing and LTR
In business credit, we also gave special importance to Green Mobility. Pollution of cars through the emission of CO2 and otherpolluting gases is one of the main causes of pollution emitted into the atmosphere, with a high environmental impact. It is in
this context that the Leasing and Renting sectors are of particular importance in the important commitment to achieve carbon
neutrality by 2050.
In 2023 we supported our customers in the acquisition of 1,084 green vehicles in car leasing, and 100 green vehicles in ALD,
corresponding to a volume of 44 million euros. We closed the year growing 37% (YoY) in car leasing, with a significant component in Sustainable credit.
During the year, we continuously developed several initiatives aimed at simplifying operations, implementing processes thatfacilitate access to information and improving the level of service we provide to our Customers.
PolandIn Poland, Bank Millennium provides loans for the construction of photovoltaic units or plants. With this product, environmentally friendly solutions, the energy transition are supported, while responding to the increase in electricity prices. The
product is available in two options:▪

▪

Photovoltaic loan - self-consumption, with which we can finance 100% of the net construction costs of micro andsmall photovoltaic installations with a capacity of up to 1 MWp, intended to produce renewable energy entirely forthe company's own needs. The loan amount is a maximum of PLN 2 million;
Photovoltaic loan - mix with which we can finance 80% of the total net construction costs of a photovoltaic installation with renewable energy production for sale and own consumption, with a minimum of 50% self-consumption.
The investment may also involve the purchase and installation of energy storage up to and including 10 MW. The
maximum loan amount in this option is PLN 20 million.

Companies can also apply to the Bank for a Technology Loan, which offers financing in the form of a non-refundable technology bonus provided by the Gospodarstwa Krajowego Bank. The Technology Loan is a continuation of the line known in thepast as the Technological Innovation Loan. It allows companies to obtain financing of up to 70% of the eligible costs of aninvestment project that involves the implementation of a new technology, understood as any significant and beneficial
change in the process, which has not previously been used in the business, and which, at the same time, improves the characteristics of the product manufactured or the service provided. The deadline for applications ended in May 2023.
For customers seeking financing for green investment projects, an Environmental Credit is available. It can be used for investments in energy efficiency, energy savings, including thermal modernization of buildings, switching from energy sources91

2023 SUSTAINABILITY REPORT

used to greener sources, and replacing equipment, facilities, or process lines with more energy-efficient ones.
Environmental Credit is a project funded by the European Funds for a Modern Economy (FENG) Operational Programme.
Support under this programme is offered to companies in the micro, small and medium-sized enterprises sector (up to 250
employees) and enterprises in the small mid-cap (up to 499 employees) and mid-cap enterprises (up to 3,000 employees)
category.
The Environmental Loan is a new form of financing for green projects, with support for businesses in the form of a nonrefundable green bond that covers up to 80% of eligible investment costs. Applications for support are accepted by the Gospodarstwa Krajowego Bank (BGK). The submission of an application to BGK is conditional on obtaining a loan commitment
letter. Bank Millennium is one of the creditor banks that issues the necessary commitment letters to obtain financing. The
call for applications in this round closed in August 2023. In 2024, it is planned the launching of 2 new notices for the Environmental Credit line.
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. To this end, Millennium Leasing uses the financingof equipment for energy generation from renewable sources. Since 2019, Millennium Leasing has been particularly active inthe development of the MilleSun program, designed to finance photovoltaic investments. The rental of panels is a solution
aimed at commercial enterprises that want to reduce energy consumption costs and change social awareness regarding environmental protection and interested in building their environmentally friendly image and ensuring the economic efficiencyof their investments. Millennium Leasing cooperates with the main trusted suppliers of this type of facilities, offering secure
financing on preferential terms and conditions and a greatly simplified process for renting green investment projects. In 2022,
Millennium Leasing launched financing for heat pumps under the MilleSun Program, and in 2023, for energy storage facilities.
In 2023 Millennium Leasing continued to implement the Mój Elektryk Program, which guarantees customers subsidized lease
payments for zero-emission vehicles. The aim of the program is to reduce air pollution emissions by reducing the consumption of fuels that generate emissions in transport. It supports and encourages the choice of zero-emission vehicles. Millennium Leasing participates in the Program since 2022. Subsidies range up to PLN 4,000 for motorcycles, scooters and quadbikes, up to PLN 27,000 for passenger cars (for transport up to 8 people) and up to PLN 70,000 for delivery vehicles up to 3.5t.
In 2023, Millennium Leasing launched a pilot Preferential Program for green asset financing, which it expects to fully implement in 2024.
The transition of the economy and the implementation of sustainable development policies by customers will be a growing
source of demand for the financing offered by Millennium Leasing in the future. We anticipate that this growth will be primarily directed towards:▪
▪
▪

investments in energy-saving machinery and equipment to reduce the amount and cost of electricity used perunit of product;
low-emission modes of transport that support the reduction of CO 2 emissions in the transport of people andcargo;
technologies for the generation and storage of energy from renewable sources.

MozambiqueMillennium bim, in Mozambique, provides the KFW Credit Line in partnership with the German Development Bank. This fundis aimed at Micro, Small and Medium Enterprises (MSMEs), with two forms (generic and specific) for the agricultural sector.
Generic fund: intended for financing investment in improving productivity and competitiveness and for job creation; andSpecific Fund: to finance investments in improving the productivity of companies in the sector.
The following lines are also available:- Credit line FECOP Calamities- created within the scope of the cooperation established between the Government of thePortuguese Republic, the Government of the Mozambican and the Mozambican Banking Association. 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 impacted by the Covid19 pandemic.
- 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 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 in922023 SUSTAINABILITY REPORT

Mozambique and boost the growth and appreciation of the Mozambican women through her involvement in activities that
contribute for the growth of the economy;

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
Personal Loans
Throughout 2023, the following products remained on the market:
▪

▪

▪
▪

▪

University Credit with mutual guarantee - under this credit line, which ended on 31/12/2023, 175 loans were
granted in the amount of 2.3 million Euros. The volume of credit granted to the 2,265 operations in the portfolio
amounts to 19.1 million euros;
University Credit (Personal Training Credit) - in this type of credit, which allows financing Customers who do notmeet the requirements to access the Mutual Guaranteed Credit line, 26 loans were granted in the amount of 423
thousand Euros;
Car leasing for new 100% electric vehicles - a product that benefits from the exemption of the initial commission(dossier commission) - 53 operations were carried out, in the amount of 2.5 million Euros;
Sustainable Buildings Personal Loan (formerly known as Renewable Energies) - this credit product, which benefits
from a lower rate, was adjusted at the end of the year, to include new purposes, now covering all investments that
aim, in addition to the production and storage of renewable energy, to increase the energy efficiency of Residential
Buildings - 61 loans were granted in the amount of 682 thousand Euros;
Energy Efficiency Personal Loan - 7 operations were granted in the amount of 93 thousand Euros.
Home Loans

The incentive for properties with better energy ratings (Green Housing Credit) was maintained, translating 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 workon 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 Feeand the cost of the Energy Certificate. During the year, this incentive was attributed in 1,613 operations.
Millennium bcp, with the objective of continuing to support Customers in financial difficulties, 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 Individual 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, during 2023, 2,624 contractual changes were made (1,589 real estate loans and 1,035 consumer credits),
totalling a restructuring value of 158 million euros (90 million in 2022) e) covering 2,305 customers (1,306 real estate loans
and 999 consumer loans).
At the same time, Millennium bcp continues to provide the Western Union Money Transfer service, allowing its Customers
from the most diverse geographies who work and reside in Portugal to continue to support their family members in theircountries of origin. These regular transfers can now be made in a distinctive way through the APP or the Website, with all theconvenience, availability, and security.
Insurances
During 2023, the partnership in the sale of insurance with Ageas (Oeste) maintained a high dynamic, with novelties in theoffer, process improvements and considerable investment in digital channels, namely in the App. We highlight:▪

At Médis, the launch of Mental Health coverage, the Traveler's Consultation in the Online Physician service,
and also Medis Dental and Light insurance for the corporate segment;932023 SUSTAINABILITY REPORT▪
▪

▪

Launch of the "Repatriation from Here to There" insurance for foreign citizens who intend to settle in Portugal;
As for financial insurance, it was guaranteed that the entire offer is classified according to Art 8 of the SFDR.
"Double" products were launched that combine Unit Linked and Savings with guaranteed capital, a guaranteed capital PPR and a Closed Unit Linked PPR. The big news was the launch of an automated investment
product with exclusive trading in the App based on three strategies of an open Unit Linked, called Easy Invest.
Regarding digital channels, the launch of journeys on the App was intensified, with the subscription of Móbis
car insurance, Médis Light, Pétis pet insurance, the new financial product EasyInvest, Servicing of Retirement
products and Pending Operations for health products without a medical questionnaire. We invested in multiple dynamization actions with associated campaigns, which allowed us to increase the weight of digital sales
in Insurance products.

Integrated Solutions
In 2023, the strategy of valuing the offer associated with the holding of an integrated solution was reinforced with thelaunch of a savings product with an exclusive remuneration for the holders of these solutions.
Positioning itself as the reference bank for young people, Millennium bcp has extended the "0€" University Offer also
to graduate, master’s or Doctor Clients who domicile their salary and adhere to the digital statement.
At the end of the year, Millennium bcp made available a new banking solution - unique in the market - aimed exclusively
at Customers 55+ with integrated solutions for banking products and services: M Advantage+, with two levels of offerthat include hospitalization expenses, health care, home help and services available in pharmacies of the M advantage+
network.
Thus, Millennium bcp:▪
▪

Reinforces its position as a promoter of the health of its 55+ Clients;
It embarks on a new chapter in its strategy of launching integrated solutions by segment, allowing its customization.

Term Resources
The Bank has been increasingly concerned about the inclusion of ESG features in resource products. In 2023, the questionnaire to assess preferences in ESG issues was developed, which aims to collect information from Clients within thescope of Advice and Portfolio Management, allowing the offer to be directed according to the preferences in terms ofsustainability shown by Clients. We direct the offer to digital channels and in the branches we privilege the sending of
emails with the documentation to the detriment of paper printouts.
All Investment products marketed by the bank are now valued taking into account the current SFDR regulations, MiFID
updates and taxonomy principles, and are not made available for marketing if the valuations are deficient in these objectives/principles.

Mozambique
Products and services with Social benefits•

IZI Microcredit – short-term financing (up to 45 days), available to Customers with salary domiciled at the Bank whomeet a set of eligibility criteria, to meet small daily expenses. This product has no interest rate, and a fee of 4% isapplied to the amount to be financed and is presented in amounts brackets ranging from 500 to 5,000 meticais (MZN).
In 2023, this financing recorded a positive evolution, with around 5.1 billion MZN being financed in 1.6 million operations.

•

Salary credit - short-term financing (up to 4 months), with subsidized interest rate and amount up to 100,000 MZN.
This financing allows eligible Customers with a salary domiciled at the Bank to meet specific needs, making it possible
to apply for a consumer credit without having to go to a branch, immediately and fully digitally, through Mobile Banking (IZI and Smart IZI), and pay it in monthly instalments. The product was accessible to 25,000 customers until December 2023 (in the pilot phase), with a universe of 6,438 users. Around MZN 269 million were financed in 11,917
operations, demonstrating that it is a product with potential for adherence by our customers.

942023 SUSTAINABILITY REPORT

Products and Services aimed at inclusion and accessibility•

Millennium IZI - the Bank's most transactional and accessible Mobile Banking platform, made available in 2013
through the USSD (*181#) section of national mobile operators. It continues to stand out for its number of users,
more than 832 thousand, and an average of 17.7 million transactions per month. With no cost of use for the Customer, it provides a wide range of features, with answers on the phone screen and/or by SMS, of which the following
stand out: balance and movement queries, transfers, purchase of Credelec top-ups and card usage features. In 2023,
it is worth mentioning two new features: salary credit and the management of the transactional limit of the Mobile
Banking+ channel.

•

Mtop and Mtop+ transactional packages - a set of products and services made available to Private Clients, in the formof packages, which allows the Clients' profiles to be adjusted to a more appropriate offer of products and services
sold by the Bank, providing a better service at a more affordable cost. The MTop and MTop+ transactional packages
comprise a Debit Card with exemption from annual fees, free withdrawals at ATM Bim, free monthly combined Statements, exemption from the fee for intrabank transfers in Mobile Banking accident insurance guarantee of 20,000,00
MZN and immediate access to digital channels (Mobile, Internet Banking and the transactional Millennium bim Line).
In addition, the Mtop+ package gives the subscriber access to a TOP credit card, its attribution depends on the Customer's credit capacity.

•

IZI Smart App - the 2nd most transactional mobile banking platform, with 250.6 thousand users, suitable forsmartphones and tablets with android and ios operating systems, available to private customers from all segments.
Investing on the digital transformation of products and services, the year 2023 was marked by the availability of somemore time deposit products on this platform, with emphasis on the Savings and Campaign Deposit Plans "Millennium
4X4 Deposit".

Launching of of incentive to the savings products and/or services•

Millennium 4X4 Deposit - 180-day term deposit, with a minimum constitution of 5,000 MZN, made available in asavings incentive campaign at the end of the year, which enabled its subscribers to participate in a contest, where
several prizes were drawn. This product, in addition to competitive rates, provides the application user with flexibility
in the management of their savings, allowing them to be set up and managed in a fully digital way.

PolandBank Millennium and its local subsidiaries offer products and services to improve the living conditions of its customers, facilitating the management of their finances and savings, while also seeking to positively impact the environment.
The Bank's goal is to provide appropriate solutions that make Clients' lives easier and help them achieve their financial goals. This approach is illustrated by
the Millennium 360° - Personal account present in the bank's offer as of April
2022. The offer of the Millennium 360° Account is universal and designed tomeet the needs of different groups of customers, regardless of their age andincome.
More and more Poles are using online banking services daily. The surveys showthat 80% of the Polish people use mobile banking services regularly, while almost half of account holders have not visited a branch for more than six
months. For 41% of the Polish people, the convenience of online banking is oneof the top two criteria for selecting an account, after no fees. The Millennium 360° account - a free account combined with awide range of personalized services in the mobile app with which we want to meet customer expectations.
In addition to being free, once a simple condition is met (5 card payments or BLIK, or 1 payment for people between 18 and 26
years old), the debit card as well as BLIK contactless payments are also free and no fee is charged for withdrawals. . This meansthat customers with mobility issues (elderly or people with disabilities) can use ATMs in convenient locations, without incurring
fees for withdrawals from third-party ATMs. Domestic transfers in PLN, standing orders and direct debits and BLIK transfers toa telephone number are always unconditionally free of charge.

The Very Useful package, offered in conjunction with the 360° Account, allows you to use home repair, medical assistance, orcomputer services. Customers who cannot afford doctors' home visits can benefit from this in case they or their children fall ill.

952023 SUSTAINABILITY REPORTThis package also provides for the assistance of a plumber or an electrician or the repair of equipment such as household
appliances, radio and television equipment, smartphones and tablets. By selecting an account in the Very Useful Package, customers can take advantage of 7 interventions per year. This package is free for 3 months after opening the account.

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 fees for account management,
while debit card and ATM withdrawals are free, provided they make at least one payment per month by card or by BLIK. Children aged 7 to 12 can use a mobile app and a 360° Junior Account card, 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.
Millennium Bank also provides mortgage loans for the renovation or modernization of properties, under which Customers canuse the funds to replace the roof or central heating system.
One of the measures implemented within the scope of the Bank Millennium Group's strategy is the integration of ESG factors
in the selection processes of assets in investment portfolios. Given the growing trend of European and global investors using
sustainability criteria in investment decision-making and considering the bank's business strategy, Millennium TFI's productoffering has been modified. Millennium TFI has transformed three separate sub-funds into the Millennium Specialized OpenEnd Investment Fund in accordance with the requirements of Article 8 of the SFDR. They promote environmental, social andcorporate governance aspects (light green products) by including them in investment selection criteria and applying certain
restrictions to investment. Customers who want to support sustainability in their investment decisions can now find the rightproducts in the Millennium TFI range.
The Sub-Funds that meet ESG criteria are available both at Bank Millennium's points of sale and through electronic channels,
i.e. the Millenet online banking system and the Bank's mobile application. Clients can choose from three sub-funds designed as
funds of funds:- Spokojny Plan Sub-Fund | whereas it invests mainly in global debt instruments;- Plano Wyważony Subfundo | que equilibra investimentos em instrumentos globais de dívida e capital;- Wyważony Plan Subfund | balancing investments in global debt and equity instruments;
In these sub-funds, sustainability (ESG) issues are assessed as a risk to the value of the investment. Investment risk is assessed
within an internal ESG risk rating system and considers ESG ratings published by independent agencies and analysts, reports
from the issuer on observed ESG principles, the type of industry in which the issuer operates, and other public information that
may serve as a source for the issuer's ESG assessment.
Each of the above-mentioned sub-funds invests at least 50% of its assets in other "green" investment funds that meet the SFDR
criteria. Additional limits have also been introduced to limit the share of funds (instruments) with poor or no ESG ratings, aswell as restrictions for issuers that do not follow good practices.
All new customers, regardless of how they have established a relationship with the Bank, receive a set of communications that
inform them of the functionalities of their account, the mobile application and Millenet, as well as the Bank's offers. The
communication is personalized according to relevant criteria so that the information offered has value for the customer (forexample, if the customer has already started using a certain option, they will not receive the message in which it is presented).
In onboarding communications, we also address issues related to the security of electronic channels and good practices in thecontext of cybersecurity.
Application for childrenChildren's app - the Bank has made available a special version of the mobile app for children aged 7 to 12. This application is
not only a useful gadget, it is also a tool to introduce children to the world of finance and to use technology safely. During theactivation, the app recognises the user and adapts the version to his/her age. The children’s app supports payments by phoneor BLIK. It is friendly to younger users and designed together with them – it has a simplified menu, children-friendly, a language
and a children-friendly design. At the same time, it gives parents full control over their children's spending, special transaction
limits, and the option for a child to block a card and for parents to block a card using its app. The app grows with the child.
After turning 13 years old, the version of the application installed on the birthday person's cell phone automatically changes tothe version currently available for people over 18 years old, offering a greater number of services.

The BCP Group provides solutions, products and services focused on the Customer anddesigned to protect the Future, People and the Planet962023 SUSTAINABILITY REPORT

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. 318 accounts with these features were opened in 2023, corresponding to a total of 5,322
accounts in the Bank's portfolio.
Regarding the support to enterprise creation investment projects by unemployed persons, through the following credit lines:i) Microinvest Line - which financed 40 entrepreneurs to a total of 622 thousand Euros; and ii) Invest+ Line which supported
21 entrepreneurs, to a total value of 861 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, which can be used with a debit card and through online banking. In 2023, 5,669 accounts wereopened, presently accruing to 26,705 accounts.

Charitable Cards
In Portugal, the credit cards issued by Millennium bcp continue to promote solidarity:
Loyalty Programme - gives Customers the possibility of exchanging the points on the card into donations to charitable institutions. In this context, the Visa/Mastercard Network cards (Points Catalog) delivered 271 donations for a total value of about
3,615 euros (199 donations in the amount of 2,675 Euros in favour of the Portuguese League Against Cancer and 72 donationsin the amount of 940 Euros in favour of AMI);
Launch of digital cards - digital versions of debit, credit and prepaid cards are now available on any channel, allowing immediate use in digital payments with smartphones or smartwatches or online purchases.
This is another important step in the experience that Millennium provides to Customers: the card available on the spot. The
physical card is issued and sent to the Customer's home or to a Branch if the Customer has requested the diversion.
In addition, the trend observed in the previous year was maintained, with a total of 10,974,280 statements issued, of which
95% were in digital format and only 5% on paper.
We 2022", launched for the first time in Portugal of 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, andspecifically in the development of actions aimed at protecting biodiversity and environmental intervention.
It is important to highlight the work that the Bank has been developing in this dimension, embodied in the fact that the vast
majority of cards issued in 2023 have already been produced in 100% recycled plastic (rPVC), which provides the same print
quality and durability as common PVC and greatly reduces the impact on the environment.
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.
Innovation must also be stimulated by the need for inclusion. In this sense, Millennium bcp is moving forward with theissuance of cards with cut, so that customers with visual impairment can easily identify the correct position in which theyshould insert the card at ATM or POS.
The first card to be launched in 2024 with this feature is the Classic credit card. This novelty will be gradually applied to all
Individuals and Companies cards.

972023 SUSTAINABILITY REPORTIn Poland, Bank Millennium cooperates with the WWF Polska (Worldwide Fund For Nature) since 2008. WWF is an independent environmental organization supported by more than 35 million people, with an active
global network in nearly 100 countries. The mission of the WWF is tostop the environmental degradation of our planet and shape a future
where people live in harmony with nature, protecting the world's biodiversity, sustainably using renewable resources, and reducing pollution
and waste.
The Bank's and WWF's joint initiatives aim to promote nature and climate conservation actions. From 2022 onwards, the activities revolvearound the motto "Forest – home for animals, breath for people and climate protection". On International Earth Day in April 2023, Bank Millennium launched a new WWF Millennium Mastercard. The card features a
new image of a lynx – the largest representative of the cat family in Europe, which is under strict species protection in Poland. For each main card issued, the Bank donates PLN 50 to WWF Poland.
The Bank also provides additional funds to support the organization's statutory activities.
Also in Poland, the goodie eCard is a convenient and environmentally friendly way togive a virtual 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”, which offers, besides discounts on a set of commercial establishments and access to the several online channels,a health insurance that covers treatment expenses for breast and uterine cancer andchildbirth health care. This card is part of the “Women's Solution”, a set of financial
products and services designed in detail to meet their needs and facilitate the management of their activities.

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 physical platforms of Millennium bcp and ActivoBank, with thedecision being made in 2022 to classify this type of product under the SFDR (Sustainable Finance Disclosure Regulation), in
accordance with their contribution/promotion to environmental and/or social sustainability:▪
▪

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

Millennium bcp had 344 sustainable Investment Funds on sale at the end of 2023 (323 Articles 8 and 21 Article 9) whose
accumulated amount in the portfolio amounted to 7,073 million euros, which represents an increase of 25% compared to2022 (5,632.2 million euros), of which about 97% is Article 8. At the end of the year, the total amount invested in these Funds
represented around 81% of the Bank's total investment fund portfolio, compared to 71% at the end of 2022.
In relation to Activobank, it had 283 funds with subscribed PUs (261 Art. 8 and 22 Art. 9), in the amount of 110.704 million
euros, representing an increase of 13.1% versus 2022. At the end of the year, the total amount invested in these Funds
represented around 73% of the bank's total investment fund portfolio.
In Poland, Bank Millennium integrated ESG factors in the asset selection processes in investment portfolios, to respond to
the growing concerns of investors with sustainability criteria in their investment decisions. Bank Millennium had 32 SRI fundswith subscribed PUs (30 Articles 8 and 2 Article 9) in 2023, for a total amount of 1,116 million euros, which represented
around 9.25% of the total funds in the portfolio. Bank Millennium SRI funds are available for sale either at branches or throughelectronic channels (homebanking and APP).

98

2023 SUSTAINABILITY REPORT

Service Quality
Material issue:

CUSTOMER SATISFACTION AND EXPERIENCEIn 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 andreliable manner, being continuously monitored and perfected, thus contributing to a progressive increase of customer satisfaction.

Customer Satisfaction Studies and Surveys

GRI 2-29

In Portugal, Millennium bcp continues to be focused 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 withhis/her experience with the Bank and the corresponding level of recommendation.
The year 2023 continued 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 doing 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 ona 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 2023:
▪

▪
▪
▪

Prestige Customers recorded a decrease to 59,7 points NPS, less 4.3 points than in 2022. This figure includes the
Prestige Customers of the "Physical" Network, which recorded a value of 61.4 NPS points, 4.3 points less than in
2022, and the "Direct" Prestige Customers (remote monitoring), in which there was also a decrease to 54.3 NPS
points, 3.9 points less than in 2022;
The same trend was observed in the NPS of the Business Customers, however with less relevance, recording also adecrease, moving down to 64.5 NPS points, less 1.0 points versus 2022;
Also in the Mass Market Customer segment, there was a slight increase in NPS translated into an increase of 0.4
points, to 73.9 NPS points;
Based on these results by segment, Millennium bcp's overall NPS is 70.4 NPS points, an indicator that had been
evolving positively since the evaluation process began in 2013, reaching in 2021 the highest value ever (72.5 points)
and which, for the second consecutive year, retracted slightly.

Another issue dealt with was the recommendation of the service provided by the Employee / Account Manager. This indicator, after reaching the best global Service Recommendation NPS value ever in 2021, retracted slightly in 2022 and remained
relatively stable in 2023, at 84.0 NPS points (-0.3 points compared to 2021), continuing to position itself at a level of excellence. Of note, the performance recorded this year in the Mass Market and Business Segments, reaching the highest value
ever in this indicator.
The Bank assessed over 117,500 experiences of Customers 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 2023, 41 surveys were carried out, using different methodologies, to monitor Customer satisfaction with the various Direct Channels and Business Networks, translating into more than 201,000 experiences with Millennium bcp evaluated
by Customers.

992023 SUSTAINABILITY REPORTAs for the satisfaction rates with the remote channels of Companies, they remained at high levels, of which the 85% of User
Customers who answered that they were satisfied or very satisfied with Internet Banking - Companies and the 78% of Mobile
Banking Companies are examples.
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.
In this way, some processes of Evaluation of Experiences, which had exclusively human intervention through telephone contact, have been migrated to automatic channels, and the new processes have been initiated, right from scratch, through these
automatic channels. This allows not only a more robust process by increasing the number of responses, but also more sustainable in terms of costs and resources. This year, examples of migration processes are the Evaluation of Prestige Customer
Experiences and Customers after Account Closure and, of new processes, the evaluation of Customer Experiences after 3
months of Account Opening.
Throughout 2023, we conducted 4 Mystery Customer actions, totalling 1,392 visits to Millennium bcp Mass Market branches
and 560 visits to branches of other banking institutions. The purpose of these actions is to assess customer servicing to beable to continuously improve the experience of our customers when they visit our Branches. We obtained a global score of
82.05%, which compares with the average global score of 67.8% of the other institutions and is above that obtained in 2022
(81.6%).
These results prove the continuous investment in improving Customer service and the positioning of Millennium bcp in theuse of the best practices.
- Reinforcement of Skills and Employee Satisfaction
In order to provide a better service experience to our Customers, within the scope of Internal Communication, it is worthhighlighting some initiatives promoted to strengthen the knowledge and skills of employees in the provision of an excellent
service:
In conjunction with the Millennium Banking Academy, some behavioural and technical training was provided to the Network,of which we highlight:▪
▪

▪

B#1 Prestige | completion of the training initiative that began in 2022 and aimed to enable the employees of the
Prestige Platform with skills in different themes;
Self Bankers Certification Program | a training initiative that, in two editions, throughout 2023, covered practicallyall employees of the Mass Market Platform, with the aim of providing them with knowledge about Self-Banking
Equipment and its use/maintenance;
Duties of Information and Assistance to the Consumer in Mortgage Credit | training initiative to raise awarenessof compliance with the legal duties associated with Mortgage Credit, which covered all Employees of the Mass
Market and Prestige Platforms.

Several internal communication items were also promoted for all employees, with a view to improving knowledge and skills
in customer service. Examples of this are the "Momento #1" project (training content on topics with an impact on the
Customer Experience), and multimedia content on new products, processes and campaigns (news, videos, direct with the
Network...).
The "Customer Experience Forum #1" was also launched, held monthly, in which different areas of customer service(products, segments and channels) are seated, to share quality indicators, and identify areas of action and improve customer
service.
As employees are one of the strategic pillars of the BCP Group, their level of satisfaction - with a direct impact on the qualityof the service guaranteed to Customers - is an important endogenous indicator for measuring the effectiveness and efficiency
perceived by the Bank.
In this way, as usual, an opinion survey was carried out on satisfaction with the internal service with all Employees whointeract (directly or indirectly) with other areas to perform their functions, with the objective of, within the scope of acontinuous improvement policy, identifying opportunities for improvement and optimization of processes, operations,
technological solutions and procedures in force. This study is carried out on an annual basis, and the overall value obtainedin 2023 was 76.8 index points (p.i.), slightly below that recorded in the previous year (78.5 p.i.), but remaining at a positive
level.

100

2023 SUSTAINABILITY REPORTIn the course of 2023, 14 specific surveys were carried out with Employees, a significant part of which were in cooperation
with DRH - Human Resources Division. Among the themes evaluated are corporate volunteering actions and events held by
the Bank, such as the Summer Festivities or the Open Day of Shooting Sports.
As in previous years, the satisfaction with the inGenicious Program was evaluated by new employees who joined the 4thedition, essential for the continuous improvement of the integration and development process of young talents. We also
carried out another 16 recurring surveys, which aim to monitor satisfaction with various internal operational processes andIT services.
- Market Studies - Satisfaction, Quality of Service and Image
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 thequality 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.
The CSI Banking Global Index is the result of two indexes, one that evaluates the satisfaction of Customers who preferentiallyuse Banks' branches (CSI Branch Index) and another that evaluates the satisfaction of Customers who preferentially use
Digital Banking solutions (CSI Digital Channels Index).
In 2023, Millennium bcp showed greater market pressure, falling to #2 in the ranking in CSI Canais Digitais and #4 in the
ranking in CSI Balcão, with scores of 76.7 pts and 75.2 pts, respectively, below those of the previous year. As a result, in the
CSI Banca index it was positioned this year in TOP3 among the 6 largest banks operating in Portugal, with a score of 76.2pts,
with Crédito Agrícola being excluded from the analysis.
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 offeredby banks.
In the 2023 study, Millennium bcp is once again considered, for the sixth consecutive year, as the"Leading Corporate Bank" in Portugal.
Millennium bcp is also elected, in terms of the image it conveys, as the "Most Innovative Bank", the"Globally Most Efficient Bank", the "Bank with the Most Suitable Products for Companies" and the"Globally Better Bank for Companies".
In the "Consumer Choice" study, Millennium bcp is once again distinguished in Portugal, in the"Large Banks" category, as "Consumer Choice" in 2024, with a final score of 84.4%. This is the
fourth consecutive year that the Bank has received this distinction. In 12 editions of the Consumer
Choice Award, Millennium has won 8 editions.
Consumer Choice aims to publicly promote the companies that have services and products witha high level of satisfaction and acceptability among consumers, helping them to make an
informed purchase regarding a given product and service.
In addition to this distinction is the "Five Star Award" 2024, in the "Large Banks" category, withan overall rating of 79.0%, above the main competitors. App Millennium also won this award inthe "Banking Apps" category, with an overall satisfaction rating of 81.3%.

1012023 SUSTAINABILITY REPORT

Millennium bcp applied for this study for the 1st time in 2022, winning the award in these twocategories for the second consecutive year in 2023.
The Five Star Award, a study by Five Star Consulting Portugal, is an evaluation system that annually
measures the degree of satisfaction that products, services and brands grant to their users, having
as evaluation criteria the main variables that influence the purchase decision of consumers,
including Satisfaction through Experimentation, Recommendation, Trust and Innovation.

2023 was a year in which Millennium bcp was, once again, rewarded and recognized for its consistent path of digitaltransformation and strong investment in innovation, in multiple reference awards.
The Millennium App was also elected "Product of the Year 2023", in the "Banking Apps" category by Product of the Year
Portugal.
In the World's Best Digital Bank Awards, promoted by Global Finance magazine, Millennium bcp won in ten categories. In
Portugal, it was distinguished as the: Best Consumer Digital Bank, Best Consumer Mobile Banking App, Best Consumer
Information Security and Fraud Management, Best in Consumer Social Media Marketing and Services, Best in Consumer
Lending and Best Consumer Open Banking APIs.
In addition to the distinctions related to the Portuguese market, Millennium bcp also won in several categories in Western
Europe, namely: Best in Consumer Social Media Marketing and Services, Best in Consumer Open Banking APIs, Best
Corporate Information Security and Fraud Management and Best Corporate Information Security and Fraud Management.
Also, the iziBizi, the first Invoicing and Management Program with a Bank Account that merges the Cloudware Businessinvoicing and management software with Millennium bcp's financial services and Open Banking API, was also distinguishedin 2023 as "Best Digital Project - Financial Services" at the ACEPI Awards - Navegantes XXI and in the "Top Tech of the Future
by a Bank" category at the PayTech Awards 2023, awards that recognize excellence and innovation in the use of IT in thefinancial and payments sector around the world.
Millennium bcp also maintained its leadership in the recognition as "Best Digital Bank" in 2023, for the 6th consecutive year,with 56% of nominations in the total number of Customers in the BrandScore Banca study, another study we monitored,
carried out by Scopen.
The main objective of this study is to evaluate the impact of Brand and Communication on Notoriety, Image, Customer
Loyalty and Attractiveness to new Customers.
In this study, Millennium bcp is also recognized as the "Best Corporate Bank", also for the 6th consecutive year, with 44% of
the nominations.
- Quality KPI’SAs Quality Key Performance Indicators (KPI's), we continue to adopt the Global Satisfaction (NPS) and Bank Recommendation (NPS) indicators from Marktest's BASEF Study.
In 2023, Millennium bcp will once again position itself at #1 in the ranking in both KPIs, among the five largest banks
operating in Portugal.
For 2024, the objectives are the same, with the aim of achieving the TOP2 among the TOP5 of the largest banks operating in Portugal.
The awards and the good results obtained in 2023 recognize the excellent service that Millennium bcp provides daily tocustomers, both individuals and companies, offering products with convenience and security through branches and digital channels, the result of a large investment in innovation. We are continuously looking for new ways to improve theservice we provide to our customers.
- Consumers

1022023 SUSTAINABILITY REPORTIn 2023, 34 Surveys were sent to the Bank by DECO - Portuguese Association for Consumer Protection (32 in 2022), on themost diverse topics, with an average response time of 8 days (in 2022 it was 10 days).
Millennium bcp is committed to meeting the expectations of its customers with convenience and agility, in a personalized
and high-quality manner, with solutions supported by excellent human service and state-of-the-art mobile and digitalplatforms, to continuously maintain the quality of service and its reputation as a Bank, as provided for in the CUSTOMERCHARTER - Individual Customers.
In the international activity, customers' overall satisfaction levels
with the Bank recorded an improvement of 1.5 index points,
moving from 79.5 to 81.0 i.p..

Satisfaction levels - External Costumers(Pontos índice)
84,0

79,5

81,0

This improvement is due to Mozambique, whose value wentfrom 71.0 to 73.0 p.i., but also to Poland, which recorded anincrease of 1.0 p.i. and now has a satisfaction level of 89.0 p.i.

2021

2022
International Activity

2023

In Mozambique, the goal for 2024 continues to be to achieve an
overall customer satisfaction index of 75 points.
In this context, several studies have been carried out in thiscountry to know the opinion, needs and expectations ofcustomers, of which the following stand out:
▪

▪

▪

▪

▪

▪

▪

▪

"Business Network Customer Satisfaction Survey", an annual online survey aimed at contributing to the increaseof cross-selling and the financial relationship of the Company's Customers. Overall satisfaction increased by 3
points compared to the previous year, to 70 points. The buy-back intention and the recommendation level
increased by 2 points compared to the levels reached in 2022, 71 and 67 points, respectively;"Prestige Customer Satisfaction Study", an online survey aimed at improving the quality of services provided,
increasing cross-selling and supporting the acquisition and retention of Prestige Customers. Overall satisfactionrose by 2 points to 74 points. The Repo and recommendation levels also rose. The intention to buy back increased by 3 points and currently stands at 75 points. The recommendation level increased by 1 point to 69
points. Satisfaction with the Customer Manager remained at the levels reached in 2022, 73 points;"M-Top Customer Satisfaction Study", an online survey with the objective of assessing the quality of services
provided in the segment. Overall satisfaction remained at the levels reached in 2022, 73 points. The buy-backlevel decreased by 2 points to 73 points. The recommendation level also decreased by 1 point to 69 points.
Satisfaction with the Manager registered a sharp decrease of 6 points, standing at 66 points;
Regarding the Bank's remote channels, and to know (i) the satisfaction of Customers with the experience ofusing IZI and (ii) reasons for not using the channel, the "Study of the evolution of dormant IZI Customers (active
and non-active)" was carried out through an online survey and a telephone survey. The Bank’s degree of overallsatisfaction fell by 4 points compared to 2022, to 79 points. The level of recommendation of the Channel stoodat 81;"bim Line Satisfaction study", a telephone survey carried out by the Employees of the Quality Division, to assess(i) the satisfaction of Customers with the experience of contact with the bim Line and (ii) reasons for not using
the channel. The level of recommendation of the Channel stood at 80;
To increase the moments in which the satisfaction of corporate customers is measured, the quarterly online
survey "NPS Assessment of Corporate and Corporate Customers" was introduced in 2023, which aims to assess the degree of recommendation of the Bank. Globally, the level of recommendation of the Bank was 69
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 69 points, 2 points increase versus 2022. The moments of Interactions evaluatedwere: (i) Account Opening; (ii) 6 months after Account Opening; (iii) Manager Contact/Visit; (iv) Financing Process (Granted); (v) Claims Management; and (vi) 6 months after transfer to the Prestige segment;
In the “Assessment of the NPS (Net Promoter Score) of the Millennium bim Branches”, carried out throughUSSD sessions, Customers are invited to give their level of recommendation of the Bank, after: (i) make a transaction over the counter; (ii) perform an operation on IZI/Smart IZI/IZI on Whatsapp; (iii) credit card activation;(iv) disbursement of NVC credit; (v) completion of a claim; (vi) contact with the BIM Line; (vii) account opening;1032023 SUSTAINABILITY REPORT(viii) periodic evaluation of Prestige Clients; (ix) carry out a transaction in ATM BIM; (x) make a transaction on
the deposit machine, and (xi) subscribe to other credits. In 2023, 218,167 Customers were interviewed and theoverall NPS was 83, rising 13 points.
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 ofoperations 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 2023 was 3.4 points(objective: 3 points).
Regarding Internal Customers, the following Surveys were carried out in 2023:▪

▪

▪

The bank made 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 66%, and enabled identifying improvement opportunities in the services provided.
In its 12th 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 of 88%. The overall level of satisfaction with the services provided by all the Millennium bim Divisions was 77 points, an increase of 7 points compared with 2022.
In order to evaluate the experiences of providing internal service by the Employees of the Commercial Network, the "Evaluation of the experience of the support provided to the Network" was carried out, where thefollowing processes are evaluated: (i) Account Opening; (ii) Issuance of Payment Order Issued; (iii) Contractingof Credit; and (iv) contact with SOS Rede.

We also continue to monitor 13 areas of central service operations through the Balanced Scorecard, a management support
tool that measures performance indicators through a simple, actionable scorecard ranging from 1 to 5 (lowest to best performance). The KPIs of each OU are distributed into 6 categories: Efficiency, Financial, Risk, Service (NS), People and Strategy.
In 2023, all the OUs evaluated showed positive results.
In Poland, Bank Millennium also benefits from robust processes and instruments to assess the quality of the service renderedto customers and recorded in 2023 a global satisfaction of 89 i.p. The objective for 2024 is to maintain the customer overalllevel of satisfaction above 85 points.
As in previous years, Bank Millennium carried out annual satisfaction monitoring studies in the Mass Market, Affluent, Small
Business and Corporate areas, which provide a holistic view of all the Bank's business segments. The main objective of thesestudies is to monitor the levels of satisfaction and recommendation of our Customers in the main lines of business and to
identify the main pain points and delighters that influence them.
In the Mass Market, satisfaction and recommendation remain at a very high and stable level, reaching in 2023 the level of NPS
50 and a fraction of satisfied customers of 93%. As in previous years, the Customers indicate as the Bank's strengths acompetitive offer (mainly our new Millennium 360° account), high quality of service, as well as modern solutions (mobilebanking - a dominant advantage especially among younger customers). The high level of satisfaction and recommendation wasproven by an external NPS benchmarking study conducted by Minds&Roses. Bank Millennium is in the TOP3 of the mostrecommended banks in Poland.
The quality of the service is evaluated by the Mystery Shopper audits, which are carried out on a quarterly basis. The current
approach is not just to monitor the implementation of standards by branch consultants. In our opinion, it is a tool to shapeattitudes through communication, indicating roles and tasks in the process of working on quality. A tool that puts the Customer
at the center, supports the implementation of business objectives and develops sales skills.
The quality activities developed by Bank Millennium were recognized in one of the most prestigious rankings of service quality- the Newsweek survey. Bank Millennium won first place in the Traditional Banking category and in the Remote Module. In
addition, Bank Millennium also took its place in the Złoty Bank ranking carried out by Puls Biznesu. The end of the year brought
another award - Bank Millennium took the podium in the 'Customer Satisfaction Ranking' carried out by ARC Rynek.
Knowing customer expectations is a critical element of any project that aims to change the process, product, communicationor sales/service model at Bank Millennium. The solutions developed, before their implementation, are tested through surveys
and interviews with customers and employees.

1042023 SUSTAINABILITY REPORTThe philosophy of monitoring Customer surveys in all business lines is based on two pillars: moments of truth and closing thecycle. 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 theCustomer; iv) we look for opportunities to improve processes, procedures and products.

ClaimsConcerning 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 orby 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 is also part of an unequivocal orientation of
the Bank for Customer service.
In Portugal, the claims are managed by the commercial areas and by the Customer Care Centre (CCC).
2023

2022

2021

VAR.% 23/22

CLAIMS RECORDED
Activity in Portugal

69 23466 55753 976

4.0%

International activity

153 938

135 271

118 777

13.8%

CLAIMS SOLVED
Activity in Portugal
International Activity (1)64 735144 84453 821132 32342 859118 450

20.3%
9.5%

(1) Includes justified complaints regarding Customer data privacy in Poland (94) and Mozambique (9) resulting from operational lapses in the processing of personal data.

In Portugal, the number of claims increased 4.0% compared to the previous year, with a total of 69,234 (66,557 in 2022), 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 improve the average resolution time to 4 days (it was
5 days in 2022), which contributed to the Bank's constant effort to resolve claims submitted by Customers as quickly as possible.
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 Customer Ombudsman is a body independent of the Bank's hierarchical structures and carries out its activities inaccordance with its own Regulations, defending and promoting the rights, guarantees and legitimate interests of Millennium
bcp's Customers who approach it.

CLIENT OMBUDSMAN'S OFFICE
Activity in Portugal

2023

2022

2021

VAR.% 23/22

RECORDED CLAIMS

2,802

2,918

2,788

-4%

Claims

2,695

2,745

2,533

-2%

Requests*

-

93

255

-

NEW CLAIMS

107

80

57

25%

Concluded

105

78

61

35%

5

11

7

-55%

100

67

54

49%

5

6

12

-17%

In favour of the Customer
In favour of the Bank
Average Response Time (days)(*) Note: As of the 2nd half of 2022, the Ombudsman's Office started to include Requests in the general category of Claims.
Thus, looking at the activity developed in 2023, the Client Ombudsman assessed 2,695 Claims, forwarded to the Customer
Service Centre, responsible for ensuring the analysis and final response to claims; and 107 Appeals (80 in 2022, up 34%), whichby their nature, were analysed and answered by the Client’s Ombudsman Office.
The Appeal provision rate was 5%, compared to 14% in 2022, and the average response time was 5 days.
The matters - from a financial product or service perspective - that raised the highest number of claims from Customers were1052023 SUSTAINABILITY REPORT

those related to "Current Accounts" (26% vs 31% in 2022), with the main topics being the maintenance and closure of accounts
and "House Credit" (17% vs 10% in 2022), with a focus on changes in contractual conditions and repayment/settlement.
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 15%.
In Mozambique, there was a very significant increase in the number of claims, which amounted to 61,213 (32,124 in 2022),
and the worsening of the respective average resolution period to 35 days (29 days in 2022), explained essentially by the Errors
Considered, claims that were accepted by the Bank, despite there being no actual error.
Poland recorded a decrease in claims by around 10% (from 103,147 to 92,725), with the average resolution time remaining at
7 days. This reduction was mainly due to the decrease in claims related to house loans and current accounts.
In order to reduce the number of claims and prevent their causes, Bank Millennium acted in three areas:▪
▪
▪

Prevention - involvement in the design and implementation phase of new products and services and participation in
the review of processes;
Elimination - identification and correction of procedural constraints, services and products based on reported claims;
Emergency - actions to reduce and mitigate the impact of unexpected service failures on customers, in order tominimize the number of claims.

As a result of this holistic approach, 145 new initiatives were designed in 2023 as part of the "Voice Of Customer" (VOC) claim
elimination program, 114 of which have already been successfully implemented.
At the same time, a number of measures have been taken to simplify the process of handling claims in order to reduce theanalysis time and increase the level of customer satisfaction:
Registration of all claims (retail and corporate) in the MilleResolver2 claims centre, and a series of changes have been
introduced to optimize the daily work in the application (robotization).
In 2023, we continued "Rumo à Qualidade” (“Towards Quality") project, whose main objectives are:▪
▪
▪

Regular training, by e-mail, to all employees responsible for handling customer claims;
Regular workshops for the development of writing skills in clear and empathetic language in solving customer
problems;
Monthly qualitative evaluation of responses to claims in the following dimensions: 1) merit and solution of customer
problems; 2) information structure (visual transparency); 3) writing sentences according to the rules of plain
language; 4) maintenance of relationships.

Continuous monthly monitoring of customer satisfaction with the claims process, with the following results:▪
▪

79% - Clear Language Index - score for the claim processing units,
87% - result of the answers' qualitative assessment.

The high quality of problem resolution and responses translates into high customer satisfaction with the claim process – 86%
in 4Q2023 (satisfied and very satisfied). Thanks to the measures taken, in 2023 customer satisfaction with the claim process
improved by 5% compared to the previous year. The year 2023 is the best since the survey began.
We continue with the "Close The Loop 2.0" program, which consists of contacting customers who, in a telephone satisfaction
survey, have commented negatively on the claim handling process. The goal is to use customer feedback to improve theproducts and services provided by the Bank and thus increase customer satisfaction.
The quality initiative "Abraçar o Problem” (“Embrace the Problem") was continued. This initiative aims to support frontline
employees in solving customer problems. Employees are periodically provided with information on how to resolve thecustomer's issue on first contact.
In 2023, we have optimized the process of handling card claims, thanks to which the customer now receives a much fasterrefund.

106

2023 SUSTAINABILITY REPORT“Escolha do Consumidor” (Consumer Choice”): Millennium bcp is once again
distinguished in Portugal in the "Large Banks" category1072023 SUSTAINABILITY REPORTFiscal Policy

GRI 207 - 1, 2 and 3

The social responsibility of the companies requires an increasing adoption of behaviours and commitments with thecommunities of which we are part of, such as the protection of environment, of social well-being and the quality of governanceof institutions. More recently, conscious, and fair tax behaviour by companies has gained prominence as an integral dimensionof the corporate social responsibility of organisations. The companies face high tax burdens (taxes, charges, and contributions),a fact that often leads to fiscal planning, able of jeopardizing the desired fiscal responsibility standards.
The payment by the companies of a fair amount of taxes 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 Report BEPS – (Base Erosion Profit
Shifting), the action of which includes controlling tax avoidance behaviours. In this context, the concept of tax governancearises as a fundamental part of corporate social responsibility, requiring companies to adopt good tax governance practices,such as: (i) compliance and timely payment of its tax obligations; (ii) the management of tax risks and (iii) the good relationshipwith 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. Awareof 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, disclosing theannex to the consolidated 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.
There are several international organizations that have promoted the disclosure of non-financial information, including tax
information. In the latter case, the Global Reporting Initiative (GRI) and the GRI 207 – Taxes standard are particularly prominent,
which came into force on January 1, 202114 and which the BCP Group incorporated into its tax policy.
The GRI - 207 standard contains the following tax disclosure guidelines: i) the company's tax policy and strategy; ii) identificationand management of tax risks; iii) the tax burden associated with the jurisdictions where companies carry out their activities,
requiring extensive reporting of information, country to country; iv) and withholding taxes made, aspects presented below.

Fiscal policy and strategy
BCP discloses on its corporate website, on the page related to Sustainability / Main Corporate Policies and Principles, thePrinciples it adopts in tax matters:
Principles on Tax matters_BCP_jan2024 (millenniumbcp.pt)

Identification and management of tax risks
BCP Group no longer carries out relevant activities in countries, territories, and regions with clearly more favourable tax
systems, as laid down in Ministerial Order no. 150/2004, of 13 February, pointing out the following aspects:▪

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

The cancellation of the banking license of BCP Finance Bank, based in the Cayman Islands, has already been requested,
whose liquidation is expected to take place in the course of 2024.

14

GRI
207
–
The
new
globalsustentability
https//www.globalreporting.org/standards/media/2482

108

reportingstandard

for

tax.

Availablein:2023 SUSTAINABILITY REPORT

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. In notes 6 and 31 of the disclosure of the annex tothe consolidated accounts, the amounts of sectoral contributions and income taxes borne by the BCP Group are highlighted;
This chapter highlights the remaining taxes that are borne or collected and delivered to the State within the scope of theactivities carried out.
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 legislativechanges. Moreover, the information publicly disclosed in this context includes an analysis of the reconciliation between thenominal and effective income tax rate applicable to the BCP Group on the individual and consolidated basis. Through thisanalysis, the BCP Group explains the weight in its earnings of the income tax accounted for, which includes, overall, the impactof current tax and the impact of deferred taxes associated with existing temporary differences. Considering 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 group of multinational companies, according to theestablished legal deadlines, respecting the last reporting period to the financial year of 2022.
Information included in the 2022 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 theultimate parent entity of a multinational group of companies, in respect of the 2022 financial year (amounts in thousands ofEuros):
Earnings
Tax jurisdiction From operations with From operations withindependent entities
related entities

Profit before income Income tax paid (on a Estimated tax for the Specific taxes paid on
tax
cash basis)
periodthe banking sector*

Total

Retained earnings andNumber of employees
other equity items

Share capital

Net tangible assets
other than cash or
cash equivalents

Portugal

4,135,407

74,987

4,210,393

377,256

2,808

3,237

22,099,325-15,429,283

6,222

301,632

China

33,403

8,245

41,64818,554

1,787

1,947

0

18,64623

3,713

France

0

0

0

0

0

0

0

25,6190082,913082,91382,805075

1843,694

0

65

6,310

6,375

5,041

0

0

230,882

55,4331

04,874,216

90,647

4,964,864-157,587

56,341

56,333

285,042894,327

6,987

123,712

381,4393,826

385,265

136,238-1

36,11565,997379,404

2,504

83,868Brasil120

12-1,0660012,425-12,347

6

208

Ireland

6,179

0

6,179

462

0

0

40

14,49800Netherlands
Cayman Islands
PolandMozambique

88,511

120,946

0*Information on the specific banking sector Taxes that have been paid is not reported to the tax authorities in the Financial and Tax Statement by country.

Presented below is the financial and tax information by country that BCP must report to the Portuguese tax authorities, as theultimate parent entity of a multinational group of companies, in relation to the year 2023 (amounts in thousands of Euros):
Earnings
Tax jurisdiction From operations with From operations withindependent entities
related entities

Profit before income Income tax paid (on a Estimated tax for the Specific taxes paid on
tax
cash basis)
periodthe banking sector*

Total

Retained earnings andNumber of employees
other equity items

Share capital

Net tangible assets
other than cash or
cash equivalents

Portugal

3,941,693

118,382

4,060,075

914,970

7,675

7,400

72,564

3,775,193

3,234,443

6,212

327,661

China

48,6186,431

55,04910,271

1,967

1,244

0

0

13,25323

3,116

France

0

0

0

0

0

0

0

0

25,61900Netherlands

0

0

0

-761

255

-70

0

18

43,0020Cayman Islands

20

0

20

-647

0

0

0

230,882

54,7871

0

6,535,189

117,348

6,652,537

290,540

141,044

134,957

13,226

314,813

1,104,441

6,872

131,452

425,583

4,852

430,435

147,127-3

31,5780

63,766359,900

2,574

84,541

17

0

17

-798

0

0

0

14,508-14,2176

171

21,233

021,233

7,578

0

0

0

40

13,07600PolandMozambiqueBrasilIreland0*Information on the specific banking sector Taxes that have been paid is not reported to the tax authorities in the Financial and Tax Statement by country.

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 2022 and 2023 translates mainly into expenditure on the reduction ofDeferred 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.

▪

As of 31 December 2023, had not yet begun in Portugal and in Poland the legislative process for the transposition into
national law of Directive (EU) of the Council 2022/2523 of 15 December 2022 on ensuring a global minimum level oftaxation for groups of multinational companies and large domestic groups in the Union, establishing common measures
for the minimum effective taxation of those groups.

▪

In terms of the activity developed in Poland, the income tax values in 2022 and 2023 were strongly conditioned by theconstitution of provisions related to legal risks associated with the home loan portfolio granted in foreign currency andby the taxes on the banking sector, partly non-deductible for tax purposes.

1092023 SUSTAINABILITY REPORT▪

The amounts of income taxes borne in Mozambique in the years 2022 and 2023 are related to the autonomous taxationthat is levied on interest on public debt earned in that jurisdiction.

▪

The results obtained in China, within the scope of the activity of the Macao Branch, are also taxed in Portugal at theincome tax level.

Specific taxation on the banking sector
The specific taxation on the banking sector bears a significant weight within the BCP Group and, as a 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 thiscontext, 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 theamounts collected, even after the change and harmonisation of the regulatory framework of the resolution mechanisms andtheir financing within the European Union from 2015. In fact, since 2015, the two domestic resolution contributions and thecontribution 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:

In the BCP Group, as can be seen from the table above, the amount of contributions and taxes on the banking sector amounted
to around 72 million Euros, with a reduction being observed compared to 2022 as a result of both the reduction in theContribution rate for the national resolution fund set by the Bank of Portugal (from 0.057% to 0.029%) or the value of theContribution to the single resolution fund determined by the Single Resolution Council.
In the case of Poland, after an increase in 2022 of the mandatory contributions resulting from the contribution to the Polishinstitutional protection fund, which did not exist in 2021, it was found that the creation of this new contribution was partiallycompensated, in 2022 and 2023, by the reduction in the amounts paid to the deposit guarantee fund (in 2022 were paid, only
the figures for the first quarter of the year) and the suspension of the payment of the special tax on the banking sector following
the activation of the Polish subsidiary's Recovery Plan.

1102023 SUSTAINABILITY REPORTThe values of taxes on the banking sector paid by the BCP Group in Poland amounted to the following amounts:(Thousand Euros)

Group Millennium Bank
2023
Contributions and taxes on the banking sector:

2022

13 226

Special tax on the banking sector

120 946-

Contribution to the Resolution Fund

36 107

13 22617 821

Contribution to the deposit guarantee fund

-

8 046

Institutional protection Fund-

58 972Other contributions borne by BCP
In 2022 and 2023 financial years, the banking activity developed by BCP Group in Portugal also supported the following Taxation:(Euros)Banco ActivoBank

BCP

BCP + ATB

2023

2022

2023

2022

2023

2022

3 183 533

2 717 728

50 402 000

62 461 431

53 585 534

65 179 159

IVA suportado

3 107 252

2 656 475

44 025 633

52 920 557

47 132 885

55 577 032

Imposto do Selo

73 97359 301

5 169 754

7 026 863

5 243 728

7 086 165

IMI e Adicional ao IMI--

698 036

2 322 853

698 036

2 322 853

IMT

-

-

395 03192 466395 03192 466

IUC

2 308

1 952

113 545

98 692115 854

100 644301 755

173 980

3 591 176

3 435 043

3 892 931

3 609 023

2 235 671

1 989 433

72 099 660

67 487 738

74 335 330

69 477 172

1 794 344

1 587 500

58 221 877

54 624 598

60 016 221

56 212 098

441 327401 933

13 877 783

12 863 140

14 319 110

13 265 074

Encargos de exploração (inclui provisões utilizadas):Pagamentos a Reguladores / Supervisiores (BCE/BdP, CMVM)

Encargos sociais exceto fundos de pensões
TSU
Contribuições para os SAMS e outras de natureza similar

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 300 M€ in 2022 and 332 M€ in 2023, and it should be stressed that theactivity of tax collection on behalf of the State absorbs significant resources:(Euros)Banco ActivoBank

Impostos retidos / cobrados a terceiros:
IRS

2023

2022

7 432 239

BCP

BCP + ATB

2023

2022

2023

2022

6 204 219

324 568 358

294 217 466

332 000 597

300 421 685

3 300 001

2 394 131

153 613 927

139 058 650

156 913 929

141 452 781

Colaboradores e pensionistas

1 926 309

1 742 242

114 707 221

109 996 629

116 633 530

111 738 871

Clientes e outros

1 373 692

651 889

38 906 706

29 062 021

40 280 399

29 713 910

9 617

8 274

26 648 424

11 504 859

26 658 042

11 513 133

3 903 835

3 575 360

107 493 965

101 299 656

111 397 800

104 875 015

218 785

226 454

27 365 123

33 020 252

27 583 908

33 246 706--

9 446 919

9 334 050

9 446 919

9 334 050

IRC
Imposto do Selo
IVA (valor líquido coletado)
IMI e Adicional ao IMI repercutido em terceiros (Leasing)

The world today is changing and various international institutions are charting a path towards greater transparency andgreater sustainability (ESG), including fiscal sustainability (Tax ESG). In this sense, the Global Reporting Initiative (GRI
207 – taxes) recommends greater tax disclosure regarding the company's tax policy and strategy and the management of
its risks. The BCP Group complies with international principles and guidelines of conscious and fair tax behavior (fairshare of taxes), disclosing its tax policies and strategies to the market and society in general.

1112023 SUSTAINABILITY REPORTBCP is an institution with a relevant contribution to the development of a more inclusive, fair andsustainable society1122023 SUSTAINABILITY REPORT

SocialResponsibility

1132023 SUSTAINABILITY REPORT

Social responsibility
The BCP Group’s strategy aims at promoting a culture of social responsibility, developing actions for and with several groupsof 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.

Main highlights 2023

POLAND
Donations: m€ 502
Volunteer Hours: 12,047 (*)
Number of Volunteers: 1,713
PORTUGAL
Donations: m€ 1,375
Volunteer Hours: 1,097
Number of Volunteers: 236

MOZAMBIQUE
Donations: m€ 536
Volunteer Hours: 160
Number of Volunteers: 60*Includes the volunteer program “Our People'23: Save the Planet”, implemented in 2023. Details about this Program in the section “Participate and Share”.

SDG

Our goals

Our contribution in 2023
Financing, support and products addressed to social enterprises

Promoting employment andsocial innovation
through support tosocial companies

Initiatives:•

Associações sem Fins Lucrativos ('Non-Profit Associations') account - account withspecial conditions.

Results:•

Opening of 318 'Non-Profit Associations' accounts, which corresponds to a total of
5,332 accounts in the Bank's portfolio.

1142023 SUSTAINABILITY REPORTSDG

Our goals

Our contribution in 2023
Community donations and collaboration on community support initiatives
Initiatives:••
Contribute to improving thequality of life and reducing
poverty•••

Initiatives of proximity and creation of social value, namely volunteering actions,which will be developed by the Foundation, DESC - Corporate Sustainability and the
Human Resources Division, within the framework of the Corporate Social Responsibility Plan in force.
Cooperation protocols with "CASA - Centro de Apoio ao Sem Abrigo” and with
"BIPP/Projeto Semear".
Partnership between Millennium bcp Foundation, Millennium bcp and EPIS - skills
volunteering through which a group of Millennium bcp Employees/Volunteers give
explanations to students from disadvantaged backgrounds.
Corporate Volunteering Action in collaboration with SEMEAR - Terra de Oportunidades project, a sustainable program for the socio-professional inclusion of young
people and adults with DID (Intellectual and Developmental Difficulties).
"Girl Move" Project - a partnership that aims to help young Mozambican women tohave 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, fairer and more inclusive society.

Promotion of financial literacy actions
Initiatives:•
Promote the financial literacyof the population, contributing to amore informed managementof personal financesand promoting entrepreneurship

•

•
•

•

"Afinal de contas" - a section launched on social networks and on the Millennium
App with the aim of deconstructing banking or financial themes.
Digital Literacy Program in partnership with APB - Associação Portuguesa de Bancos(Portuguese Association of Banks) on digital banking, aimed at the senior population that is not yet familiar with the use of electronic banking.
European Money Week and European Money Quiz, promoted together with APB.
"Financial ABC" Program - financial literacy program of the Bank Millennium Foundation, in Poland, which aims to introduce basic financial concepts to pre-school
children.
Banking Olympics - a project whose main objective is to train young people in
Mozambique in terms of financial knowledge, allowing them to make responsible
decisions in their savings management.

Promotion of a safe and secure workplace
Protecting labour rights andpromoting safe and secure
work environments for all
employees

Initiatives:••

Medical units and a dedicated medical staff on the premises.
Internal Medical Services, with specialties such as Nutrition, Clinical Psychology andPhysiotherapy.

Results:
203 visits by occupational safety and health officers to the premises

Contribute for thedevelopment ofentities in the social economy sector by the provisionof training in management

Training for managers of social entities within the scope of the GOS Program (Managementof Social Organizations) by AESE
Results:•

The 2023 edition had 53 participants (Lisbon and Oporto).

Promotion of equal opportunities
Ensure equal opportunities
at work and reduce and reduce inequalities (internally)

Initiatives:•••

Participation in Inclusion Labs - meetings of the Inclusive Community Forum (ICF)
working group.
Participation in the initiatives of iGen – Forum of Organizations for Equality.
Training “Vencer no Mundo do Trabalho” - support in the promotion of trainingthat addresses key concepts to improve social skills and the employability potentialof people with disabilities.

1152023 SUSTAINABILITY REPORTSDG

Our goals

Our contribution in 2023•

Partnership with APSA - Associação Portuguesa de Síndrome de Asperger – with aview to the inclusion of its members in the labour market.

Results:••

58% of the total training hours provided are aimed at women
Number of employees with disabilities: 235

Participate and share
At Millennium bcp, employees have the possibility to dedicate
part of their time to participate in volunteering initiatives, putting
their professional and personal skills and competences at theservice of the community. In 2023, 9 actions were carried out (5social, 1 environmental and 3 financial education and literacy) fora total of 989 hours spent, between employees and family
members, covering 14 regions of Portugal. The entities thatreceived the help and proximity support were: Banco Alimentar;
SEMEAR/Bipp; Entrajuda; C.A.S.A; Brigada do Mar; EPIS; ICF; andschools from Baixa da Banheira, Loulé, Almada and Vale deCambra (APB Program).
Of the several volunteer actions carried out with the communities,
we highlight:

Donations allocated per intervention
area
Other

(%)

7%

Culture48%

Social30%

Education

15%

Carrying out a Corporate Volunteering Action of an environmental nature - garbage
collection on Carvalhal beach - Grandola, Portugal, in a total of 3.0 kms. The action,
which was attended by 22 volunteers from different areas of the Bank, was carriedout by "Brigada do Mar", a Portuguese NGDO - Non-Governmental Organization for
Development, whose main activity is the decontamination of the coastline, within thescope of the Collaboration Protocol established between the Bank and thisOrganization in 2021. About 800 kg of garbage were collected in this initiative.
With
SEMEAR
TerradeOportunidades/Bipp, responsible for a sustainable program for the socioprofessional inclusion of young people and adults with IDD (Intellectual andDevelopmental Difficulty), based on training, development of skills for
employability and professional insertion, we carried out a volunteering action withenvironmental and social impact.
This initiative, which took place on the agricultural land explored by SEMEAR in
Oeiras, where this institution is dedicated to the production of organic vegetables,
was attended by 16 Millennium volunteers who participated in the cultivation and planting work integrated in joint teams withthe beneficiaries.
Christmas lunch promoted by CASA - Centro de Apoio ao Sem Abrigo
This solidarity initiative had the participation of 7 Millennium volunteers, who helped in tables
support, serving meals, cleaning and the general organization of the event. This lunch, a true
embrace of sharing and solidarity, provided, both to the beneficiaries and the volunteers, a
moment of sharing with impact.
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 viewto contributing to the development of the communities in which the Bank is present and responding to the challenges thatarise in the social, environmental and corporate governance axes, aligning its activities with the Group's Sustainability strategy.
We once again participated in the regular food collection campaigns promoted by Banco Alimentar, held in May and December,which were attended by 134 volunteers (70 in May and 64 in December), including workers, family and friends, distributed1162023 SUSTAINABILITY REPORT

across nine of the warehouses in Portugal (Lisbon, Oporto, Santarém, Coimbra, Funchal, Aveiro, Setúbal and Palmela), helping
in the separation and packaging of donated food.
In 2023, the partnership established between Millennium bcp, its Foundation and EPIS - Empresários pela Inclusão Social was
continued, with the aim of bringing together a group of Employees / Volunteers of the bank with interest and availability togive explanations to students in the 2nd and 3rd Cycles of schooling from disadvantaged backgrounds (with a higher risk offailure and school dropout), thus helping to promote their social inclusion through school. 18 workers (10 in 2022/2023 and 8
in 2023/2024) volunteered to give explanations of different subjects, through digital media, for 1 hour/week.
EPIS is responsible for the largest civil society engagement program in promoting
the social inclusion of young people through school success and professional
insertion, working in close partnership with the Ministry of Education, Regional
Governments and Municipalities across the country.
Millennium bcp also renewed its support for "Vela Sem Limites" project, an
initiative of the Cascais Naval Club that allows the regular practice of sailing toseveral dozen people with disabilities.

In 2023, Millennium bcp and its Foundation signed cooperation protocols with "CASA - Centro de Apoio ao Sem Abrigo"
and "BIPP/Projeto Semear", also delivering support of €10,000 to each of these institutions; and with Vela Sem Limites,
to whom a donation of €6,000 was made.
These protocols provide for several initiatives of proximity and creation of social value, namely voluntary actions, which
will be developed by the Foundation, DESC and the Human Resources Division, within the framework of the annual
Corporate Social Responsibility Plan.

In Poland, social programs are essentially managed by the Bank Millennium Foundation and focus mainly on financial
education, cultural sponsorship, academic support and volunteering. Bank Millennium Group attaches great importance to theinvolvement of its employees in social campaigns. To allow them to pursue their own volunteering ideas, internal competitions
are held to motivate the work of the banking community, in which grants are awarded to be used in the execution of solidarity
projects for employees.
Bank Millennium and the Foundation are not indifferent to environmental problems, which is why a volunteer program called"Our People'23: Save the Planet" was implemented in 2023, focused mainly on protecting the planet and aimed at all
employees of the Bank and the Group in Poland (see Bank Millennium Foundation section).
The programme is divided into two interdependent parts: sports challenge and eco-volunteering. The sporting aspect of thecampaign was based on the involvement of volunteer employees in sports activities. Every kilometre travelled and every calorie
burned contributed towards the goal of donating PLN 250,000 to the Bank Millennium Foundation. 1,508 volunteers wereinvolved in the activities, covering a total of 311,444 kilometers and burning 18 million calories between April 24 and June 25,
2023. As part of the second part of the campaign, on eco-volunteering, 26 different eco-initiatives were implemented thanks
to the amount donated to the Foundation. The eco-volunteering collectively involved 125 volunteers.
For the "Our People'23: Save the Planet" grant program, the Bank Millennium Foundation awarded an aggregate value of PLN
250,000, which supported a total of 27 volunteering actions, involving 1,713 employees and totaling 12,047 hours, the vast
majority (947) carried out in the "Our People'23: Save the Planet" eco-volunteering component.
In Mozambique, the commitment to be an active agent in the social development of the country is also assumed by the workers
of Millennium bim who, through the "Millennium bim Responsável" project, participate in actions of social and community
interest, contributing to the improvement of the quality of life and well-being of the population. This project has been an
example of the supportive, civic and altruistic attitude of Millennium bim employees.

1172023 SUSTAINABILITY REPORTThe Bank's "Millennium bim Responsável" corporate volunteering project involves employees and their families in actions ofcollective interest, implementing structuring projects in institutions without the human and financial resources to implement
them.
Reference for the "Girl Move" Project, an association that aims to help young Mozambican women to have access to more andbetter 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 isan advanced leadership and social entrepreneurship program for young university students across the country. Support isprovided to these young women at the most diverse levels, namely in the field of education, making them role models foradolescent 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 thegreatest 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 2023, Millennium bcp, in Portugal, which is also part of the companies that have supported the "Girl Move" project since
the outset (since 2016), hosted Girl Mover Cleid Sande for an internship at the Bank, in a fully face-to-face format that involved
several Bank Divisions, and which also included a Volunteering experience with Semear. In the words of Girl Mover Cleid Sande,"It was the best two weeks of my life."

From the point of view of the human resources function in liaison with the external community, the involvement of the PROVMOV Program, coordinated by the Business Roundtable Portugal Association (ABRT), of which Millennium bcp is a founder, forthe requalification of people at risk of unemployment is one of the key initiatives.
In 2023, Millennium bcp was involved in three different requalification laboratories and collaborated in the launch of therespective classes, as well as the allocation of vacancies for Professional Training in a Work Context (PTWC).
Classes

PTWC at Millennium bcp

Digital

7

4

Sales

2

3

Business Intelligence2

1 (to start in 2024)

The Bank has also organized, encouraged and monitored, in what constitutes an important contribution to the materializationof 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:

118

2023 SUSTAINABILITY REPORT“Millennium Solidário – Natal 2023”
As part of the traditional Christmas solidarity campaign, theBank and Millennium bcp Foundation have partnered, thistime, with two institutions that treat and support people(adults and children) facing serious health problems:
Instituto Português de Oncologia de Lisboa de Francisco
Gentil and ACREDITAR - Associação de Pais e Amigos de
Crianças com Cancro. This campaign, which is part ofMillennium bcp's Sustainability strategy and Corporate
Social Responsibility policy, is the result of a successful
partnership between the Bank's employees and theMillennium bcp Foundation, which supported "ACREDITAR"with 2,500 Euros and "IPO - Lisboa" with 20,000 Euros.
The Social Impact policies of Millennium bcp and its Foundation, which provide for the development of actions that createsocial value and consolidate a culture of partnership and proximity to the surrounding communities, had in this initiative arenewed example of materialization of principles of solidarity and corporate social responsibility, revealing a citizenship individual and collective - consequent and with a (real) impact on people's lives.
Employees and Millennium bcp Foundation donate 5,000 euros to UNICEF
Millennium bcp and its Foundation have partnered with UNICEF to support the victims of the earthquake that struck a large
area of Turkey and Syria last February, causing thousands of deaths and homelessness. 36 donations were made by employees
in the amount of 1,740 euros, which were complemented by a donation of 3,620 euros from the Millennium bcp Foundation.
UNICEF - United Nations Children's Fund is the main humanitarian agency that works specifically for the promotion and defenceof children's rights, being present in more than 190 countries and territories, providing humanitarian aid without discriminationof race, colour, sex, language, religion, political opinion or other. The most disadvantaged children and the countries with thegreatest needs are given priority.
Oeiras Solidária Program (POS) and local proximity actions
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 in this context that the Bank once again
made its facilities available for the annual sale of Magic Fireflies, with the main objective ofcontributing to the raising of funds in favour of CERCIs.

In 2023, we reinforced corporate volunteering actions, with the actions carried out in the main geographies of the BCP
Group involving the participation of 601 volunteers (236 in PT, 205 in PL and 30 in MZ), which corresponded to 2,504
hours of environmental volunteering and Social. To these values must be added the 1,508 volunteers (10,800 hours)
who, at Bank Millennium (Poland), contributed to raising support for initiatives to support communities and protect
nature.
This added value allowed us to exceed the target of 4% increase in hours attributable to volunteering when compared
to 2022, in which we recorded a total of 3,066 hours.
In 2024, materializing a strong social commitment that allows us to be (always) closer to communities and People, we
aim to increase by 10%, when compared to the same period last year, the total number of Volunteer hours at Millennium
bcp.

119

2023 SUSTAINABILITY REPORT

Material issue:

SOCIAL AND ENVIRONMENTAL AWARENESS

Millennium bcp, in Portugal, also carried out a number of supporting actions to institutions and initiatives able of generatingsocial 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 incondition to be reused. In 2023, including computer equipment and furniture, the Bank donated 443 assets to 14 institutions;▪

Millennium bcp donated 50,000 Euros to the organization that promoted the World Youth Day, held in Portugal between the
1st and 6th of August, in what was the largest gathering of young people from all over the world, which was attended by PopeFrancis;▪

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 Culture, the highlight was the 15th 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. Musicaldiversity, dances and the presentation of young talents were part of the event. Millennium has also
made the commitment to be the main patron of the Territory Program, of Victor Córdon Studios, recognizing the importanceof supporting young talents, from the most varied national dance schools.
In Mozambique, the Bank's social commitment is embodied in the "Mais Moçambique pra Mim" program, one of the BCP
Group's benchmarks in the field of Corporate Social Responsibility and outreach to local communities, which continued to givepriority to projects in the areas of health, education, culture and community development:
HealthThe contribution in the area of health translates into support for the implementation of projects that can provide a higher
quality of the Mozambican Health System, either through long-term projects or by responding to requests for immediate
intervention.
- Campaign for the treatment of Children with Laryngeal Papillomatosis
In order to contribute to the improvement of the quality of the Mozambican Health System, we support the project entitled"Plano Nacional Moçambicano de Rastreio e Tratamento de Crianças com Papilomatoses Laríngeas", implemented by "Massala- Associação de Médicos no Abraço a Moçambique”. As part of this project, a mission of specialist doctors, members of"Massala", carried out free surgical interventions to about thirty children at the Laryngeal Papillomatosis Screening andTreatment Centre of the Maputo Central Hospital from 24 to 28 April 2023.
- Rehabilitation of 41 Health Units in Zambezia Province
In 2023, in partnership with the Non-Governmental Organization Friends in Global Health (FGH), we supported therehabilitation of 41 Health Centres in Zambezia Province. The initiative aimed to contribute to the improvement of health carein communities affected by the devastating effects of Cyclone Freddy.
Community Intervention
Community development is another of Millennium bim's main focuses of intervention. The continuous support given to social
institutions, schools and communities in the various provinces aims to contribute to a better quality of life for people and to
the social development of the country.
- Rehabilitation of the São José de Boroma Sanctuary
We support the rehabilitation process of the São José de Boroma Sanctuary, in the province of Tete, a historical heritage sitethat is more than 100 years old. With this initiative, the bank has joined the promotion of the heritage of the Tete region andits tourism projection at national and international level. With this support, we reinforce our commitment to continuously andactively contribute to the construction, improvement and preservation of national historical heritage, allowing a greaterappreciation and enjoyment of the cultural elements of the province of Tete and the country.

1202023 SUSTAINABILITY REPORT- Celebration of Children's Day
As part of the Children's Month Celebration, we brought fun and learning to more than 600 vulnerable children.
These actions took place in Tete, Chibuto, Matutuine and Maputo, where we provided a day of fun and learning for children,
stimulating values such as interpersonal relationships, respect, tolerance and self-esteem.
In addition, the initiative raised awareness among the academic community and society in general about the importance ofsocial inclusion.
- Festival of recreational activities
As part of the existing partnership between "Mais Moçambique pra Mim" and the Ministry of Education and Human
Development, specifically in the implementation of the social inclusion and recreational activities project, another edition of"Brincando Sem Fronteiras" took place in June 2023. This project is aimed at children with special educational needs between
the ages of 6 and 12. In 2023, the project was carried out at the São Carlos Lwanga Community School, located in the Mahateneighborhood in the city of Pemba and had the participation of 200 children.
- Screening of the musical Os Saltimbancos TP50
In partnership with the TP50 group, we contributed so that children from the Community of Sant'Egidio had access to achildren's event, associating different artistic manifestations, such as music, dance, theatre, singing and photography,
stimulating healthy habits in a learning environment with empathy and fun. The children involved in this initiative followed thescreening of the children's musical "Os saltimbancos".
- Offer of food products to the Inhambane Kindergarten
Several essential goods were delivered to improve the living conditions of the children housed in the Inhambane Provincial
Nursery. This delivery was conducted by the athletes involved in the Minibasketball Project.
- Issuing Identity Cards
Within the scope of the Minibasquete project, a campaign was developed to issue Identity Cards to all children who did nothave this document, covering about 14 children.
SportsMillennium bim believes that projects aimed at training and sports practice help prepare children for their future challenges,
by acquiring fundamental principles for their development as men and women. Betting on sport is believing that, through thepractice of various sports, it is possible to transmit values and structuring principles in the growth of young Mozambicans, aswell as to alert the general population to the importance of physical activity and the need to have a healthy lifestyle.
- 16th Millennium bim Minibasketball TournamentThis tournament, supported by Millennium bim for 16 years, celebrates the practice of sports and the healthy development
and well-being of young people. Started on August 5, 2023, this edition had 2 competition poles: South zone and Central andNorth zone, with the participation of 1,230 children from 6 to 11 years old. At the end of the tournament in the South zone,
which took place in the province of Inhambane, Identity Cards were issued to 60 children participating in the tournament andfood products were delivered to the Provincial kindergarten, which houses 25 children in vulnerable situations.
CultureHaving access to culture is fundamental for the aggrandizement of human beings. This has been one of the Bank's areas ofintervention and represents a clear commitment to support the development of Mozambican arts and culture.
- A Escola do Caminho LongoIn February, we inaugurated, in partnership with the Helpo Association, the photographic exhibition called "Escola do Caminho
Longo", an initiative that portrays the dilemmas experienced by the victims of the humanitarian crisis in Cabo Delgado Province.
The life-size exhibition depicts the escape of 20 children who had to abandon their villages to survive the attacks, walking
hundreds of kilometers for several days in an attempt to reach safety.
- Albinism AwarenessWe support, in partnership with the Khanimambo Association, the painting of a mural, created within the scope of World
Albinism Awareness Day. The mural, which is located in downtown Maputo, is a creation of renowned artist Sebastião Coana,
and aims to raise awareness among the community in general about the importance of protecting and valuing people with
Albinism. With vibrant colours and symbolic elements, the artwork aims to convey a message of acceptance of difference,
respect, and equal rights.

1212023 SUSTAINABILITY REPORT

Environment- Painting of the Wall of Biodiversity
We supported the "Wall of Biodiversity" project, an action that aimed to promote the painting of about 40 murals on theprotection of Mozambican wildlife, marine and flora. The murals are located between the exit of Maputo International Airport
and the bridge of Lusaka's Accords avenue, making them the first calling card for the country, through its main entrance, theCity of Acacias.
- Conference on the dissemination of climate resilience and environmental conservation potentials
In June 2023, we supported the holding of the "I Conference on the Dissemination of Climate Resilience Potential andInvestment Attraction for Environmental Conservation". This conference was promoted by the Gorongosa District
Government, and served to consolidate business relations with the institutions present. The event was attended by theGovernor of the Province and several private, Governmental and Non-Governmental (NGOs) entities.

Financial Literacy
In all its operations, the BCP Group assumes as one its strategic goal the increase of financial literacy. An example of thiscommitment are the actions that the Bank has been continuously developing to increase the financial knowledge of citizens,particularly the youngest, always bearing in mind the importance of the widespread adoption of responsible banking
behaviours and informed decision-making. In this context, the Group promoted a diverse set of initiatives throughout 2023,
among which we highlight, in Portugal:
Within the scope of the "Financial Education" Working Group of the Portuguese Banking Association (APB), in which
Millennium bcp participates, throughout the year, APB promotes or associates itself with various events aimed at thedevelopment of financial education among different target audiences.
From the European Money Quiz, a financial literacy game dedicated to young people, to financial literacy sessions for thegeneral public, to the financial literacy content site – "Saber de Contas"... there are many initiatives that aim to promote
greater culture and financial inclusion among civil society.
“No Banco da minha Escola”

Throughout the 2023/2024 school year, the APB Financial Education Working Group, in collaboration with a group of
volunteers from Associated Banks, toured and will continue in 2024 to travel the country from North to South promoting
financial literacy in dozens of 3rd cycle and secondary schools.

▪
▪

“No Banco da Minha Escola” addresses the following topics:
1st Period: Family Budget Planning and Management (Cost vs. Income);
2nd Period: The financial system and basic financial products (Credit, Deposits, Payments, Insurance);1222023 SUSTAINABILITY REPORT▪

3rd Period: Preventing Online Fraud (the types of fraud that exist and the precautions to be taken when using digital channels).
These clarification sessions are aimed at students between the 7th and 12th grades and follow the program guidelines of the
Financial Education Framework, promoted by the National Financial Education Plan (PNFF), of which APB is a partner.
In 2023, in addition to having reinforced financial literacy content on online security, we created a section on social networks
and in the Millennium App, entitled "Afinal de contas", with content that simplifies users' daily lives. The objective is to address
topics such as filling out the IRS return and the delivery dates, the payment of IMI or the operation of the young IRS. We also
explain some investment products, such as ETFs, or any other banking or financial topic that deserves to be deconstructed forusers (Digital).
The realization of another edition of the "European Money Week", andthe "European Money Quis", which, in Portugal, are promoted by APB.
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 of the various countries involved develop a set of activities
aimed at promoting financial education among different audiences,namely children, young people and entrepreneurs. This project's main
objective is to draw attention to the importance of greater and morecomprehensive financial education in Portugal and Europe, raising awareness in the community of the importance of adopting
appropriate behaviour in present and future financial choices.
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 amplify the publication and dissemination ofcontent on Sustainability topics, in particular on Sustainable Finance, the Bank maintained
its support for the ECO Green Capital project. Among the initiatives carried out andmaterials published, we highlight the presence in the ECO Sustainability Yearbook and in
the Green Economy Forum, ECO Green Capital's annual conference dedicated to the green
economy, sustainable finance and energy transition. Following this partnership, the Bank's
sustainable initiatives, products and services were also promoted, such as the installationof photovoltaic panels in Millennium bcp Branches or the Green Real Estate Development.
The Bank also maintained, with the same objective, its support for the Jornal de Negócios
project on Sustainability. Of the activity carried out in 2023, we highlight
Millennium bcp's participation in a conference of CEOs on Sustainability
topics - "Miguel Maya - A Sustentabilidade faz transformar a forma de fazerbanca" -, but also its presence at the three ESG conferences that discussed
topics such as: Environmental (Decarbonization, Circular Economy,
Preservation and Natural Capital); Social (Equality and Diversity, Well-being,
Sustainable Cities); ESG Governance (Sustainable Finance, Sustainability
Communication and Digital Transformation in Sustainability.
In Mozambique, in 2023, the bank developed the following initiatives in the area of Education:- ADPP Protocol
ADPP is a humanitarian Non-Governmental Organization (NGO) that has been operating in Mozambique since the 1980s. The
Bank has been supporting this NGO in the training of primary teachers (grades 1-7) since 2021. This funding is intended tocreate a generation of passionate educators by actively promoting new approaches to teaching and learning, and to maketeachers capable of leading various community development initiatives in rural areas of the country.
- Banking Olympics
With the aim of introducing the newest banking and personal finance management concepts into everyday life, the Banking
Olympics aims to contribute to a generation that is more informed and aware of the choices they should have at a financial

1232023 SUSTAINABILITY REPORT

level. This project also makes it possible to raise the level of financial knowledge among the school-age population, throughthe creation of propitious moments for discussion and presentation of doubts and suggestions regarding the topics addressed.
For the first time in Nampula province, northern Mozambique, we held the 12th edition of the Banking Olympics, a financial
literacy project that has been in place since 2010, whose main objective is to train young people in matters related to thefinancial system, the environment, savings and entrepreneurship. Students from the 15 schools in Nampula had the opportunity to participate in workshops and make study visits to the Millennium bim facilities in Nampula.
In this province, we had as the winner, the Secondary School of Muatala, which presented the project "Um livro +conhecimento".
In Maputo Province, the project covered 5 Secondary Schools, and the Mártires de Mbuzine Secondary School was the winner,with the presentation of the Project on Environmental Education and Sustainable Recycling.
- Marrocane Project
More than 1000 students from the Morocane Primary School in Cabo Delgado benefited from school supply kits. This support
is part of the social responsibility strategy that includes actions to improve the teaching and learning conditions of displacedchildren and victims of the humanitarian crisis in this part of the country.
For 10 months, a campaign to collect monetary support for the purchase of school supplies took place through Digital Channels.
This campaign allowed the Bank's Customers and Partners to contribute to minimizing the negative impact of the humanitariancrisis in that part of the country. The amount acquired in this campaign was used to purchase school supplies that weredelivered to students in the district of Marrocane.
- International Money Week
On March 24th, at the Emília Daússe Secondary School, in Inhambane, we participated in the celebration of the International
Money Week (Global Money Week), through the exhibition of products and services to promote financial literacy. Under the
motto "“Planifique seu Dinheiro, plante seu Futuro” (“Plan your Money, Plant your Future”), this year the initiative included
workshops, debates, paintings, drawings, staging, simulation, quiz and a fair, with the aim of empowering children and young
people to make the right financial decisions and ensure greater financial resilience.
In Poland, in addition to the financial literacy initiatives carried out by the Bank Millennium Foundation, with emphasis on the"Financial ABC" program, a financial literacy program that aims to introduce basic financial concepts to pre-school children, in
2023 the Bank focused its support on online safety education:
The problem of fraud or embezzlement in which bank customers are the injured parties concerns the entire banking sector in
Poland and worldwide. Given that customer awareness is of fundamental importance in each case, in terms of the safe use of
online financial services, banks, and this includes Bank Millennium, intensively educate their customers in collaboration with
the Polish Banking Association, but also with their own initiatives, reminding customers about the online risks they face andthe need to comply with security rules. Bank Millennium publishes warnings and recommendations on safety rules on its
website. Whenever the Bank receives information about a new criminal action or a new method of fraud, it immediately
publishes notices to customers on its portal, in special campaigns and on social networks. Bank Millennium also adopts various
preventive measures and responds to all signals that may constitute an attempt to deceitfully obtain customer information or
funds.
The number of fraud attempts through electronic channels has remained high since 2020, which justifies the continuity ofeducational activities. Customers have continuous access to information and video materials on the Bank's website and on
mobile. As part of the "Spr@wdzam" campaign, Bank Millennium has created a special page with questionnaires on its portal,
where customers can test their knowledge of security issues and learn new information(https://www.bankmillennium.pl/sprawdzam ). The quizzes were supplemented with video clips mimicking the format of agame show. The films were also published on the Bank's YouTube channel.

▪
▪
▪
▪

Educational campaigns for customers are delivered through several channels:banners on the Portal, on the mobile app and Millenet;
PUSH messages on the mobile app;messages in the contact box available on Millenet and on the app;
SMS to less active customers on digital channels.
The campaigns are regularly updated and targeted at a variety of target audiences, including seniors, teenagers, parents ofyounger children and also selected groups based on risk profiles created at the Bank. We see the need for additional
communication with non-Polish-speaking customers, which is why we prepare communication in English and occasionally in1242023 SUSTAINABILITY REPORT

Ukrainian. Communication plans and content are created through cooperation between various departments, namely the
Security Division, Electronic Banking Division, the Quality Division and the Customer Knowledge Division. In addition, we
examine customers needs in this area to better tailor educational activities to their level of knowledge and expectations.
Cybersecurity issues are also discussed in other contexts, for example, when establishing a relationship with a new customeror submitting an application for an electronic money loan. Customers can also call a special helpline operated by a team oftrained cybersecurity consultants.
A series of videos featuring children and commentaries by the Bank's experts, created as part of the Bank Millennium
Foundation's activities, is also available on YouTube.
Customers taking their first steps in digital banking can use the website www.bankmillennium.pl/pierwszykrokonline since2020.
In 2023, cooperation with the CFO Club of the ICAN Institute, which has more than 900 members, was maintained. The CFO
Club is a development and networking initiative that brings together CFOs of companies operating in Poland. Company
representatives can participate in both webinars and presentations during on-site meetings. The topics discussed during themeetings are related to the most current challenges faced by CFOs and CFOs of companies. In 2023, the topics of the meetings
included: 1) modern financial management methods, 2) data analytics and artificial intelligence, 3) ESG strategy, 4) effective
cooperation and communication.
As part of the 6th edition of the Forbes Family Business Forum - a joint initiative of Forbes magazine and Bank Millennium - 9
meetings were held with entrepreneurs throughout Poland. It is an annual event that brings together family businesses. Bank
Millennium has been the Strategic Partner of the Family Business Forum since 2018. During this year's series of meetings, a lotof time was devoted to the need to implement the principles of sustainable development and the importance of investmentsin this area, among others, taking into account EU-supported funding.

(Millennium Volunteers at the Lisbon Food Bank – December 2023)

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
and digital literacy levels of the communities it serves

1252023 SUSTAINABILITY REPORT

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, the employees benefit from medical units and a group of full-time physicians, who ensure the provisionof curative and 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, with the aim of reinforcing the health benefits for Employees, the Bank also guarantees, in the Internal Medicine
Services at Taguspark, follow-up in the specialities of Nutrition (653 consultations vs. 543 in 2022) and Clinical Psychology (1,114
consultations vs. 853 in 2022), specialities also available to Employees located in Porto. The Physiotherapy Office is also available
at Taguspark and at the Clube Millennium bcp headquarters in Lisbon. In addition, a service is available for clinical analyses.
In Mozambique, Millennium bim has in its registered office: i) a medical office, which, in addition to medical appointments, alsooffers 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 andpsychological support.

HEALTH SERVICES (1)2023

2022

2021

VAR.% 23/22

Consultations made26,20325,22024,472

3.9%

Check-ups carried out

8,465

10,4268,344-18.8%

43,14144,733

46,862-3.6%

MEDICAL SERVICESHEALTH INSURANCES
Individuals involved(1) Includes active Employees and retired Employees.

1262023 SUSTAINABILITY REPORTThe Employees of Group BCP as well as their families also benefit fromhealth 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 2023, 221 consultations werecarried out, which resulted in 90 hospitalizations.
The disclosure, through internal communication corporate platforms, of
information on issues related with health and well-being, prevention ofillnesses and healthy life habits are a practice transversal to all operationsof Group BCP.
In Poland in 2023, the medical service provider was changed and the scope of medical services offered in the standard
medical package was expanded. As part of the newly negotiated medical package, employees now have access to a greaternumber of specialist doctors, medical procedures and access to comprehensive medical diagnostics. Standard medical
packages include, among other things, access to limited psychological consultations, preventive health programmes(vaccinations, laboratory tests), as well as periodic dental examinations extended to include dental prophylaxis. As part ofannual and ongoing health prevention, a medical diagnostic programme is available, focusing on the most common cancers
in women and men.
The private healthcare plan allows all the Group's employees to have equal access to basic and specialised medical
appointments, detailed diagnostic tests and preventive programmes. In addition, employees can acquire health packages fortheir immediate families. Upon termination of employment, retired employees will also be able to continue with the private
healthcare plan on preferential terms.
Bank Millennium Group employees in Poland enjoy the same social and financial benefits regardless of the type of
employment contract (fixed-term/indeterminate) and working hours (part-time/full-time). The value and extent of thebenefits depend on the employee's life and financial situation. A private healthcare plan is offered to employees for at least
half of the equivalent to full-time. The scope of the plan varies for different positions. Retired employees and people onparental leave also benefit from access to medical care.
Also in Poland, the Regulations of the Corporate Social Benefits Fund regulate the Bank's social activity. According to theseRegulations, the Bank pursues the following initiatives:▪
▪
▪
▪

carrying out leisure, cultural, sporting, recreational and tourist activities;
organising events and group meetings;
providing material or financial assistance;
providing financial assistance in individual events, in a particularly difficult financial, family or life situation (financial
assistance that does not have to be repaid), also in states of emergency or epidemiological risks.
The subsidiaries take advantage of the social benefits offer provided by the Bank, but finance it through their own Social
Benefits Funds.
In Mozambique, the commitment to employee health and well-being was reinforced by:▪
▪
▪

holding educational talks and screening sessions, as well as improving medical assistance conditions;introducing improvements to the conditions of medical care and medication, including updating the amounts of copayments;
holding educational talks to make employees aware of the causes, signs, symptoms, risk factors and treatment of various
illnesses, such as: Uterine Myoma, Diabetes and Hypertension, Kidney Failure, Breast Cancer, Prostate Cancer and HIV/AIDS.
In addition, screening sessions for breast and cervical cancer, participation in family planning, HIV counselling and testing,blood pressure assessment were held to safeguard the health and well-being of employees and their families and, as part ofthe drive to promote a healthy lifestyle, a new meal service was introduced in the headquarters building, which covers
around 1,000 employees. This new service provides access to meals in comfortable, high-quality conditions, with breakfast,
lunch and snack options.
These actions are fundamental to maintaining a healthy and productive working environment.

1272023 SUSTAINABILITY REPORTThe Bank maintains a policy of making social benefits available to employees, which it endeavours to improve andcomplement each year, always with the aim of meeting the needs expressed by employees.
Financial initiatives were developed to mitigate the impact of rising interest rates and, in an effort to ensure a balance
between employees' financial needs and their ability to pay, the maximum amount of credit for social purposes wasincreased.
In the aftermath of Cyclone Freddy, significant resources were mobilised for disaster relief for employees and their families,
including assistance to rebuild homes. This support was provided through the immediate granting of an amount for thepurchase of basic necessities and the allocation of a non-refundable amount for the reconstruction of houses, plus the
granting of a credit line with a subsidised interest rate.
Partnerships for health benefits were also set up with various entities to provide benefits to employees and their families.
Of particular note are the protocols that grant permanent discounts for medical assistance for breast, cervical and prostatecancer screening, partnerships with gyms and kindergartens.
Millennium bim once again contributed to the celebration of Christmas, offering presents to 2,643 of its Employees' children.
In Portugal, since 2017, Thursdays at Millennium bcp's facilities have been "Farm" days. 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. Thisinitiative, 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 Banka 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, in terms of internal communication, 5,714 pieces were published on the intranet, 327 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”, acommunication vehicle though which the news and the most relevant events that mark the activities of Millennium in
Portugal, Poland and Mozambique are shared. In 2023, 100 editions were carried out (Portuguese and English), with anaverage circulation of 6,242 units per edition..
BCP Group provides a work place 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 andhealth (HST) inspection visits to the premises, so as to find and correct malfunctions. During 2023, the Group carried out 203
visits and 2 air quality analyses.
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 is a permanent
concern in the management of its daily activity - the specific corporate policyon this matter incorporates elements that reflect the reality of Banco de Portugal and the applicable legal and regulatory context, but also good practices ofvoluntary implementation.
The Bank maintained a regular and constant flow of information and training
on matters of Health and Safety at Work throughout 2023, 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 311 employees (in 2023 only new employees or those returningfrom long-term absence were invited to take this training). 42 Employees received specific training on means of 1st intervention
against fires.

1282023 SUSTAINABILITY REPORTAs part of its Social and Environmental Responsibility policy, Millennium bcp has a partnership with CP - Comboios de Portugal
encouraging the use of trains for long-distance journeys. This partnership makes it possible to reduce the costs of employee
travel, while at the same time making it possible to travel more comfortably and quickly, to use mobile phones and computers
and to enjoy free newspapers and magazines and a welcome drink. In addition, any Employee has access to a 15% discount on
the purchase of tickets for personal journeys on the Alfa Pendular and Intercidades services, in comfort or 1st class seating.
In addition, to make travelling easier for Employees who work at Taguspark, Millennium bcp provides a free daily bus service
between Lisbon and Taguspark, every working day and at different times in the morning and evening.

Remote Working
Millennium bcp, in Portugal, based on the experience of teleworking due to the Covid-19 pandemic, approved in 2022 a new"Regulation on teleworking" in addition to the one legally provided for. This regime foresees, for compatible functions(essentially Central Services), the possibility of using a hybrid work regime, with a weekly distribution of 60% in the workplace(3 days) and 40% in remote work (2 days), at each employee's discretion, thus promoting a better balance between workand personal life.
In Poland, on the other hand, the Bank recommends that employees work 50% of their time in the office and 50% remotely,with the heads of the Organic Units authorised to change these proportions as required, with regard to the tasks and projects
underway and the effectiveness achieved by the teams.
This hybrid regime allows for a better balance between professional and personal/family life, reconciling the interests andpriorities of the Bank and its employees, while also helping to reduce commuting.

The BCP Group offers a diversified set of social benefits to Employees, which havebeen reinforced to respond to new challenges and improve the balance between
Professional and Personal life

129

SUSTAINABILITY REPORT 2023

CreditBCP Group employees have the possibility of getting credit to purchase a permanent residence 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)

2023

2022

2021

AmountEmployees

AmountEmployees

AmountEmployees

In portfolio

374.4

5,833

437.3

6,637

574.4

7,395

Granted in the year

21.2

175

17.9

148

22.8

158

In the portfolio

10.3

2,230

10.2

2,047

9.64

2,210

Granted in the year

4.0

922

3.7

848

2.4

876

HOME LOANS

SOCIAL PURPOSES(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.

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SUSTAINABILITY REPORT 2023

ParentingSupporting the needs of parents in the early years of their children's lives
and pregnancy protection are also Millennium bcp's priorities.
Aware of the demands that maternity and paternity entail, the Bank has
had a Parenthood Protection Programme - “Bebé Millennium” (Baby Millennium) - in place since 9 September 2015, which aims, on the one hand,to celebrate the special moment when they become parents and, on theother, to create the necessary conditions for Employees to find a balance
between work and family life.
In 2023 we celebrated the birth of 100 babies with the granting of individual Millennium Baby Vouchers worth €849.42 and around 1,324 were able
to enjoy their children's birthday afternoon with them.
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.
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.
Also, within the scope of social and corporate responsibility, Millennium bcp has been reinforcing the support and assistanceprovided to employees in situations of prolonged absence due to illness, through its medical services.
The bank also provides financial support of a social nature for active employees, retirees and pensioners in cases of special
economic and social need, adapting the corresponding means of financial support to each case.
The provision of community gardens for employees, located in Taguspark, has had a very positive impact on employees, promoting team spirit as well as environmental sustainability and healthy living practices.
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 the permanent development of its employees' skills and in addition to the contents detailed
in the “Training” chapter, Millennium bcp also provides for the payment of external training or the co-payment of academic
qualification courses in certain situations, where the relevance to the duties performed by the employee is demonstrated.
In Portugal, in terms of education and through monthly subsidies, the Bank also supports: i) Employees who qualify as StudentEmployee, granting a total of 7,371 Euros, to 44 Employees; ii) Employees with children of school age, supporting 3,257 Employees, totalling 1,165 thousand Euros; and iii) school-age children of deceased Employees. The bank supported 81 children
and young people with 231,575 Euros.

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SUSTAINABILITY REPORT 2023

Inclusion and Diversity Programmes
As part of its diversity and equal opportunities policy, Millennium bcp
renewed its signature of the “Commitment to Inclusion” of the Inclusive Community Forum (ICF) in 2022.
ICF is a Nova SBE initiative dedicated to the lives of people with disabilities. Its objective is to promote a more inclusive community,
through the construction of a network made up of everyone who intervenes in these people's lives, challenging them to play an activerole in co-creating solutions, namely companies.
The Journey to Inclusion is the path proposed by ICF to companies that want to be more inclusive in relation to people withdisabilities and that, to this end, decide to sign the “Commitment to Inclusion”. This journey emerged as a response to a market
need – the creation of a set of clear steps to achieve inclusive recruitment.
In 2022, the Bank also entered into a partnership with APSA – Associação Portuguesa de Syndrome de Asperger (Portuguese
Asperger Syndrome Association), with a view to including its associates in the labor market.

Culture and Leisure
Activity of Clube Millennium bcp - Initiatives developed in 2023
The Millennium bcp Club is the Cultural and Recreational Association for employees and former employees of the Banco Comercial Português Group, and its mission and objective is to encourage the practice of cultural, leisure and sporting activities, promoting socialising among its Members and their families and also their participation in civic, humanitarian and solidarity causes,
thus contributing to improving their well-being and promoting quality of life.
To fulfil its objective and mission, the Club offers its 34,455 members (10,515 full members and 23,940 members of their families)a wide range of initiatives and a variety of promotions and discounts on products and services.
The year 2023 saw the resumption of activities in the post-covid
period, developed, whenever recommended or possible, in amixed format, in person and remotely (online), which made it possible to promote a greater number of activities outside the usual
Lisbon and Porto circuits where more than 67% of its members areconcentrated. It should be noted that the percentage of Members
living outside the major urban centres increased by around 7% in
2023.
This diversification meant that in 2023 it was possible to fulfil
14,235 enrolments for activities directly promoted by the Club,
distributed as follows: 4,997 related to attendance at the Christmas Circus, 4,748 related to sporting activities, 2,402 cultural, 583
leisure and 1,505 related to ticket requests for the different initiatives publicised, all the result of a very remarkable demandbased membership, which is reflected in the hundreds of thousands of visits to the Club's website (www.clubemillenniumbcp.pt)
and more than 1,570 thousand page views (up 12% on 2022), evidence of the members' interest in and recognition of the actions
carried out.
Of these many activities, the most noteworthy are the various Christmas circuses (Lisbon, Porto, Faro, Funchal and Ponta Delgada), the distribution of 1,466 Christmas presents to Members' children under the age of 12 on 31/12/2023, as well as enrolment
in various events, of which, given the high number of participations (always over a hundred), the V Corrida do Clube (Run of theClub) stands out, requests for tickets to the Zoo, Oceanarium, Dino Park and Óbidos Vila Natal and Torres Medieval Fair, tickets
which are made available to Members at a reduced cost, as well as participation in guided tours of a cultural nature to places ofhistorical interest and museums. Likewise, in terms of activities promoted on the Club's premises, we should highlight the music,
painting, language, gymnastics, yoga and Pilates and jewellery classes.
The charity aspect was not neglected, with the distribution of more than four hundred tickets for the various circus shows to
IPSSs supporting children and senior citizens, as well as, in this case with the sponsorship of the Millenniumbcp Foundation, adonation of €5,000 divided equally between two IPSSs dedicated to supporting children with special needs. Our jewellery section
also held a charity sale, the proceeds of which were also donated to an IPSS that supports underprivileged children.

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SUSTAINABILITY REPORT 2023

Also noteworthy are the hundreds of partnerships that allow members and their families to purchase goods and services undermore favourable conditions, such as discounts at gyms, hotels, restaurants, travel agencies and fuel distribution companies.
Always with the same quality standards as in previous years, we will continue to work in favour of our members, with the aim of
expanding the range of activities available, counting on our Shareholders, the Management and all Club employees, as well as
the indispensable presence, collaboration, critique, participation and enthusiasm of the Millenniumbcp Club Members, who are
its raison d'être.

MEMBERS OF CLUBE MILLENNIUM BCP
2023

2022

VAR.%
23/22

Active Employees

5,096

5,118

-0.4%

Retired Employees

5,419

5,493

-1.3%

Subtotal

10,515

10,611-0.9%

Family members

23,94023,979

-0.2%

Total

34,45534,590-0.4%

Total registrations in modalities on the website

14,235

14,0201.5%

Source: Members database and website December 2023

Support for Culture - Bank Millennium
For over 30 years, cultural involvement has been an important part of Bank Millennium's social activities. The Bank supports
national and local cultural initiatives. It is a 360° patron of culture, promoting art in almost all its forms, both erudite and popular,
including music, painting, sculpture, cinema, theatre, photography, literature and performance, always on the premise of beinga long-term partner.
For 18 years it has been a patron of the Millennium Docs Against Gravity festival, the largest film festival in Poland, for more than
20 years it has sponsored the International Traditional Jazz Festival "Old Jazz Meeting Złota Tarka" and is also a long-standing
sponsor of the Lidzbark Nights of Humour and Satire, one of the most important Polish cabaret events.
In 2023, Bank Millennium became a partner of the Inside Seaside festival, a new event on the Polish music scene. The Inside
Seaside Festival is a major new cultural event with a good, diverse programme of music and accompanying events for music
lovers from all over Poland. The organisers chose a new formula and an unusual date for music festivals, filling a gap in the Polishmusic market.
In addition, the Bank once again sponsored the “Cultural Start-up”. This is an initiative of the city of Gliwice, which supports
innovative ideas, unique events and art at the highest level. This is a proprietary programme of the Victoria Cultural Centre in
Gliwice aimed at organisations, artists, entertainers, event and workshop organisers - professionals and amateurs - who havesomething unique to offer in the field of culture and art.
- Millennium Docs Against Gravity Film Festival
The most important cultural project supported by the Bank is the Millennium Docs Against Gravity festival. It is the largest film
festival in Poland and an important documentary festival in the world. Bank Millennium has been a partner of the festival for 18
years and is also the founder of the festival's grand prize.
In May 2023, the 20th edition of the Millennium Docs Against Gravity festival took place, once again using the hybrid formula. The
festival presented 190 of the best documentaries from around the world, including short and feature films. They were accompanied by meetings with artists and protagonists and debates on important themes addressed on screen. As every year, the festival
tackled a range of important issues - from ecology to diversity, politics, psychology, human rights, art, pop culture and family
relationships. The festival was held in eight cities and online on the festival platform. The 20 th edition of the Millennium Docs
Against Gravity festival was attended by more than 144,000 people.
The Millennium Docs Against Gravity Film Festival is the biggest celebration of documentary film in Poland and its popularity
grows every year. The authors of the festival, as well as its patron - Bank Millennium - aim to bring knowledge about the modern
world to as many people as possible. The festival's presence in multiple cities and, from 2020, online, allows the best documentaries from around the world to reach a wide audience. Thanks to this, Millennium Docs Against Gravity achieves its main objectives - cinema and social education, bringing audio-visual culture to a wide audience, not only in big cities, but also in smaller
centres.

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SUSTAINABILITY REPORT 2023

- MyBenefit Platform
In Poland, Bank Millennium has an online shopping platform where purchases can be made with resources 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. Retired employees can also benefit from the offer ofa sports card upon termination of employment, as part of a card specially dedicated to senior citizens.
- MilleKlub
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. Moreover, the Kids Projects also enables the co-financing of projects
to stimulate family activities.

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 2023 the Concerts of Festival ao Largo (Portugal), the film festival Millennium Docs
Against Gravity film festival (Poland) and the Art Nucleus Exhibition (Mozambique).

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.

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SUSTAINABILITY REPORT 2023

Human Rights
At a time when the world is facing enormous political and socio-demographic challenges, there is growing pressure on organizations
to be active agents of promotion and respect for Human Rights. Whether through regulation, through initiatives such as the Proposal
for a Due Diligence Directive published by the European Commission, or through voluntary initiatives, both national and international,
such as the UN Global Compact or the UN Guiding Principles Reporting Framework (more details on this framework presented in thetable attached to this report), organizations are required to adopt and communicate concrete management practices in these matters,
not only in their own operations, but across the entire value chain.
The respect for Human Rights is a principle transversal to all axes of action, activities, operations and geographies of the BCP
Group. As a financial sector organization, aware of the significant potential for influence it has with other organizations, theBank has implemented a set of internal instruments and mechanisms, and established several external commitments that
underpin efforts to manage and protect human rights throughout its value chain.

BCP’s Human Rights Journey2005−

Subscription of the Principles of
the UN Global Compact⚫

Ambition for the Future (2024)

2010

⚫

−

Publication of the Code of Conduct

2014

⚫

−

Publication of the Human Rights
Policy2019⚫

−

Subscription of the ‘CEO Guide to
Human Rights’ from WBCSD andfrom BCSD Portugal

2020

⚫

−

−

Subscription of 'Statement from
Business Leaders for Renewed
Global Cooperation' from UNGC
Publication of Sustainability
Guidelines for Suppliers

The Bank's Human Rights Journey has been planned annually in a structured manner in the Sustainability Master Plan (SMP). The SMP 2024 continues the actions tomanage and promote Human Rights throughout thevalue chain established in 2023, among which the following stand out:
Axle
GovernanceSocialActionInclusion of ESG criterion in the selection of suppliers.
Implement human rights management process in Group BCP anddisclosure of data, including identification of vulnerabilities and improvement actions.
Execute regular human rights selfassessments in Group BCP as awhole.

2022⚫

−

1st revision of the Sustainability
Guidelines for Suppliers

2023

⚫

−

2nd revision of the Human Rights
PolicyThe Bank's approach to the theme transcends the legal requirements in force, and is guided by the Human Rights Policy,
which is aligned with the main national and international guidelines, principles and commitments:
▪
▪
▪
▪
▪
▪
▪
▪

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);
UN Guiding Principles Framework.

In addition to the above-mentioned Policy, the Group has other regulatory policies and instruments that include relevant
guidelines on this themes. The implementation of the principles established by them allows the BCP Group to better ensure
the prevention, minimization and elimination of adverse impacts related to Human Rights throughout its value chain.

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SUSTAINABILITY REPORT 2023

Together with the policies and regulatory instruments, the BCP Group's approach to Human Rights management integrates
other internal mechanisms and procedures, specific for this purpose or transversal to other themes. All of them are subject
to regular reviews to ensure the greatest alignment and applicability in the face of the demands of the current context.
Risk management
The Bank's risk management process covers issues related to Human Rights, namely in Operational Risk, in the categories of
Employee Relations, Occupational Health and Safety Issues, Employee Discrimination, Customer Relations, Product/Service
Design, Regulatory, Legal and Tax Duties and Outsourcing. In 2023, and as in previous years, the results of the SelfAssessment of Operational Risks in operational processes showed moderate exposures to this set of risks.
Whistleblowing mechanism
In order to report any irregularities or violations of the above policies, the Bank provides a whistleblowing mechanism (seemore information in the Ethics and Professional Conduct chapter), which is confidential. In 2023, no situation related to
Human Rights was reported.

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SUSTAINABILITY REPORT 2023

Self-Assessment
To identify the main Human Rights issues and risks in the BCP
Group's value chain, a Human Rights self-assessment was
carried out in the geographies in which the Group operates –Portugal, Poland and Mozambique – which covered five key
areas (as shown in the figure).
In this self-assessment, no risk situation with potential
assessable impact was identified. However, and from a risk
management and minimization perspective, the areas in which
the Bank's operations can be intensified were identified andimprovement plans were defined and implemented in thevarious geographies.
Training
Employees are key players in the implementation of best practices in respect and promotion of Human Rights. For thisreason, the Bank is committed to communication, awareness and training in these matters. The training courses are, for themost part, provided within the scope of continuous training programs aimed at Employees, such as in Portugal, in 2023, thecourses on (i) Code of Conduct, (ii) Sustainability and (iii) Happiness, Emotional Intelligence, Stress Management, Diversity
and Inclusion and Emotional Management, already carried out by 3,162, 3,787 and 396 Employees, respectively. These
training actions, which covered Human Rights topics, made it possible to record, in Portugal, an overall value of 10,275 hoursof training.
Human Rights

Employees

Time

Ethics and Conduct

3 162

4 194

Happiness, Emotional Intelligence, Stress Management, Diversity and Inclusion
and Emotional Management

396

1 518

Sustainability

3 787

4 563

Total

7 345

10 275

Management of suppliers
The BCP Group has sought to encourage respect for Human Rights among its suppliers as well. For that purpose, it has
defined as mandatory the commitment of all suppliers to the Guiding Principles of Sustainability for Suppliers. These
Principles, which have been developed in accordance with the Universal Declaration of Human Rights and the Principles of
the UN Global Compact, include a specific topic on Human Rights and related topics, which reflects the conduct expected ofsuppliers in this regard.
Service providers/Outsourcers and main suppliers (contracts over €50,000) are subject to an additional due diligence process,materialized through the response to an ESG questionnaire that also includes Human Rights topics (see more information in
the "Suppliers" section).

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Fundação Millennium bcp•
Culture, Knowledge and Social Solidarity are the three main focusesof the activities performed by Fundação Millennium bcp. During 2023,
the Foundation sought to support projects in these areas in order tocontribute to the development of society in its various aspects, andencourage the activity of the supported entities, so that theyenrich their potential for innovation and sustainability.
In Culture, it supported projects aimed at valuing thenational museums, for the recovery of architecturaland artistic heritage and to promote contemporary art and new artistic talents in a wide range of fields.
In this context, we highlight the signing of a new protocol with Museu Nacional de Arte Antiga (MNAA), for the 2023-2025
triennium, which will allow the recovery of relevant pieces from the museum's collection, for the close collaboration with
Museu Nacional de Arte Contemporânea (MNAC), supporting the development of its activities and ensuring the existence ofquality programming at the Millennium bcp Gallery, sharing the Bank's artistic collection, but also for the cooperation
protocol with Centro de Arte Oliva, for the realization of the commemorative program of its 10th anniversary.
A strong dynamism of Núcleo Arqueológico da Rua dos Correeiros (NARC) was maintained, providing free guided tours to all
those who want to know this National Monument and its new museum exhibition experience.
In Science and Knowledge, Fundação Millennium bcp has been favouring research, training and scientific disclosure projects
with a special focus on the area of health and postgraduate programmes in leading Portuguese universities.
Concerning Social Solidarity, it tried to promote relevant projects in social innovation and structuring social programs able ofcontributing for local development, namely in the assistance to the most vulnerable parts of society.
The growing relevance of environmental issues and the recognition of the importance and commitment to the goal of the
Sustainable Development Goals of the United Nations (SDGs) have motivated the Foundation to actively participate in forums
and discussion groups on these matters, especially those organized within the framework of Centro Português de Fundações
which aim to increase the contribution of the foundational sector to the implementation of the SDGs.
In order to create greater awareness among the entities it supports for (i) environmental issues and (ii) the fulfillment of theSDGs, the Foundation began to ask the supported entities to reflect on the impacts that the actions developed have on these
two aspects.
Also within the scope of Millennium bcp's Corporate Social Responsibility, the Foundation integrates an internal
multidisciplinary team with the Human Resources Division and the DESC - Corporate Sustainability Area, with a view topromoting, planning and monitoring solidarity actions and deepening a volunteering program that provides opportunities
for the Bank's employees to create social and/or environmental value and strengthen proximity ties with local communities.
In 2023, the Foundation applied for the renewal of its Public Utility Status (EUP). The recognition of the work carried out onbehalf of the community in which it operates motivated the postponement of this request, and by order of August 11, 2023of the Secretary of State for the Presidency of the Council of Ministers was published in the Official Gazette, 2nd Series on
September 8, 2023, the Foundation's EUP was renewed again, taking effect from February 28, 2024, for a period of 10 years.

The Foundation supported, in 2023, a total of 127 projects, 58% of which were in the Culture area, 10% in the Knowledge
area and 32% in the Social Solidarity scope.
During 2023, a total of 128 projects were supported, 57% of which in the Culture area, 11% in Knowledge and 32% in Social
Solidarity.

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CultureIn Culture, the Foundation provided support to the following initiatives:
Conservation and Disclosure of the Bank's Assets•

Museu Nacional de Arte Contemporânea (MNAC):i.

ii.

As part of the protocol signed with Museu Nacional de Arte Contemporânea (MNAC), the exhibition "Jorge
Barradas no Jardim da Europa" was supported, curated by the researcher and Art Historian, Carlos Silveira, which
presented close to 100 works, from institutional and private collections, with emphasis on the collection ofMillennium bcp, of Fundação Calouste Gulbenkian and Museu Nacional do Azulejo. The exhibition was inaugurated
on 04/04/2023 and was exhibited at the Millennium bcp Gallery at MNAC until 27/08/2023 and received 23,957
visitors.
Also at the Millennium bcp Gallery, with the support ofFundação Millennium bcp, the exhibition "Só porque foi, evoou", in partnership with Umbigo LAB and with thecuratorship of the students of the Master's Degree inCuratorial Studies of the College of Arts, University of
Coimbra, took place. The exhibition was inaugurated on
03/11/2023 and will be open to the public until
17/03/2024, having received, in 2023, 6,865 visitors.

Under the existing protocol, in the component of support for the MNAC activities, a set of supports was granted that
contributed to the museum developing and implementing its programming in terms of exhibitions, but also to democratize
access to knowledge about them through publications, mostly bilingual. It also contributed to the continuation of theMuseum's musical programme (Noites de Verão) as well as to specific aspects of its operation. In terms of Educational
Service, it has also enhanced the dissemination of knowledge at different age and gnosiological levels of access to artistic
literacy, necessarily contributing to the improvement of the life quality of its users.
Within the scope of the MNAC’s Educational Service, a schedule of visits aimed at schools, families and visitors of different
age groups is still available. During 2023, the museum received about 58,904 visitors.
•

Arte Partilhada - Centro Internacional de Artes José de Guimarães (CIAJG) / Workshop

Support for the project "Primitivo: uma cartografia atípica a partir de Portugal" which is a consequence of the results of the
Iberian Modernisms project and the Primitivist Imaginary by Joana Cunha Leal, Co-IR and Mariana Pinto dos Santos.
•

Arte Partilhada - Loan of works from the BCP collection

In the field of Shared Art, it is worth noting the loan of a significant number of works belonging to the BCP collection for
integration in a wide range of exhibitions that were open to the public in 2023:- Museu e Centro de Artes de Figueiró dos Vinhos - 5 paintings by José Malhoa to be part of the exhibition “A importância
do riso: José Malhoa e Rafael Bordalo Pinheiro”;- Casa das Histórias Paula Rego - 4 paintings from Paula Rego for the exhibition “Paula Rego: Anos 70”;
- Fundação Champalimaud - 3 oil paintings by Armanda Passos for the exhibition “Armanda Passos, Pintura a óleo em
retrospetiva”;- Atelier-Museu Júlio Pomar - 1 oil painting by Júlio Pomar for the exhibition “Em matéria de matérias primas: Júlio Pomar,
André Romão, Jorge Queiroz, Susanne S.D.Themlitz”;- Museu de Arte Contemporânea da Madeira - 1 Tapestry by Lourdes de Castro (Tapeçarias de Portalegre) for the exhibition“Como uma ilha sobre o mar: Lourdes de Castro”;- Millennium bcp Casa da Música Branch - 3 oil paintings by Armanda Passos for the exhibition "Armanda Passos aniversário do nascimento";- Museu Nacional de Arte Contemporânea - 1 tile panel, 1 oil painting and 6 drawings by Jorge Barradas for the exhibition“Jorge Barradas, No Jardim da Europa”;- Mosteiro de Ancende - Centro Cultural de Baião - 7 paintings by Manuel Cargaleiro for the exhibition “Eu sou… Cargaleiro”;- Lisbon Humberto Delgado Airport / Group Exhibition in Leiria - 1 silkscreen print by Maluda and 1 silkscreen print by Maria
Menez;

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- Museu de Neo-realismo - Vila Franca de Xira - 1 oil painting by Querunbim Lapa for the exhibition “Querubim Lapa, uma
poética neorrealista”;- Museu da Marinha - 3 oil paintings by João Vaz for the exhibition “A Beleza da Água. O Museu de Marinha e João Vaz”;- Casa das Histórias Paula Rego - 1 drawing by Paula Rego for the exhibition “Mudam-se as histórias, mudam-se os estilos”;- MAAT - Museu de Arte, Arquitetura e Tecnologia - 1 oil painting by Paula Rego;- Musée Mohammed VI d’art moderne et contemporain à Rabat, Marrocos - 2 oil paintings by Arpad Szenes and 5 oilpaintings by Vieira da Silva;- Centro de Arte Oliva - 37 painting from several artists, for the exhibition “Revolução da Noite”;- Museu Nacional de Arte Contemporânea - 1 oil painting by Aurélia de Sousa and 1 oil painting by Columbano Bordalo
Pinheiro for the exhibition “Só porque foi, e voou”.

•

Núcleo Arqueológico da Rua dos Correeiros (NARC)

Classified as a National Monument since 2015, this space
allows the public to get in touch with archaeologicalremains from the last 25 centuries of Lisbon's history
through guided and completely free tours. Visitors haveat their disposal brochures that summarize the main
characteristics of the Nucleus, and there is also a moreexhaustive catalogue of the history of the site. During2023, the Núcleo Arqueológico da Rua dos Correeiros
received 9,526 visitors (7,900 in 2022), of which 1,811
were visits from educational institutions.
The Innovation Awards 2023 awarded EDIGMA the award for best project in the "Smart Building" category for the work
developed at NARC as the company responsible for the coordination and implementation of the new smart museum
experience. The ceremony of these awards, considered as the "Oscars" of audiovisual and interactivity, took place inBarcelona, at Museu Nacional de Arte da Catalunha, where excellence in the design, integration and management of therefurbishment of NARC was globally recognized.
Museum Activities•

Fundação Centro Cultural de Belém (CCB)

As "Mecenas da Garagem Sul", and within the scope of the collaboration protocol signed for the period from 2022 to 2024,
the Foundation supported the initiatives developed in this space dedicated to architecture. Among the different initiatives
carried out, the exhibitions "Sala de aula, um olhar adolescente", "Escola do Porto Santo: uma obra de Raúl Chorão Ramalho"
and "Habitar Lisboa: uma perspetiva arquitetónica sobre uma crise contemporânea" deserve to be highlighted. In 2023,
Garagem Sul programs and exhibitions received a total of 17,319 visitors. The educational service covered 4,761 visitors who
participated in guided tours, workshops and activities for families. The conferences, debates and equivalents were attended
by 2,078 people.
•

Museu Nacional de Arte Antiga (MNAA)

A new protocol was signed, for the 2023-2025 triennium, with Museu Nacional de Arte Antiga and Grupo dos Amigos do
Museu Nacional de Arte Antiga through which the Foundation became a strategic patron of the MNAA for the conservation
and restoration of a set of pieces that are in need of urgent and profound intervention to ensure their material and heritage
integrity. This protocol covers the interventions in "Painéis de São Vicente", whose first phase of restoration and study took
place between 2020-2022, in the sixteenth-century relief in polychrome stucco representing the "Defesa de Pavia por Santa
Clara", in a precious group of six large painted papers, of Chinese manufacture, dating from the eighteenth century,
representing the cycle of manufacture and trade of porcelain and, also, in a nineteenth-century bronze version of the socalled Medici Venus. During 2023, Museu Nacional de Arte Antiga received an estimated number of about 218,500 visitors.
•

Museu Nacional Soares dos Reis (MNSR)

Support for the realization of the exhibitions:i)Portreto de La Animo - Arte bruta e etc, curated by António Saint Silvestre. From the Esperanto expression portretode la animo – which in Portuguese means "portrait of the soul" – the exhibition provided a meeting between works
from the collection of Museu Nacional Soares dos Reis and Treger Saint Silvestre collection, on deposit at Centro

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de Arte Oliva. Portraits and self-portraits present themselves as tools for exploring the inner world and its multiple
expressions. This exhibition and the parallel activities were the focus of the "Arte & Saúde" program in 2023
through a cultural offer aimed at minimizing the impact of mental illness. The exhibition welcomed 32,000 visitors;
Exposição Teresa Gonçalves Lobo e Domingos Sequeira: a dialogue in time, curated by Bernardo Pinto de Almeida,
which results from the MNSR's initiative to share works from its collections with contemporary artists. This
exhibition will be open to the public from January 25 to April 28, 2024.

ii)•

Museu Nacional do Azulejo

Support for the recovery of a tile clock from the period 1730-1750 and the acquisition of audiovisual equipment to ensure
the production of materials to disclose the Museum's activity on social networks and other communication channels. In 2023,
Museu Nacional do Azulejo received 246,720 visitors.
•

EGEAC / Museu de Lisboa

A protocol was signed with EGEAC, for 2023 and 2024, with a view to supporting the "Museu Acessível" project, withinterventions at Museu do Aljube and Casa Fernando Pessoa. MUSEU ACESSÍVEL project includes a framework of measuresthat make EGEAC's Museums more accessible and overcome barriers that prevent or hinder the cultural participation ofpeople who have sensory deficiencies or disabilities – among others, people with low vision or blind, deaf people, people
with intellectual disabilities, neurodivergent people and people whose first language is not Portuguese.
•

Museu Nacional dos Coches

Support was maintained for the conservation and restoration of Berlinda Processional (inventory number V0063) dating fromthe eighteenth century, a hypomobile vehicle of religious apparatus used to transport Imagem da Virgem na Procissão deNossa Senhora do Cabo Espichel (cult dating back to the mid-sixteenth century).
Heritage Recovery•

Mosteiro dos Jerónimosi)

Support for the continuation of ecological practices for the conservation of stone in the Cloisters of Mosteiros
dos Jerónimos. This support follows the support granted in 2020 that allowed, for the first time in Portugal,
the use of new products and methodologies, environmentally friendly, in the stone conservation. Thisconservation project through ecological practices was distinguished by APOM with the award, in 2021, of the"Intervenção em Conservação e Restauro" prize;ii)

The Foundation supported the 1st phase of the conservation process of the silver tabernacle of the main
altarpiece of Mosteiro dos Jerónimos church, whose first approach and enhancement consisted of thepreventive and curative treatment of the pathologies detected, as well as their adequate and correct lighting.

Other cultural initiatives•

São João da Madeira Municipality - Centro de Arte Oliva

Support for the celebrations of the 10th anniversary and the activities developed by Centro de Arte Oliva, a place that seeks
to boost the contact, knowledge and interpretation of the visual arts of the 20th and 21st centuries and which stands out as
one of the institutions in the country that regularly works with contemporary art and brut/outsider art. Through its activity
structured in exhibition projects, educational programs and collaborative initiatives, it seeks to make everyone's relationshipwith the arts vital, accessible and participatory.
•

Círculo de Artes Plásticas de Coimbra - Bienal de Arte Contemporânea de Coimbra

Support, within the scope of Anozero - Bienal de Arte Contemporânea de Coimbra, of the "solo show'23" that brought to the
Santa Clara-a-Nova Monestary, in Coimbra, the exhibition "não sofra mais" by the Icelandic artist Ragnar Kjartansson. This
exhibition was open public to between April 14 and July 16, 2023. Over the course of 93 days, the exhibition presented 13
works, attracting 14,585 visitors from 63 countries. In this event, about 40 pedagogical actions were carried out involving
about 2,000 people.

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Brotéria

Support for the exhibition "Pintura sem fim" that took place between January 19 and February 15, 2023 and which brought
together a wide range of painting works executed on canvas, its traditional pictorial support. The exhibition, which brought
together an unusual amount of painting, was available to the public free of charge and was visited by about 1,600 people.
•

Ar.Co

Contribution to the development of the program of commemorations of the 50th anniversary of Ar.Co. The celebrations had
their official opening with the opening of the exhibition "I-II-III-IV-V cinco décadas do Ar.Co - Centro de Arte e Comunicação
Visual", which took place at Museu Nacional de Arte Contemporânea between March 7 and May 28, 2023. The exhibition
included around 60 works covering the areas of drawing, painting, sculpture, installation, photography, ceramics, jewellery,graphic arts, moving image.
•

ARCO Lisboa

ARCO Lisboa is one of the most relevant international art fairs that took place between 25 and 28 May 2023 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.
Fundação Millennium bcp sponsored the Millennium Art Talks, a space for debate and reflection that promotes thinking
about contemporary art. In 2023, the Millennium Art Talk was organized by EGEAC and curated by Ángel Calvo Ulloa andMarta Mestre and in which prominent professionals in the field participated.
In 2023, the Vera Cortês gallery was awarded the First Prize Fundação Millennium bcp for the best stand at Feira Arco Lisboa
2023, an initiative that aimed to recognize and support the work of gallerists.
The event was attended by 86 galleries from 23 countries, representing around 300 artists. The event, at Cordoaria Nacional,
registered 13,984 visitors, including 372 young people under 25 years of age who visited the event at the free time for thisage group.
•

Exhibit Art Management - Drawing Room Lisboa (6th edition)

The event, dedicated to contemporary design, took place from 25 to 29 October 2023 at Sociedade Nacional de Belas Artes.
This year's edition, which received around 8,400 visitors, was attended by 23 national and international galleries,
representing more than 65 Portuguese and international artists with a program with several parallel activities, including theMillennium Art Talks, with programming by the Portuguese curator Maria do Mar Fazenda.
Within the scope of this initiative, the following awards were granted in 2023:
Aquisição Fundação Millennium bcp Talento Emergente award, which supports an artist under 35 years of age throughthe acquisition of work and its inclusion in Millennium bcp – Katarzyna Pacholik collection (Poland, 1990), represented
by Galeria Silvestre;
Projeto Artístico Destacado award, which distinguishes an artist of this year's edition – Gabriela Albergaria, represented
by Galeria Vera Cortês, who presented an exhibition with works where she interprets gardens as elaborate
constructions, representation systems and descriptive mechanisms used to represent the natural world;
Projeto Curatorial Galeria award, which distinguishes a curatorial proposal from a participating gallery - Galeria das
Salgadeiras, based in Lisbon, a project conceived by Ana Matos, which brings together the works of artists Rui Soares
Costa and Rui Horta Pereira under the concept of "labyrinth".
•

Carpe Diem Arte e Pesquisa - Arte Jovem 2023 Award

Support for Arte Jovem Fundação Mbcp 2023 Award, an initiative that aims at promoting the works of artists who have justentered the world of art and provide a broader view of national artistic production, creating the opportunity for the firstexhibition with curatorial monitoring and catalogue. The selected works, by 10 artists, were brought together in an exhibition
that opened on October 12 and lasted until November 11, 2023, in Pavilion 31 of Centro Hospitalar Psiquiátrico de Lisboa.
The Foundation attributed two awards:“Viagem a Madrid Millennium bcp” award: taking place during the art fairs and parallel events of that city, which wasawarded to Joana Duarte from Faculdade de Belas Artes of the University of Lisbon;“Aquisição Fundação Millennium bcp”: consists in the acqusition of a work to be part of the of Millennium bcp collection
and was awarded to Mariana Maia Rocha from Faculdade de Belas Artes of the University of Oporto, with the work “A142

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voragem do tempo”.
The Jury of the 2023 edition of the Arte Jovem Award was made up of the artistic duo Rosana Ricalde and Felipe Barbosa,the researcher Glória Diógenes and the independent curator Katherine Siroiss.
•

Nebula - Associação Cultural

Support for the development of the Chiado, Carmo, Paris 2024 Project, coordinated by Professor José Quaresma, from FBAUL(Faculdade de Belas Artes of the University of Lisbon), which includes the publication of a book and five art exhibitions
evoking the passage of Salgueiro Maia (and what he symbolizes for the women and men he influenced) through the arteriesof these two cultural neighborhoods — Chiado and Carmo —, when, as he walked along Rua Garrett, Calçada do Sacramento
and Largo do Carmo, he filled with hope all those he met there.
•

Fundação Eça de Queiroz – Literary Award Fundação Eça de Queiroz / Fundação Millennium bcp

This biennial award aims to encourage the production of literary works in Portuguese, as well as to pay tribute to Eça deQueiroz, one of the greatest national and international figures in Portuguese literature and culture.
The prize for the 2023 edition, which distinguished a fictional work (novel or novella) written in Portuguese and published in
Portugal in 2021 and 2022 by a national author aged no more than 40 years at the time of publication, excluding previous
winners, was awarded to Joana Bértholo with the work "A História de Roma".
•

Fólio 2023 – Livraria de Fundos

The project proposes the sharing of programming between the FOLIO MAIS section of Festival Literário Internacional deÓbidos and the inauguration of the Casa do Comum cultural centre, in Lisbon. Ler Devagar, curator of the aforementioned
section of FOLIO and promoter of the new Cultural Centre, thus intended to take the programming from Óbidos to Lisbon.
In both spaces, the cultural programming privileged lesser-known authors and singer-songwriters within the Portuguese
cultural circuit, in particular artists and authors from Portuguese-speaking countries (Brazil, Angola, Cape Verde, Guinea,
among others) and artists who had less representation on the large stages and cultural programming spaces.
•

SPIRA / Mundo do Património

Support for the realization of Feira do Património - Bienal Ibérica do Património Cultural AR&PA 2023, which took place
between October 12 and 15 in Angra do Heroísmo, Azores. AR&PA is a reference event in the Cultural Heritage sector in
Portugal, being a privileged meeting point and debate forum for professionals and institutions dedicated to Cultural Heritage.
The 2023 edition was attended by 50 stands. A total of 80 activities were carried out. The cultural program had about 2,000
participants.
•

Associação CIVOC - “Cascais Ópera - Concurso internacional Ópera Cascais” project

Support for the "Concurso Internacional de Ópera de Cascais", an initiative that is a novelty in the international panorama oflyrical competitions and which will have its inaugural edition between 6 and 14 of April 2024, at Centro Cultural de Cascais,
at Casino Estoril, at Casa das Histórias Paula Rego, with its final being held at Teatro Nacional de São Carlos, in Lisbon.
Designed as a 'showcase' for the most promising among the new values of operatic singing, Cascais Ópera is open to
candidates from all over the world and of all vocal typologies, aged between 18 and 32 years.
•

Francisco de Lacerda A Música e o Mundo Associação Cultural

Support for the Compositor Francisco de Lacerda / Fundação Millennium bcp award, created by Francisco de Lacerda - A
Música e o Mundo, Cultural Association, which aims to promote national musical creation and reward works by Portuguese
or foreign composers living in Portugal, this award being one of the most relevant distinctions for orchestral composition in
Portugal.
In the 2023 edition, the jury, consisting of composers Magnus Lindberg, Christian Mason, Aspasia Nasopoulou and Vasco
Mendonça, elected as the winner the work "Ecos das Trovas" by Luís Neto da Costa.

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Banda de Alcobaça - Cistermúsica 2023

The 2023 Temporada Cistermúsica kept its commitment to a range of different artistic and sound experiences that captivate
different audiences, covering centuries of musical history, from ancient music to contemporary creation, with formats
ranging from chamber music to several symphonic concerts and other major productions, and the Foundation's support was,above all, directed to the Rota de Cister programming network which, starting from Mosteiro de Alcobaça, seeks todisseminate and value the Cistercian heritage built in Portugal.
In the 2023 edition, 58 shows were held, in which 1,177 national and international performers participated, spread over 33
stages and with 10,000 spectators.
•

BOCA

Support for 2023 activities, including:- BoCA Bienal de Artes Contemporâneas 2023, "Presente Invisível": bringing together 35 cultural institutions (theatres,
museums, cultural centres, heritage and natural spaces), the BoCA Biennial ran from 2 September to 15 October 2023 (6weeks). It included the production of new creations by 63 artists, from 13 nationalities, having achieved an occupancy rateof 98%.
- Artistic residencies: BoCA has produced 5 Artistic Residencies in different creative spaces (Victor Córdon Studios, Lisbon;
Goethe Institut, Lisbon; O Espaço do Tempo, Montemor-o-Novo; Fábrica da Cerveja, Faro).
- Programming and Participation / A Defesa da Natureza: continuity of the project started in 2021, which combines art andenvironment and calls on civil society and artists, on the one hand, to plant trees by assigning a title to each new
natural/artistic creation and, on the other hand, to program artistic and educational activities for these same spaces, over
10 years. In 2023, 525 trees were planted in Lisbon, in a partnership between BoCA and the Green Structure department of
the Lisbon municipality, which brought together more than 100 citizens residing in Lisbon who planted and named theirtree/artistic creation.
- Programa Educativo / BoCA Summer School: 5 workshops in different artistic areas (theater, dance, visual arts, music,
cinema) directed by artists of international prestige.
- Programa Educativo / Mutantes – Entre o Teatro e o Museu: a transdisciplinary project of training and creation of new
artistic paradigms, coordinated by Sara Franqueira, and the partnership of BoCA with several cultural institutions in the cityof Lisbon (MAAT, Culturgest, Centro Cultural de Belém, Teatro do Bairro Alto, Museu do Chiado).
- Programa Educativo / BoCA Sub21: training and creation project aimed at young people between 15-21 years old- Mediation in higher and artistic schools / BoCA: transversal to the entire program and continuously, Mediation inhabitseach activity, establishing links with 19 secondary, artistic and higher education institutions for actions to raise awarenessabout programming and taking artists from the BoCA Biennial to masterclasses.
- National and International Circulation: the artistic projects commissioned and produced by BoCA (shows and performances)premiered in Lisbon and Faro as part of BoCA 2023 and circulated in other geographies of the country and the world: Paris,
Antwerp, London, New York, Madrid, Toulouse and Porto.
The 4th edition of BoCA – Biennial of Contemporary Arts, an international biennial of contemporary arts, brought together atotal of 51,000 spectators.
•

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.
Additionally, O Espaço do Tempo promotes and organizes Plataforma Portuguesa de Artes Performativas - a biennial event
where the most relevant works of Portuguese performing arts are presented to national and international programmers,
curators and artistic directors. In 2023, the 8th edition of this event took place between 6 and 10 June 2023, during which 18
Portuguese performing arts shows, premiered between 2021 and 2022, were presented. The initiative was attended by 80
programmers and Artistic Directors from international and national structures.
•

AICA - International Association of Art Critics

Support for the AICA/MC/Millennium bcp Visual Arts and Architecture Awards, which are awarded annually in Portugal to avisual artist and an architect.

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These awards intend to distinguish Portuguese artists and architects who, for their work and personal path, provide acontribution of excellence for art and culture.
In 2023, the prizes for 2022 were awarded, with Luísa Cunha being distinguished, for the exhibition "Partitura #4" and forthe intervention in the "Gabinete” space, at MAAT, with the piece "Não", and Ricardo Carvalho, for the solo exhibition "Todas
as Direções" held at the Note gallery.
•

Associação Portuguesa de Historiadores de Arte

Support for the 2nd edition of the APHA/Millennium bcp - José Augusto França Awards. These awards are intended to
distinguish the best master's thesis and the best doctoral thesis in Art History, presented in this scientific field in Portuguese
Universities in the years 2020 and 2021, through the sponsorship of their publication.
•

RHI Arte Institute

The RHI is an initiative organized by the Arte Institute, with the aim of internationalizing contemporary Portuguese art andculture. In the 2023 edition, held under the theme RHI - Revolution Hope Imagination, it took place between 5 and 13 May
in 12 cities: Évora, Cascais, Loulé, Braga, Lisbon, Torres Vedras, Alcobaça, Leiria, Faro, Oporto, Vidigueira and Funchal.
A total of about 1,500 spectators were reached who attended the 33 organized events (lectures, workshops andmultidisciplinary events) in person or online.
The cultural moments were documented on the online platform RHI_Think (rhi-think.com) which will continue to promotethese shows throughout the year, allowing anyone in the world to have access to their content.
•

CULTURXIS

The 18th Festival Internacional dos Açores aimed to promote a more diversified cultural offer in the region. For the first time,
the festival, which took place between August 31 and September 16, 2023, had sessions on all the Azores islands.
Throughout the festival, 22 shows were held, ranging from classical music to performing arts, jazz and hybrid performing
arts. The shows were directly witnessed by more than 7,000 spectators, and the event had an additional projection provided
by the publicity carried out by the media.

Science and Knowledge
In line with the Sustainable Development Goals of the United Nations (SDGs)

Scientific Investigation Projects•

Fundação Rui Osório de Castro

A new protocol was signed with Fundação Rui Osório de Castro for the three-year
period from 2023 to 2025 which aims, through the attribution of an award, to promote
the development of innovative scientific works that deal with the pediatric oncology
issue and that are capable of encouraging and promoting the improvement of careprovided to children with cancer disease.
In the 7th edition, 9 applications were submitted, and Fundação Rui Osório de Castro /Millennium bcp Award was awarded to Isabel Antunes, from IPATIMUP and i3S, withthe project "Desvendar o papel da glicobiologia nos sarcomas pediátricos: Abrir portas
para novas estratégias terapêuticas”.
In this edition, the jury also awarded an honourable mention to Ana Vieira, from IST "ALL4WISH" and Rui M. Reis, from
University of Minho, with the project "Papel da CD24, uma proteína do “checkpoint” imunológico, na biologia e terapia demeduloblastomas”.

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SUSTAINABILITY REPORT 2023•

Universidade Nova / Instituto de Higiene e Medicina TropicalSupport for the 6th National Congress of Tropical Medicine, which took place between April 18 and 21, 2023, dedicated tothe theme "Tropical Medicine and Sustainable Development". Within the scope of this initiative, pre-congress courses,
thematic panels, guest conferences, oral communications and selected posters were held.
The event also included the photographic exhibition "Parcerias em Medicina Tropical: Histórias e Memórias”.
•

Federação Portuguesa de Formação Profissional e Emprego de Pessoas com deficiência e Incapacidade

Support for the International Congress on Socio-professional Inclusion, which was under the theme "The socio-professional
inclusion of people with disabilities - the state of the art and future perspectives".
The event took place at Centro de Artes e Espetáculos, at Figueira da Foz, on November 22 and 23, 2023, with 133 participants
attending the event.
University Education•

Aprender e Empreender - Junior Achievment 2023

This initiative aims to undertake entrepreneurial programmes with university students by creating new micro companies.
Under the format of a university and entrepreneurship competition and with the guidance provided by professors fromseveral universities, the 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 theirstudents a more global view of the set of career opportunities. In addition, and due to the fact that it is connected to aninternational 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 22/23 academic year, 13 universities, 927 students and 45 volunteers were involved in this initiative.
The final of the national competition was won by the Trade team, from the Universidade de Évora, with a project for aplatform for the exchange of services between university students that aims to develop soft skills. This team represented
Portugal at the Gen-E 23 European Entrepreneurship Event that took place between 11 and 14 of July, in Istanbul, Turkey.
•

Universidade Católica - CEPCEP

Support for the celebrations of the 40th anniversary of the Centro de Estudos dos Povos e Culturas de Expressão Portuguesa(CEPCEP), which was marked by 4 public events on topics of great relevance: Seminário Lições da Pandemia Aprender com
uma Experiência Limite (January 2023); Seminário Uma agenda de Investigação para o Futuro (March 2023); Seminário A
Sociedade do Cuidado (June 2023) and Congresso Portugês Global - Língua, Cultura e Ciência no Século XXI (November 2023).
•

Museu Nacional do Teatro e da Dança – Estudar a Dança Award

Support for the Estudar a Dança award, which is intended to reward academic works of exceptional quality that contributeto the knowledge of this art and stimulate its development. This is an annual award, which is directed alternately to master's
dissertations and doctoral theses.
In 2023, the prize for the competition was awarded, which covered Doctoral Theses defended in the last five years (between
30 September 2017 and 30 September 2022) in polytechnic institutes and national universities.
Basic Education•

Associação Empresários pela Inclusão Social (EPIS)

Support for the Association's activities aimed at promoting initiatives for creating job opportunities and social reintegrationof people, families or groups in exclusion or risk of social exclusion situations, with a special focus on promoting the social
inclusion of young people through school success and professional integration.
In the 2022/2023 school year, EPIS programs to promote school success closely monitored 8,922 children and students in
251 schools in 36 municipalities and 4 Azores islands.

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SUSTAINABILITY REPORT 2023

The academic success of EPIS students in the 2nd and 3rd cycles and secondary school, monitored by EPIS for more than a
year, reached 85.4%, 2.4 pp more than in the previous school year. In primary school, the academic success of the studentsmonitored was 99.8%.
In the 2023/2024 school year, EPIS extended its presence to 254 schools in 37 municipalities and 5 Azores and Madeiraislands.
Within the scope of the BCP Group's Corporate Social Responsibility Policy, a partnership was established in the 2022/2023
academic year between Fundação Millennium bcp, Millennium bcp and EPIS with the aim of bringing together a group ofMillennium bcp Employees / Volunteers with interest and availability to give tutoring lessons to students in the 2nd and 3rd
schooling stages from disadvantaged backgrounds (with a higher risk of school failure and dropout), thus helping to promote
their social inclusion through school. The success of this initiative led to its renewal in the 2023/2024 school year.

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

Within the scope of Millennium bcp's Corporate Social Responsibility, the Foundation supported actions ofdifferent entities, covering several sub-areas of intervention, such as childhood/adolescence/seniors,
poverty and disability, of which the following are highlighted:•

AESE - Associação Estudos Superiores de Empresa - Programa GOS

Support for the holding of Programa GOS - Gestão das Organizações Sociais, resulting from a partnership between AESE and
ENTREAJUDA and aims to provide management training to managers of entities in the social economy sector, exclusively
non-profit, seeking to respond to the training needs felt in this sector.
In 2023, 53 trainees benefited from Programa GOS, at national level, representing 37 entities from north to south of thecountry, including the autonomous regions (in Porto, there were a total of 23 direct beneficiaries, from 15 entities in thesocial economy sector located north of the Mondego River, and, in Lisbon, 30 direct beneficiaries, representing 22 entities
located south of the Mondego and Islands).
•

Banco Alimentar Conta a Fome

Support for the campaigns for the collection of food carried out by this institution that seek, throughout the year, to respond
appropriately to the impact of the pandemic that many families continued to feel.
The 21 Food Banks support 2,600 charities that help around 400,000 people in need (100 tons of food delivered per day).
The foundations’ support is channelled for the purchase of paper bags used in the food collection campaigns. The bags areused once again in the following campaigns or, if damaged or dirty, re-sent to the campaign Paper for Food.
•

55 MAIS+

Project that aims to activate, value and integrate people aged 55 and over into society toprevent or counteract loneliness and reinforce self-esteem and well-being. To this purpose,it has developed a technological and human platform, connecting the needs of citizens andthe services provided by people aged 55+ (food, pet-sitting, monitoring of seniors andchildren, watering plants, …) by a competitive and fair value for all.
At the end of 2023, 3,585 Talents with 55+ were registered, with 12,216 hours of activity
provided throughout the year in 1,199 services performed. Since the beginning of the
project, Talentos 55+ have performed more than 42,400 hours of service (more than 5,000
services), achieving a remuneration of more than €250,000.
•

Associação Dignitude

The abem Program is a Medicine Solidarity Network whose mission is to allow access to medicines prescribed and reimbursed

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SUSTAINABILITY REPORT 2023

by the National Health Service (SNS) to those who do not have the financial capacity to purchase them. The beneficiaries arereferred by local entities (Municipalities, Caritas, IPSS and Misericórdias) so that the support is carried out in proximity andwith humanity.
Abem is based on a collaborative network of local entities and pharmacies. This initiative has a national scope, being present
in all districts and autonomous regions.
In 2023, there were 35,210 beneficiaries of the ABAEM program, which involved 188 referring entities and 1,165 pharmacies.
Given the average value of support per beneficiary, the donation granted allowed supporting around 61 beneficiaries for aperiod of 1 year.
•

Associação Terra dos Sonhos - We Guide and Sonhos Transformadores projects

Sonhos Transformadores: their main objective is to provide children andyoung people with serious illness, or in the terminal phase, with thefulfillment of their dreams. By contributing to a better state of mind, we
increase levels of hope by creating magical moments that reinforce theimportance of positive emotions in situations of great vulnerability.
WeGuide: aims to improve the quality of life and promote the well-being of people with serious chronic illness, and theircaregivers. It materializes through the performance of a Health Guide, a professional whose function is to accompany thepatient over twelve months. It is premised on authentic and inclusive communication, and always aims to empower thepatient, or their informal caregiver for the self-management of the disease, enhancing a greater humanization of the system.
The Foundation's donation made it possible to make the dream come true for two children and to accompany a child and his
caregiver for 6 months.
•
Associação Mais Proximidade Melhor Vida•
Aid for the carrying out the 2023 activities of this Association that seeks to reduce the impact of loneliness and isolation andcontribute to improve the quality of life of the elderly.
•

Ajudaris

Every year, Ajudaris challenges schools to join the project by reflecting on a theme linked to the 2030 agenda. After thisexercise, with methodologies adapted to the children and young people ages, stories of different literary genres emerge. In
the 2023 edition, the "Peace” theme was worked on.
In the 2023 edition, 2,560 stories were received and 610 stories were selected for publication, spread over 6 illustrated books
by illustrators from several parts of the world. One collection had a print run of 24,000 books that were distributed, for themost part, by school libraries, hospitals and municipal libraries. 42 face-to-face activities were promoted and we carried out
10 training sessions on creative writing strategies with a focus on children with special educational needs.
•

Associação Ukranian HUB - Amarelo Azul ProjectWithin the scope of this project, the realization of 3-month business educational "Business camp" for Ukrainian refugee
women is promoted with the aim of supporting companies and startups founded by Ukrainian women, refugees in Portugal,
making them drivers of future economic recovery through access to global resources - financial, intellectual, technological.
The Foundation's support translates into the awarding of a prize that distinguishes the 3 best projects presented at theBusiness Camp.
•
SOL- Associação de Apoio às Crianças Infectadas pelo VIH/Sida•
Support to the project ConSOLidar Laços - Summer Camps that provided 15 children/young people infected with HIV with adifferentiated holiday, where, among all, they shared experiences and doubts directed to the common factor, being HIVpositive. Through a welcoming environment and lots of fun, the SOL Association aimed to clarify possible doubts that exist
and improve the behaviours of each young person in the face of their disease.
•

MOG - Movimento Oncológico e Ginecológico

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SUSTAINABILITY REPORT 2023

Support for the activities of the Ovarian Cancer and other Gynaecological Cancers Movement, an association that aims to
improve the quality of life of all women suffering from ovarian cancer or other gynaecological cancers.
•

APADP - Associação de Pais e Amigos Deficientes Profundos

In collaboration with the Millennium bcp Club, the Association’s activities were supported, whose mission and objectives are
to promote and ensure the well-being, quality of life and social inclusion of citizens with profound disabilities.
•

Associação Rumo à Vida

In collaboration with the Millennium bcp Club, the Association’s activities were supported, an IPSS (chaitable institution) in
the municipality of Matosinhos aimed at children, young people and adults with intellectual disabilities and whose mission
is to provide a structured education/training of excellence, with a view to the development of their autonomy and inclusionin active social life, supported by an experienced multidisciplinary team.
•

Fundação do Gil

Support for the construction of a Child Development Unit - the Gil Clinic - which aims to provide answers in the area of Mental
and Emotional Health of children and adolescents, centered on the family.
This space aims to support in the areas of psychology, child psychiatry, family therapy, speech therapy, occupational therapy
and psychopedagogical support, among other specialties.
•

EAPN - Portugal

Support for the development of the activities of the National Observatory for the Fight Against Poverty, whose mission is topermanently monitor the phenomenon of poverty and social exclusion in Portuguese society.
For more information on Fundação Millennium bcp activities during 2023, including its impact on the SDGs, see the Activity
Report at: https://www.fundacaomillenniumbcp.pt/en/a-fundacao/informacao-coorporativa/

In 2023, the Foundation supported 127 projects in the area of Culture,
Knowledge and Social Solidarity.

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SUSTAINABILITY REPORT 2023

Bank Millennium Foundation
The year 2023 was the 33rd birthday of the Bank Millennium Foundation.
Another year of two important programs: Financial ABCs, an educational
program familiar from previous years, which is directed to the youngest children and their parents, and Our People'23: Save the Planet, a sports charity
program.
Taking advantage of the opportunities presented to the Foundation thisyear, it was possible to focus even more on the needs of the Polish society
in terms of financial education and raising awareness about protecting thePlanet. These needs became both a challenge and a goal to achieve in thepast year.

DOUBLY ECO: FOCUSING ON ECONOMICSThe Financial ABCs program was continued, with two editions held in 2023, during which the program carried out 439
educational workshops for children in 119 kindergartens. During the workshops, almost 10,000 children between the agesof 3 and 6 were able to acquire financial knowledge through play. The goal of these sessions was to provide preschoolers
with financial education, to raise their awareness of different forms of money and develop the habit of planning and saving.
DOUBLY ECO: FOCUSING ON ECOLOGYThe Foundation have decided to promote employee initiatives that this year focused on protecting our Planet. That mission
was pursued through the Our People23’: Save the Planet program - to expand the awareness of environmental protection
and the dangers of pollution among employees. The scale of the problem is great, and the problem itself does not justaffect one person or one organization, but society as a whole. The campaign had two stages: sports and eco-volunteering.

FINANCIAL ABCs: CARING ABOUT FINANCIAL EDUCATION FROM EARLY AGE
Since 2016, the Bank Millennium Foundation has cooperated with the Verba Foundation in carrying out an educational program for preschoolers called Financial ABCs. The program is an original initiative of the Foundation implemented under thehonorary patronage of the Ministry of Finance.
According to a survey conducted for Bank Millennium Foundation, more than 75% of parents of preschoolers believe thatthe age of 3-7 is the best time to start their financial education. The survey also showed that parents are open to theirchildren's development in finance and entrepreneurship areas and that financial education itself is seen by the vast majority
as a necessary part of education in today's world.
WORKSHOPS IN KINDERGARTENS
The young participants of the workshops were introduced to another edition of the adventures of Mr. Sebastian, which wasenriched this year with topics of digital world and online payments. The goal of the workshops was to use interactive methods to teach children about the value of money, its forms, the skills of financial planning and saving, and how to navigate
the world of finances consciously and safely. The
program helps to develop healthy savings habits andrespect for money.
The employee volunteers support communication
with kindergartens, assist animators during workshops in distributing diplomas, books and runninggames. The games proposed during the workshops
promoted independence, openness, charity, pro-activity and creativity. The Financial ABCs programprovides educational materials in the form of aguide for parents and a textbook featuring the adventures of Mr. Sebastian. These materials are available on the Foundation’s website and on YouTube.

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SUSTAINABILITY REPORT 2023

10TH ANNIVERSARY EDITION
In 2023 the Bank Millennium Foundation organized 3 anniversary events celebrating the 10th edition of the Financial ABCs
program in 3 Bank Millennium headquarters: in Warsaw, Gdańsk and Wrocław. Children had an opportunity to meet thehero of the program, Mr. Sebastian, and to participate in financial workshops. Additional attractions were provided in theform of various games with professional animators, an illusionist show, lots of balloons, delicious snacks, and cake. At theend, each child received a gift of books, stickers and a mascot.
From the inception of the Financial ABCs program until the end of 2023, the Foundation organized more than 3,157
workshops and trained 70,000 children in kindergartens across Poland

GLOBAL MONEY WEEK 2023
This year, from March 20 to 26, the annual Global Money Week (GMW) awareness campaign was carried out globally. It wasalso celebrated by Bank Millennium Foundation. “Plan your money, plant your future” was the official theme of this year's
edition. Financial literacy, responsibility, a thorough understanding of finances and awareness of financial behavior from anearly age is one of the priorities of the Foundation.
Bank Millennium Foundation celebrated this year’s GMW campaign byparticipating in panel discussions with, among others, the Warsaw
Banking Institute Foundation representing the Polish banking community, and the GMW Foundation, which establishes an annual crosscommunity forum for discussion, exchange of experiences, cooperation, and educational activities in the field of finance.
OUR PEOPLE'23: SAVE THE PLANETOver the past years, in programs organized by Bank Millennium Foundation, the volunteers have proven more than once
that the desire to do good and to provide help is in their blood. This is why Bank Millennium Foundation launched the Our
People'23: Save the Planet program last year.
The main focus of the program was to protect our Planet. Due to human activities, more and more climate threats arise
every day and pollution levels are increasing. All this leads to irreversible changes not only in the climate, but in the entire
ecosystem.
The Foundation is not indifferent to environmental issues - that is why in 2023 it has made a joint effort to take care of the
Earth's needs and put ecological values first. It is a very broad theme that encompasses numerous topics, for example thepreservation of biodiversity, the loss of which is the greatest threat to life on Earth.
The Foundation has committed to the goal of raising environmental awareness, promoting ecological values such as: separation of waste, increasing the number of plants in its spaces, protecting animals and forests and raising environmental
awareness among the public.
The Our People'23: Save the Planet program has helped to achieve the environmental goals while engaging volunteers inboth sports and volunteering activities and the results are tangible proof of how much we can accomplish together.
SPORTS CHALLENGE
The sports part of the campaign was based on engaging employee volunteers in sports activities. Each kilometer covered
and calorie burned contributed to the stated goal of donating 250,000 PLN to the Bank Millennium Foundation for the implementation of the eco-volunteering program.
1,508 volunteers became involved in the sports activities, traveling a total of 311,444 kilometers - 131,272 km kilometers on foot and 180,172 km kilometers on wheels - andburning 18 million calories between 24 April and 25 June 2023. Such a huge contributionof Bank employees to sports activities guaranteed the success of this part of the campaign.
The campaign not only promoted ecological values, but also encouraged a healthy lifestylewith intensive physical activity, which in turn benefits not only our health and well-being,
but also the environment. To achieve their exercise goals, the volunteers gave up driving
or taking public transportation and instead walked, ran or biked. As a result, 71 tons ofcarbon dioxide were saved, a major contributor to the pollution of the Planet.

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PROTECTING THE PLANET TOGETHER
In the eco-volunteering part of the campaign, 26 different eco-initiatives
were carried out by teams of volunteers. In total, 163 volunteers took part ineco-volunteering, and the aid reached numerous beneficiaries, including: disabled youth, children from an orphanage, patients from a children’s hospice,children from various kindergartens and elementary schools, as well as nature parks, bees and hedgehogs.
The eco-initiatives required volunteers to be engaged in their work, be open
to the local community, plan for the long-term impact of their activities, use
raw and recycled materials and minimize purchases. The campaign created aperfect space for creative and, most importantly, charitable ideas. As a result,each of the initiatives was unique. Teams of volunteers approached the topic
of protecting the Planet in different ways, which confirmed how broadly theconcept can be understood.

TWICE THE CELEBRATION: VOLUNTEER DAY
5 December is International Volunteer Day. Its purpose is to recognize the work of volunteers around the world for theirefforts, time and skills. Last year, the Bank Millennium Foundation celebrated the day with a webinar in partnership with
WWF. It was an ideal opportunity for willing volunteers to learn a little more about the steps each of us can take every day
to protect the environment. During the webinar, the attendees were able to talk about: the most effective actions to benefit
nature, our ecological debt, as well as the eco-initiatives that have already been implemented.
TWICE THE CELEBRATION: 33RD ANNIVERSARY OF THE FOUNDATIONIn December 2023, the Foundation had its 33rd anniversary, which offered another opportunity for celebration - on thisoccasion, together at the Bank’s Head Office in Warsaw. The Foundation began its activities on 10 December 1990.

For more information, see the Bank Millennium Foundation 2023 Report:
https://www.bankmillennium.pl/documents/d/guest/fundacja_raport_2023_en?mv=1mv

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SUSTAINABILITY REPORT 2023

Social Responsibility and Social Solidarity Initiatives in Portugal, Poland and Mozambique

Bank Millennium volunteers
visit kindergartens and promote financial literacy(Poland)Millennium volunteers and "Brigada do Mar" clean beachon the Portuguese coast(Portugal)“Solidarity Christmas” supports needy populations with
first necessity(Mozambique)“Solidarity Christmas”, in 2023, carries out support actionsin 11 cities across the country(Mozambique)12th edition of the Banking Olympics
promotes financial literacy(Mozambique)

Millennium volunteers at the Lisbon Food Bank(Portugal)

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SUSTAINABILITY REPORT 2023

Social Responsibility and Social Solidarity Initiatives in Portugal, Poland and Mozambique

Bank Millennium Foundation promotes nature protection with
the involvement of Millennium Volunteers(Poland)

Bank Millennium Foundation in yet anotherjoint effort to protect the environment(Poland)

16th edition of the Minibasketball Tournament of the Social
Responsibility program "Mais Moçambique pra Mim"
(Mozambique)

Millennium volunteers and "Semear" promote the inclusion ofpeople with special needs(Portugal)

BCP recognized for 18 years of participation in the
UN Global Compact(Portugal)“Our People23’: Save the Planet”, has Millennium volunteers
doing physical exercise to raise social donations(Poland)154

SUSTAINABILITY REPORT 2023

Environmental
Responsibility

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SUSTAINABILITY REPORT 2023

Environmental Responsibility
The impacts that arise from climate change and are felt at a global level, emphasize the importance of companies, governments and individuals acting in a concerted way to change habits and behaviours, which ensure greater environmental
preservation and protection.
The Bank's activities necessarily result in several environmental impacts, including negativeones. Recognizing this, Millennium bcp has implemented a strategy and an action plan,aligned with international frameworks, tools and indices, through which it seeks to minimize
adverse impacts on the environment and enhance eco-efficiency in the management of its
operations.
To reduce the negative impacts associated with its operations and portfolio, it invests in the provision of financial solutions and products that include an environmental responsibility aspect.

Main highlights 2023
POLANDElectricity: 16,605 MWh (-17%)
Emissions: 7,486 tCO2 (-26%)
Water: 66,640 m3 (-10%)
Materials: 311 t (-13%)
Waste: 386 t (-23%)

PORTUGALElectricity: 25,034 MWh (-5%)
Emissions*: 2,628 tCO2 (+1%)
Water: 106,387 m3 (+4%)
Materials: 680 t (-9%)
Waste: 711 t (- 1%)* Excluding the Emissions associated to suppliers.

MOZAMBIQUE
Electricity: 6,120 MWh (6%)
Emissions: 1,699 tCO2
Water: 27,890 m3
Materials: 370 t (-13%)
Waste: 21 t

Caption: 2023, % evolution vs. 2022

Bank’s journey to improve environmental performance in Portugal
2016

⚫

─

Implementation of the Program Go Paperless

2017

⚫

─
─

The option to use/ purchase hybrid vehicles in the selection of the company's fleet is available.
Installation of a Photovoltaic Solar Energy Plant with around 1 MW capacity.

2019

⚫

─

Replacement of traditional light bulbs for LED in all the Bank’s buildings in TagusPark

2020

⚫

─

Signing of the Mobility Pact for the City of Lisbon and Lisbon European Green Capital 2020 Commitment

2021

⚫

─

Millennium bcp in the first ranking “Europe’s Climate Leaders 2021” from FT─Use of electricity 100% green in the Bank’s premises in Portugal

─Conducting, in the Portuguese operation, universal training on Sustainability (5,815 Col.) and theSustainability Course in the Financial Sector (3,565 Col.)156

SUSTAINABILITY REPORT 2023

2022

⚫

─

Installation of a second photovoltaic plant at TagusPark with 1 MW of power

2023

⚫

─

Starting the process of installing micro photovoltaic plants in the different branches in Portugal

The path of efficiency of Millennium bcp in Portugal
Electricity

EnergyGoal 2023: +6 %✓Performance: -5%
Target 2024: -3,5%Goal 2023: -11%
Performance: +0.4%
Target 2024: -5%

Water

Direct Energy

Goal 20231: +2%
Performance: +4%
Target 2024: +2%

Waste

Materials

Target 2023: 0%✓Performance: -1%
Target 2024: 0%

Target 2023: -5%✓Performance: -9%
Target 2024: -7%

Emissions of CO2*

Direct Emissions

Indirect Emissions

Goal 20233: -15%
Performance: -1%
Target 2024: -7%* Excluding the Emissions associated tosuppliers.

Indirect energy

Goal 20231: -60%
Performance: -9%
Target 2024: -10%

Target 2023: +6%✓Performance: +4%
Target 2024: -3,5%

scope 2 (market-based) and 3(travels)

scope 1

Target 2023: -15%
Performance: -7%
Target 2024: -10%

Target 2023: 0%
Performance2: +78%
Target 2024: +10%

1 The target defined for 2023 implied 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.
2 The increase recorded between 2022 and 2023 results from the lifting of restrictions on movement regarding mobility on duty, with a more
relevant impact resulting from plane travels.

Energy consumed*(MWh)Emissions avoided (tCO2)

62% reduction
since 2012

2500

ENERGY PRODUCED IN THE
PHOTOVOLTAIC PANELS
(MWh)
811

66 710800

60 2952000

700

55 769600

50 3681500

47 894

419

387

500

2342

40 073 41 377

300

500

24 501 26 374 25 034

1163

1074

200

100

0

0

2021

2022

2023

Energy production (MWh)
2014

2015

2016

2017

2018

2019

400

1000

35 889

2013

900

2020

2021

2022

*Refers to electricity consumption from the public grid.

157

2023

Emissions avoided (tCO2)

SUSTAINABILITY REPORT 2023

MWh per employee*
2023

4.0

2022

Reduction of 49% in the
consumption of electricity per employee since
2013

4.2

2021

3.9

2020

5.1

2019

5.7

2018

5.6

2017

6.7

2016

6.9

2015

7.5

2014

7.8

2013

7.8

*Refers to electricity consumption from the public grid, by employee.

Sustainable Development Objectives
SDG

Our objectives

Our contribution in 2023
Promotion of decarbonisation in Group BCP
Initiatives:•••

Contribute to limit global
warming to 2ºC.

In Portugal, two photovoltaic plants are in operation and the process of
installing micro photovoltaic plants in its branches has begun.
Gas boilers for heating and electric chillers for cooling were also replacedby heat pumps.
In the different geographies, business travel has been minimized, andwhenever possible, it is privileged to hold meetings and training in an
online format.

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 vehicles for the Bank's vehicle fleet in Portugal of
80% by 2030.
In Poland, the Bank replaced 100% of the vehicles in its fleet with gasoline-powered hybrid models.
The BCP Group reduced the total CO2 emissions of operations (scope 1, 2
and 3 – Category 6) by 20% compared to 2022, considering the emissions
associated with Portugal and Poland. In 2023, the reporting scope was extended to include Mozambique operations in scope 1 and 2.

Consumption of renewable energies
Results:
Increase the percentage of
renewable energy in total
consumption of fuel.

••

In Portugal, all electricity consumed was 100% green, in a mix of energy
produced by the TagusPark photovoltaic plant and energy purchased witha certificate of renewable 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 is 100% certified
from renewable sources.

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SUSTAINABILITY REPORT 2023
SDG

Our objectives

Our contribution in 2023
Financing of projects that contribute directly or indirectly to the conservation of biodiversity and ecosystems and to the sustainable management of forests
Initiatives:

Mobilise and increase thefinancial means for theconservation and respect
for biodiversity and foreco-systems and for thepromotion of a sustainable
management of forests, including maintenance andre-forestation.

•

BCP finances several environmentally responsible projects, with direct
and indirect contributions to the biodiversity conservation, in the areas ofenergy, forestry and agriculture, through Guarantee Lines with the European Investment Fund (EIF) and the European Investment Bank (EIB), under the EGF Community Programme – European Guarantee Fund; Capitalize More Line - SI Innovation; Credit Lines to support the Agricultural andForestry Sector - IFAP Short Term, Fisheries Support; Biznesmax Warranty
Program; Polish Green Economy Financing Facility; FECOP Calamities
Credit Line, among other.

Financing of renewable energy infrastructure and equipment projects and others
that contribute to/enhance the consumption of renewable energy
Initiatives:•
Ensure the universal accessto modern energy services
and to accessible prices.

•••

Sustainable Buildings Personal Loan - credit intended to finance the purchase of equipment to produce renewable energy or for the improvement of the energy efficiency of residential properties.
IFFRU 2020 Millennium Line – credit for the financing of investment projects to be developed by collective entities, public or private, aimed at urban rehabilitation and regeneration, enhancing improvements in the energy efficiency of buildings.
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
Following the progress achieved in the 2018-21 period, the Millennium Strategic Plan for the 2021-2024 cycle consolidates
the Bank's position in minimizing its environmental impacts and adds new elements consistent with the current context.
In this way, Millennium bcp incorporates in this Plan strategic priorities, which translate its
commitment to sustainability, and a broad adaptation to the main trends in the financial
sector, including the following objectives:
•

•
•
•

Innovate in own products with green and social classification aimed at Individuals
and Companies, risk appetite and funding structure influenced by the adoption of agreen 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 exposure to coal and petroleum products in European operations> 50%
Green Project Finance#1
Origination of green
bonds in Portugal

2023 Sustainability Master Plan - Environmental Action Plan
In its 2023 Sustainability Master Plan, the Bank includes the various lines of action through which it seeks to reduce its
negative environmental impacts and enhance positive ones.
Size
Compliance with requirements related withenvironment

Action Line- Continue to implement the recommendations issued by the “Task Force on Climate-related Financial
Disclosures” (TCFD).
- Mandatory Taxonomy reporting in 2023 compared to 2022.
- Prepare mandatory Taxonomy reporting for 2024, compared to 2023.

159

SUSTAINABILITY REPORT 2023
Size

Risk management

Action Line- Establish, carry out and document the process of assessing the materiality of the impact of C&E factors on the different risk typologies, in line with the expectations and recommendations of regulationand supervision.
- Integrate the other environmental risks (i.e. other than climate) into the C&E materiality assessment
and relevant processes.

Policies and regulations
on sustainable financing- Integrating climatic and environmental factors in collateral assessment.
- Develop internal portfolio alignment exercise for relevant sectors in the Bank's activity.

Climate change and energy transition- Promote the development of renewable energy through financing granted to the energy sector.
- Preliminary study for the installation of a 3rd photovoltaic power station (Car Parking).
- Accelerate the transition of the Bank's Car Fleet to energy efficient vehicles, with a mid-term review
in 2025 flow and the goal of reaching 80% by 2030 (stock).

Training and environmental awareness of theemployees

Promote individual awareness among employees for the adoption of environmentally responsible behaviour, through the creation and display of new environmental signs.

Sustainable Operations
To monitor the eco-efficiency of its operations, the Bank regularly monitors various environmental performance indicators. This monitoring allows you to identify opportunities and improvement actions more quickly and efficiently.
As established in the Environmental Policy, updated in 2021 and adopted by all geographies and operations of the BCP
Group, the Bank remains committed to the preservation of natural resources, through the rationalization of its consumption, namely energy, water and materials.
2023

BCP Group

2022

2021

Units

ValuesVar. % 23/22**

ValuesVar. % 22/21

ValuesVar. %
21/20

MWh

47 760 *-10%

46 463.8

6.2%

43 749.7-22.8%

Total

TJ

314 *

-12%

313.4

-12.7%

358.9-12.9%

Direct

TJ

82 *

-4%

68.5

-36.5%

107.8

11.9%

Indirect

TJ

232 *

-14%

243.4

-3.1%

251.1

-20.5%Water

m3

201 017 *-2%

176 287.8

7.7%

163 746.8-21.6%

Waste producedt

1 117 *

-10%

1 216.1-5.4%

1 284.9

54.8%

Total

t

1 360

-11%

1 531.5-2.9%

1 577.0-9.0%

Cardboard/paper

t

1 308

-12%

1 490.6-2.6%

1 531.1-9.5%

Plastic

t

52

+27%

40.8

-11.1%

45.9

12.7%

Total

tCO2 eq

11 813 *-20%

12 709.8-67.0%

38 476.5-22.0%

Direct Emissions***tCO2 eq

5 502 *

-5%

4 543.0-34.1%

6 896.2

8.9%

Indirect Emissions****tCO2 eq

6 611 *

-29%

8 166.7-74.1%

31 580.2-26.5%

Electricity – Public Grid
EnergyMaterials

Emissions of CO2* Inclusion of the operations in Mozambique within the scope of reporting.
** For comparison purposes, data from Portugal and Poland were considered, in order to cover the reporting scope of the previous year, with the exception of the materials indicators,
which already included Mozambique.
*** Scope 1 emissions.
**** Scope 2 and 3, Category 6 – Business Travel, emissions.

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SUSTAINABILITY REPORT 2023

Main communication initiatives and awareness of sustainability
Millennium bcp frequently publishes content on the internal Portal, with good practices and general informationand to foster the individual awareness of employees for the adoption of environmentally responsible behaviour, theBank has posted environmental signage at its facilities. In addition, it carries out the daily treatment of the alarming of out-of-hours consumption in the branches and promotes the awareness of those responsible for it.
Portugal

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.
Millennium bcp, in Portugal, and Bank Millennium, in Poland, are part of the Financial Times' "Europe's Climate
Leaders 2023" ranking, which highlights the 500 European companies that have made the most progress in reducing
greenhouse gas (GHG) emissions.
The Bank developed a campaign to encourage the adoption of the electronic statement, which resulted in a 16%
reduction in paper statements sent to customers.
As part of employee awareness campaigns, it promotes the use of reusable cups in the cafeteria of Bank Millennium's Headquarters

PolandThe Bank's headquarters and some branches have been recognized for their environmental efficiency. The headquarters building in Warsaw has obtained the BREEAM certificate (Very Good level) for the use of energy-efficient
lighting and the implementation of automatic systems to reduce energy and water consumption. The buildings in
Wrocław and Gdańsk have received LEED Gold certification, which accredits them as modern, energy-efficient, andeffective buildings.
Environmental topics were part of the ESG training given to Board members and to the first lines of relevant areasin Millennium bim's ESG process.
It is also planned for 2024 to make the e-learning course on Sustainability, including environmental topics, available
to all Millennium bim employees.

Mozambique

The Bank was present at the inauguration of the "Wall of Biodiversity" as part of the Memorandum of Understanding between the Bank and the company Recycling & Services (R&S). This initiative, which aims to paint about 40
murals about Mozambican wildlife, marine and flora, as a means of raising awareness of the population for the fightagainst poaching and for the conservation of Biodiversity.
The Bank also participated, at the invitation of the District Government of Gorongosa, in the 1st District Conference
on Dissemination of Climate Resilience Potentialities and Investment Attraction for Environmental Conservation,
expanding the panorama of debate around the contemporary solutions that the country sustains in the face of climate inclement weather.
As the only Bank to operate in the Gorongosa district, Millennium bim contributes to the ecological integrity ofphysical and biological resources, as well as to the creation of opportunities for investment in sustainable areas thatleverage the social and environmental values of the province and the country.

Group BCP carries out its initiatives so as to be able to comply with the goal ofreaching carbon neutrality from the Bank’s activity

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SUSTAINABILITY REPORT 2023

De-carbonisation
Group BCP carries out its initiatives to be able to comply with the goal of reaching carbon neutrality from the Bank’s
activity (direct emissions) until 2030) The effort to mitigate the carbon footprint has been intensified, namely throughthe reduction of emissions resulting from its activity.

* According to Pilar 3 sectoral scope, which excludes sectors J, K and M –U.

In relation to the emission reduction targets set for Portugal (15% reduction in total emissions and direct emissions –scope 1) and a 0% change in indirect emissions (scope 2 - emissions associated with electricity consumption - and scope
3, category 6 - emissions associated with business travel), the Bank was unable to meet the targets set, with a 7% reduction in direct emissions and an 78% increase in indirect emissions, justified by the increase in missions because of theincrease in air travel.

Scope 1 and Scope 2
In 2023, the trend of reduction in scope 1 and 2 GHG (Greenhouse Gas) emissions associated with the BCP Group's activity
continued, despite the inclusion of Mozambique in the calculation of emissions, with a reduction of 11% compared to thetotal emissions values of 2022. Scope 1 emissions represent emissions associated with the consumption of fuels andcooling gases and scope 2 emissions represent emissions associated with the consumption of electricity.
Regarding the scope 1 emissions of Group BCP, it recorded a 14% reduction versus the results achieved in the previous
year. Regarding scope 2 emissions calculated on a market basis (market-based), there was a reduction of 26% compared
to 2022, boosted by the reduction of the consumption of electricity for heath in Poland. In 2022, the Bank updated its
calculation methodology, in line with the GHG Protocol, to include the reporting of location-based Scope 2 emissions,having recorded a total of 19,283 tCO2e in 2023 (25% less than the figures recorded in 2022).
In Portugal, there was a 7% reduction in scope 1 emissions, and a 40% reduction in scope 2 (location-based) emissions,continuing to report 0 tCO2e in market-based scope 2 emissions, since it purchases electricity 100% from renewablesources. There was a reduction of 2% in scope 1 emissions and a reduction of 33% in market-based scope 2 emissions in
Poland. This was mainly due to a decrease in energy consumption for heat generation resulting from a decrease in thenumber of buildings, the optimization and modernization of the headquarters in Gdańsk, and the higher outdoor temperatures experienced during the colder season.
In relation to the overall performance of the BCP Group, there was also a 25% reduction in the value of tCO2e per employee (considering only scope 1, 2 and emissions), from 0.93 to 0.70.

162

SUSTAINABILITY REPORT 2023

GHG EMISSIONS (SCOPE 1 AND 2)(tCO2e)3.3
60 00050 000

4,0

3,5

2.9

3,0

40 0002,530 0002,042 73531 440

0.9

6 332

6 896

7 769
4 543

5 756
5 202

2020

2021

2022

2023

20 0001,5

0.7
10 0000

Direct Emissons (Scope 1)

Indirect Emissions (Scope 2 - Market-Based)

1,0

0,5

0,0

Total emissions by employee

Scope 3
Regarding Scope 3 emissions, there has been an improvement in the quality of the data used and the methodologies
adopted, compared to previous years, and other categories have been considered, according to the GHG Protocol, upstream and downstream, namely category 1 – Purchase of goods and services, category 6 – Business travel and category
15 – Financed emissions.
In 2023, it has not yet been possible to extend all the calculated categories to all geographies, being a process of continuous improvement that the Bank recognizes as relevant and for which it is developing work.

Category 1: Purchase of goods and services (amount)
Category 1 emissions are the sum of the Bank's suppliers' Scope 1, 2 and 3 emissions. In Portugal, in 2023, the scope of
suppliers for which reported emissions data was collected (around 15% of turnover) was broadened and, in the estimatedemissions, sources of information were used that provide more accurate data, and less based on sector estimates. Two
different approaches were adopted to estimate emissions in this category: i) supplier-specific – an approach to which
preference was given, whenever possible; and ii) spend-based, methodologies duly detailed in the chapter 'Methodological Notes'. Compared to the previous year, there was a 17% reduction in upstream Scope 3 emissions associated with
suppliers.
INDIRECT GHG EMISSIONS (SCOPE
3 - Suppliers)(tCO2e)70 64558 4982022

2023

In the same category, in Poland, emissions were calculated considering the following items: payment cards (units) - quantitative data provided by suppliers to calculate emissions resulting from the purchase of payment cards, taking into account the number of cards issued and destroyed; Office supplies (kg) - Purchased materials specified in units were considered: printed paper, envelopes, paper and paper rolls for operational needs, cardboard boxes, plastic materials (stretch
films, box bags, etc.), packaging for disinfectants and batteries; and water (m3), water purchased in plastic packaging anddrinking water from the water supply network were included.

163

SUSTAINABILITY REPORT 2023

INDIRECT GHG EMISSIONS(SCOPE 3 - Suppliers)(tCO2e)

749
746

2022

2023

Category 6: Work Travels (amount)In relation to the scope 3 emissions related with the mobility in service, there was an increase of more than 100% following the lifting of the institutional travel ban, which was implemented during the pandemic period, and the extension of
the reporting scope to Mozambique. This increase thus reflects the return of work-related commuting activities.
Regarding the overall performance of the BCP Group, in this category, there was a 115% increase in the value of tCO2e
per employee, from 0.03 to 0.05.
INDIRECT GHG EMISSIONS (SCOPE 3 - Business Travel)(tCO2e)
900

0.05

0,06

800

0,05

700

600

0,04

0.03

500

856

400

300

200

0,03

0,02

0.01

398
0,01

100

140
0

0,00

2020

2021

Category 6 - business travel emissions

2022
Total emissions by employee (Scope 3)

Category 15: Financed emissions (downstream)
In 2023, the Bank made significant progress, refining the methodology for calculating emissions under category 15, i.e.
financed emissions - scope 1, 2 and 3 GHG emissions of counterparties financed by the BCP Group. To determine theBank’s financed emissions, the guidelines of the Partnership for Carbon Accounting Financials (PCAF) were considered,and priority was given to reported emissions by counterparties whenever available. Whenever this information was unavailable, estimates were produced based on the idiosyncratic features of the counterparties, as well as on their activity
sector and country.

164

SUSTAINABILITY REPORT 2023

Main De-carbonisation Initiatives
Implementation of photovoltaic panels in eight branches, with a direct impact on the amount of electricity
purchased, and use of two photovoltaic plants with a production capacity of 1MWh each. The study for athird photovoltaic plant to be installed in the Taguspark Car Park was also authorized.

Portugal

BCP invests in the use of collaboration and productivity tools to reduce business travel, namely for meetings. Thus, in 2023, 401,175 meetings were held via MS Teams and Skype.
With the aim of transitioning to more sustainable mobility, the Bank replaced all gasoline cars in its fleet
and rented cars with diesel engines with hybrid models running on gasoline. For business trips, low emission means of rail transport are privileged and limits have been set for the use of air transportation.

PolandWith the same objective, Bank Millennium provides parking spaces for cyclists and toilet facilities, encouraging workers to use their bicycles as an alternative to public transport and cars.

Mozambique

Development and implementation of the green project at the Matola Municipality counter and at the head
office building.
To reduce the environmental impacts resulting from business travel, Millennium bim has also favoured MS
Teams meetings over face-to-face ones. In addition, it has a bus that supports the transport of employees.

Energy efficiency
To reduce energy consumption and its consequent impacts, the Bank has been investing in renewable energies, with its operations in Portugal and Poland operating
since 2022 with 100% of electricity coming from renewable sources.
Electricity consumption (MWh)Reduction of 32% in the total consumption of energy in the last 5
years

2023

Domestic: Portugal
Electricity originated in renewable sources
Electricity originated in non-renewable sources

25 0340International Poland & Mozambique14
Electricity originated in renewable sources

21 501

Electricity originated in non-renewable sources

1 224

In 2023 there was a slightly reduction of about 1% in energy consumption, although the scope of the indicator has been
extended to Mozambique, which reveals greater efficiency and responsibility in the consumption of this resource. In
2022, electricity consumption per employee was 3.04 MWh, having reduced, in 2023 to 2.04 MWh, a reduction whichreflects the efforts that have been made.
Within the scope of the targets set by Portugal for energy, the targets for indirect energy consumption (which includes
energy from renewable sources and electricity) were exceeded, with an increase of only 4%, when the target pointed to
an increase of 6%, as it was the year in which the return to the office after the pandemic would have the most impact on
consumption. In terms of direct energy consumption (which includes the consumption of fuels from non-renewablesources), the target was not met, with a reduction of 9% observed, far from the 60% planned reduction.

14 Calculation of the percentage of renewable and non-renewable energy of the electricity consumed in Mozambique based on the information published in IRENA(International Renewable Energy Agency).

165

SUSTAINABILITY REPORT 2023

BCP Group performance
TOTAL ENERGY CONSUMPTION - GRI 302-1(TJ e MWh/employee)
1 500
1 400
1 300
1 200
1 100
1 000
900
800
700
600
500
400
300
200
100
0

DIRECT AND INDIRECT ENERGYCONSUMPTION IN 2023
(TJ and %)15,0Indirect
Energy;
232;
74%

10,0

3.4

3.5

3.0

359 TJ

313 TJ

314 TJ

108

70
243

82
232

251

5,0

0,0

-5,0

-10,0

DirectEnergy;82; 26%

2021
2022
2023
Direct Energy
Indirect Energy
Electricity consumption (MWh) by employee

ELECTRIC ENERGYCONSUMPTION

INDIRECT ENERGYCONSUMPTION
(TJ)

(MWh)
47 760

DIRECT ENERGYCONSUMPTION
(TJ)

251

243

232 *

86

76

51

108
14

46 464165

43 750

70

25

3
10

172

41

1
13

57

49

2021
2021

167

82

20

2022

2023

2022

2023

Thermal energy
Electricity (with cogeneration)

2021

16

11

2022

2023

Natural Gas
PetrolDirect Energy

DieselLPG* Includes 9 TJ of energy from renewable sources.

Main energy efficiency initiatives
Portugal

Replacement of gas boilers for heating and electric chillers for cooling by heat pumps. This equipment, in
addition to being more efficient, replaces the use of gas, which, being the energy acquired by BCP green,
has a direct impact on CO2 emissions.
In 2023, to minimize electricity consumption at the Bank's headquarters, the operating times of various devices and equipment (e.g., the operating time of office lighting, the operating time of ventilation and air
conditioning, and the temperature settings in individual areas) were reduced.

PolandConsidering the difficulties experienced in the energy market throughout 2023, Bank Millennium has implemented additional measures to reduce electricity consumption, including the deactivation of light panels
and advertising screens at its headquarters and branches, throughout the country, after business hours.
In addition, the Bank continued to increase the number of branches with LED lighting. By the end of 2023,
186 branches had LED lighting.
Some floors of the Bank's head office in Warsaw were also refurbished. In this context, occupancy sensors
were installed in all bathrooms and pantries. The lighting system of the open space areas now includes, inaddition to the occupancy sensors, luminous intensity sensors that adapt the lighting according to the existing natural light.

MozambiqueMillennium bim has favoured the installation of LED lighting, in the event of a breakdown of existing systems.

166

SUSTAINABILITY REPORT 2023

Management of resources - Water, Materials and Waste
WATER
The total water withdrawal/consumption in the BCP Group, used for human conReduction of 29% in the total
sumption on the bank's premises and for irrigation, has registered a downward
consumption of water in the last
5 years
trend, and during the years 2022 and 2023, there was an increase in water consumption, justified by the return of employees to the physical facilities and subsequent
intensification of their use. Also contributing to this increase was the fact that, in 2023, the Bank extended the reporting
scope of this indicator to its operations in Mozambique, reflecting its growing commitment to transparency and accountability.
Despite the aforementioned variations, the values, both in Portugal and Poland, remain below the pre-pandemic levels
recorded in 2019. This reflects effective and efficient adaptation, as well as a growing awareness of the importance ofconserving natural resources by employees. It should be noted that there was a reduction in water consumption per
employee across the Group (from 11.7 to 10.7), reflecting not only an improvement from an efficiency point of view, butalso a greater awareness of the responsible use of water.
In relation to the target set for Portugal regarding water abstraction (2% increase - supported by the idea that the returnof employees to the office would have a negative impact on the consumption trend), this was not achieved, with anincrease of 4% being recorded. Despite this increase, water consumption per employee in Portugal decreased from 12.93
to 11.78, like what was been observed at Group level.

Water withdrawal in the BCP Group - GRI
303-3
11.7
(m3)
10.7
10.6

163 747

176 288

2021

2022

201 0172023

Total water withdrawal
Total water withdrawal by employee

MATERIALS
Regarding the consumption of materials, BCP Group (Portugal, Poland, andMozambique) achieving a 11% reduction in the consumption of the main,
namely, cardboard, plastic and ink cartridges. Among these, paper and cardboard account for the largest share – 96% of the total materials consumed.

Reduction of 36% in the total consumption of materials in the last 5 years

2021

2022

2023

Variation 23/22

CONSUMPTION OF MATERIALS (tons)

1577.21531.71360.4-11%- Paper & Cardboard

1531.11490.61308.5-12%- Plastic

45.9

40.8

51.8

27%

- Ink cartridges/Toners

0.2

0.2

0.2

-6%

CONSUMPTION OF MATERIALS (Kg) PER EMPLOYEE

143.3

97.3

86.7

-8%

- Paper & Cardboard per Employee

95.6

94.7

83.4

-12%

44.9

44.9

30.5

-32%

- Plastic per Employee

2.9

2.6

3.3

27%

- Ink cartridges/Toners per Employee

0.0

0.0

0.0

-53%

- Paper per Employee

167

SUSTAINABILITY REPORT 2023

There has been a downward trend in paper consumption, driven by the continuous digitalization of business processes
and the semi-annual communication of consumption to all Divisions. Contributing to this trend is, for example, a decreasein local printing and the digitalisation of incoming processes, with operations being a opened directly in the systems andapplications, avoiding the physical circulation of documents.
Main initiatives for reduction/ promote culture efficiency in materials consumption
Currently implemented in Millennium Operations Centre, the Kaizen Programme is applied by 304 employees, distributed among 32 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 2023, 191 improvement initiatives were implemented, 7% of which led to savings of around €10,737 in
consumables (e.g.: paper, printing, internal mail stamps, internal and external envelopes, among others).
For 2024, the focus on improving processes associated with a paperless philosophy, one of the main pillars of the Kaizen Program, will continue.
Millennium bcp carries out initiatives to encourage the use of e-mail instead of physical mail, with theultimate objective of reducing the amount of printing of customer documents. In 2023, 2.8 thousand
customers had the subscription of documents in digital format, of which 47% are active customers on thewebsite and mobile. This figure represents an annual growth of 7% in Customers who no longer receive
paper statements and release notes.

Portugal

The Bank continues to invest in the dematerialization of its operations. The "GO Paperless" project,which incorporates solutions for the production and electronic signature of documents, in 2023 saved
8,948,706 B&W prints, corresponding to a 16% decrease in prints made on branch equipment when compared to the same period in 2022 and which translates into an average monthly saving of 745,726 prints.
Regarding colour printing, 810,632 were avoided, which corresponds to a reduction of 24%.
In 2022, the first biodegradable plastic card, produced from cereals, which contains zero plastic and has
zero impact on CO2 levels, was launched in Portugal, the GO! Changer.
The centralization of the Bank Millennium Group's purchasing process in the organizational units of materials necessary for daily operations, supported by the REZA+ tool, through which the legitimacy of thepurchase of each item is verified, contributes to a circumscription of materials purchased to what isstrictly necessary. The permanent monitoring of budget execution and the definition of limits to reducepurchases also contribute significantly to the decrease of material consumption.
In 2023, the decrease in paper consumption persisted at Bank Millennium, although there was a significant increase in the number of customers. This is largely due to the Bank's effort to reduce this consumption through digitization and process optimization, supported by an omnichannel approach, basedon close cooperation between digital and traditional channels. In this context, the Bank also sought tolimit the bulk and personal correspondence sent to customers, which resulted in a considerable reduction in the consumption of paper and envelopes.

PolandThe need to issue plastic cards continues to decline as opposed to the growing popularity of payments
using virtual cards, BLIK mobile payments and BLIK contactless payments via mobile app. Also contributing to this is the implementation of the temporary card blocking option, which avoids the need to issue
a new card (when, for example, a customer loses his or her card and finds it in the meantime).

Mozambique

By December 2023, around 36% of M Customers (active) had subscribed to the services of digital statements and release notes, which contributes significantly to the reduction of paper used in these processes. In addition, the Bank favours the validation of digital documents, to the detriment of physicaldocuments.

WASTE
Regarding waste generation, in global terms, there was a reduction in waste generation in 2023, despite the extension of
the scope of the indicator to Mozambique (as with the other environmental indicators).

Waste Produced, per destination (t)Total of waste re-used/recycled*

2021

2022

2023

644.02639.37481.82

Waste for landfill

0.01

0.01

0.00

Other destinations*640.88576.71635.64

Total

1284.91

1216.091117.48*Calculation based on the assumption that 38% of waste isrecycled (INE, 2020).

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.

168

SUSTAINABILITY REPORT 2023

In Portugal, there was a significant increase, justified, as previously mentioned, by the expansion of the scope of waste
included in the calculation, as shown in the table below.

Waste produced in Portugal
Total of waste produced
Total of waste re-used/recycled
Paper
Card
Plastic
Ink cartridges/Toners
Total of waste in landfill
Total waste incinerated with energy recovery
Total waste incinerated without energy recovery
Total of waste with unknown destination
Paper
Card
Plastic
Ink cartridges/Toners

2021
Ton
854.12324.56277.49
45.99
0.85
0.23
0.01
0.00

2022
Ton
718.49272.96233.81
38.75
0.19
0.20
0.01
0.00

2023
Ton
711.06270.20231.23
38.33
0.18
0.46
0.00
0.00

Variation 23/22
%
-1%
-1%
-1%
-1%
-4%
128%
45%
-

0.00

0.00

0.00

-

529.55452.75
75.04
1.38
0.37

445.53381.48
63.23
0.31
0.51

440.85377.27
62.53
0.29
0.75

-1%
-1%
-1%
-4%
47%

Main initiatives for the reduction/management of waste
Millennium bcp, through the COM-Paperles initiative, has sought to reduce the circulation of physicaldocuments, challenging suppliers to adhere to the digital sending of mail and through the digitization of
the same physical documents upon arrival at the Bank.
Portugal

Digitalisation reduces the need for paper and paper transport, contributing to the reduction of the Bank's
environmental impact, along with improvements in operational efficiency, such as the reduction of timeassociated with the processing of physical documents, the feasibility of handling information outside theoffice and real-time collaboration.
In 2023, around 17,000 documents were scanned under these conditions.
The annual electronic waste collection campaign took place at Bank Millennium Head office and allowed
employees to appropriately donate electronic equipment they no longer use.
In addition to this campaign, there was also an annual collection of bottles and container caps collected
at the head office and branches. The bottles and caps collected in 2023 by employees were donated to
the Dom Rodzina Człowiek Association, which sells them as recyclable material. The value of this sale reverts to the assistance of needy people with disabilities, namely through the financing of the purchase of
prostheses, meals for families, among others.

PolandIn January 2023, the second phase of the process of clearing the premises of the Gdańsk Head office wascarried out, resulting from the renovation carried out in 2022. The furniture suitable for use was displayed on a sales platform, accompanied by due dissemination on the Bank's internal channels. This furniture attracted the interest of employees and private buyers, who purchased almost 69% of the furniture planned for liquidation. A charity sale was also organized, with the purpose of raising funds for 7 different charitable organizations and foundations.
This way, 83% of the equipment gained a second life, with only 17% being sent for recycling because it
was worn or damaged.
In 2023, 635 items of computer and computer equipment were given a second life. Of this number, 35
items were sold to Bank employees, 55 to external entities and 545 were donated to charities.

Mozambique

To reduce the production of plastic waste, a set of measures are being implemented to progressively purchase glass containers for board meeting rooms instead of plastic containers.

Offer of eco-friendly products and services
The financial sector, of which the Millennium Group is part, plays a key role in mobilizing and accelerating the transition
to a greener economy. Accordingly, and in addition to the responsibility for minimizing the negative environmental impacts arising from its operations, the Bank (see chapter on Sustainable Operations) has sought to intensify the incorporation of ESG criteria, namely environmental performance criteria, in its offer.
Thus, with the purpose of mobilizing customers to opt for greener choices and more sustainable lifestyle habits, the Bank
makes available in the various geographies in which it operates, a set of products and services that meet these considerations.

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SUSTAINABILITY REPORT 2023

Portugal•
Green home loans - product that requires compliance with energy classification requirements: acquisition orconstruction 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 hybridcars with CO2 emissions up to 50g/km•
Sustainable Buildings Personal Loan - product for the acquisition of equipment to produce renewable energies
or for the improvement of the energy efficiency of residential properties.
•
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 orotherwise, 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 tocustomers in the various distribution channels.
•
Sustainability linked loans - In 2023, Millennium bcp carried out 3 Sustainability Linked Loans Commercial Paper Operations/Programs in the global amount of 230 million euros, with sustainability indicators related to
GHG emissions.

PolandSince 2021, with the launch of the EU's strategic green finance project, Bank Millennium has been providing product andprocess infrastructures to effectively support companies in the implementation of green investments and the energy
transition.
•

•

•

•

•

Millennium TFI Funds - One of the measures implemented as part of the Bank's strategy was the integration of
ESG factors into 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 – within the scope of the long-lasting partnership established by the
Bank with the Foundation WWF Poland, this card, made 85% of recycled plastic, is the motto for the provisionof financial support to the organization's statutory activities, focused on the protection of forest ecosystems.
The cooperation implies, among other things, the issuance of the credit card WWF Millennium Mastercard. For
each card issued, the Bank donates PLN 50 to the organisation.
Biznesmax Guarantee Programme (in cooperation with Bank Gospodarstwa Krajowego) - the guarantee isused to secure loans granted to finance innovative projects in the SME sector, including environmentally efficient enterprises. Beneficiary clients may implement an investment project with at least one category, for example: electromobility, renewable energy sources covering photovoltaic installations, technologies to reduceenergy consumption, technologies to produce alternative fuels, circular economy, installations to recover raw
materials in production processes, etc.
Program Mój Elektryk implemented by Bank Ochrony Środowiska – Millennium Leasing continued the implementation of Mój Elektryk, which guarantees co-payments from the National Fund for Environmental Protection and Water Management for renting electric vehicles and co-payments from the National Fund for Environmental Protection and Water Management for the upfront payment on electric vehicle lease contracts. 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 zeroemission vehicles.
Green loans for photovoltaic projects: financing for the construction of a photovoltaic installation or plant, inthe self-consumption or mix regime.

Bank Millennium in Poland has been trying to significantly reduce its exposure to the coal industry, whose financing constraints are expressed in the Environmental Policy. For this reason, the portfolio of exposures to coal mining and directly
ore-related industries is insignificant.

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Mozambique•
Smart IZI – Mobile Banking application that covers all operations associated with the service - membership,
registration, and use - in a functional and accessible way. Two new ones were made available in 2023: Salarycredit and the management of the transactional limit of the Mobile Banking+ channel.

Green Project FinanceMillennium bcp has been seeking to increase its financing portfolio for environmentally sustainable projects and organisations. To this end, in 2021 it published the Principles of Responsible Financing which identify, among other things, theexcluded projects and sectors/projects conditioned within the scope of the financing promoted by the Bank. 15. As can beseen, there has been an increase in the percentage of 16 'green' financing in the total project finance portfolio, except forthis year's results.
Within the scope of the activities financed, the following are included: 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 28% of the total number of projects.

“Green” financing at Millennium bcp

46,1%
41,0%

38,3%

36,1%

32,7%

2019

2020

2021

2022

2023

“Green” finance by type of investment
23%

28%

EólicasHídricas
Ambiente

9%Biomassa
Solar

18%

22%

Taxonomy of the European Union
The European Union Taxonomy - Regulation (EU) 2020/852 - is a system that identifies economic activities that can be considered green or environmentally sustainable thereby translating the EU's climate and environmental objectives into criteria
for investment in certain economic activities.

15 The Bank's Sustainable Finance Policy, is available here: https://investimentos.millenniumbcp.pt/en/Documents/MT0184-EN.pdf
16 Project finance operations whose purpose is aligned with Green Loan Principles were considered as 'green'.

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SUSTAINABILITY REPORT 2023

On this basis of transparency and regulation, the European Commission adopted on 6 July of 2021 the Disclosures Delegated
Act – Commission Delegated Regulation (EU) 2021/2178 (“Disclosures DA”), 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 key performanceindicators (KPIs) and templates for different types of entities.
The Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 (Climate Delegated Act) supplements the EU Taxonomy Regulation, by establishing the criteria under which an economic activity can be considered environmentally sustainable, through the contribution for climate change mitigation or climate change adaptation objectives (the two initial environmental objectives).
The Disclosures and Climate Delegated Acts were later amended to incorporate the disclosure requirements stemming fromthe Commission Delegated Regulation of 9 March 2022 (Commission Delegated Regulation (EU) 2022/1214 – Complimentary
Climate Delegated Act), which sets the criteria for specific gas and nuclear activities to help accelerate the shift from solid or
liquid fossil fuels.
Finally, the Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023 (Environmental Delegated Act) supplemented
the existing regulations, by establishing the criteria ruling the remaining (four) environmental objectives.
In this context, Millennium bcp discloses the applicable indicators and information pursuant to Article 10 of the Disclosures
DA, following the Article 8 of the EU Taxonomy Regulation, including the Green Asset Ratio (GAR), which represents the
proportion of assets in EU Taxonomy aligned activities over the total covered assets.
The complete set of required KPIs and templates is available in the appendix chapter 'European Union (EU) Taxonomy
alignment table'.
The legal basis for the disclosures
Pursuant to the Article 10 (5) of the Disclosures DA, from 1 January 2024, Millennium bcp is required to disclose the key
performance indicators for financial undertakings (the Green Asset Ratio), including all relevant accompanying information,
based on Annexes V, VI, XI and XII of that regulation (whereby points 1.2.3 and 1.2.4. Annex V shall apply from 1 January2026). Similarly, the disclosures related to the specific gas and nuclear activities, resulting from the Complimentary Climate
Delegated Act are also applicable from 1 January 2024 onwards.
On the other hand, under Article 10 (7) of the Disclosures DA, in the period from 1 January 2024 to 31 December 2025,
Millennium bcp only discloses the percentage indicators of EU Taxonomy eligible and non-eligible activities (along with relevant qualitative information) – for the activities specified in the Environmental DA.
In this regard, Millennium bcp prepares and discloses the required qualitative and quantitative information, in accordancewith the methodologies described in the following sections. Based on the applicable provisions, these disclosures comply
with:▪
Qualitative information referred to in the Annex XI of the Disclosures DA;▪
Quantitative information referred to in the Annexes V and VI of the Disclosures DA, including the Annex XII introduced for the nuclear and specific gas activities by the Complimentary Climate DA. In particular:
Annex VI disclosures – includes the KPI templates: 0) summary of KPIs; 1) assets for the calculation of GAR (reported twice, based on turnover and on CAPEX); 2) GAR sector information (reported twice, based on turnoverand on CAPEX); 3) GAR KPI stock (reported twice, based on turnover and on CAPEX); and 4) GAR KPI flow (reported twice, based on turnover and on CAPEX).
Annex XII disclosures – includes the quantitative and qualitative disclosures for the specific nuclear and gas activities.
The scope for the EU Taxonomy application
Millennium bcp is required to publish the legal information on the EU Taxonomy, pursuant to the provisions of the Regulation(EU) 2020/852. The information is prepared on a consolidated basis, following the prudential consolidation perimeter.
These are the legal entities included in the prudential consolidated perimeter:▪
Banco Comercial Português, S.A.;▪
Banco ActivoBank, S.A.;▪
Bank Millennium, S.A.;▪
Banco Internacional de Moçambique, S.A..

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SUSTAINABILITY REPORT 2023

All the relevant assets for each of the above entities were assessed in relation to the EU Taxonomy criteria. The environmental objectives establishing the basis for the assets’ screening comprised the two first environmental objectives – Climate
Change Mitigation (CCM) and Climate Change Adaptation (CCA) – defined by the Climate DA, and the additional objectives,
whose criteria is laid down in the Environmental DA, totaling the following six environmental objectives:▪
Climate change mitigation;▪
Climate change adaptation;▪
Sustainable use and protection of water and marine resources;▪
Transition to a circular economy;▪
Pollution prevention and control;▪
Protection and restoration of biodiversity and ecosystems.
Resting on the recent European Commission clarifications – namely the FAQs published in the EC notice from 21 December
2023 – Banco Comercial Português, S.A. (or Millennium bcp) is complying with the mandatory disclosures – the information
being reported is based on actual data collection, as prepared by the Bank’s counterparties.
Given that the regulation has been only recently applicable, it was noted that counterparties associated to the relevant Taxonomy assets, are not yet reporting their eligibility or alignment with the additional (four) environmental objectives (Environmental DA) – for this reason, Millennium bcp is not disclosing eligibility nor alignment information for those same objectives.
To perform the screening of the EU Taxonomy criteria, the following relevant assets and portfolios are assessed, from theGroup’s balance sheet (on and off exposures), but part of the banking book:▪
Loans and advances to non-financial corporations: these are credit-related activities consisting of funds that are directly
disbursed to corporate companies. The funds are still outstanding, in full or in part, at the reporting date and are assessed based on their gross book-value. Independently of the contractual definitions or any collateral’s characteristics,
the whole portfolio was subject to the EU Taxonomy application process.
▪
Loans and advances to households: these are credit-related activities consisting of funds that are directly disbursed by
the Group to natural persons. The funds are still outstanding, in full or in part, at the reporting date and are assessed
based on their gross book-value. Only the loans related to residential mortgages and car-vehicle financing were subject
to the EU Taxonomy application process.
▪
Investments in financial securities: these are debt (e.g., bonds, commercial paper) or equity (e.g., funds, stocks) instruments represented by financial securities held in the Group’s banking book that are primarily maintained for liquidity
management purposes. The relevant amounts for the EU Taxonomy application correspond to the effective book-valueof these instruments.
▪
Local governments financing: these are credit-related activities consisting of funds that are directly disbursed to local
sovereign (e.g., municipalities) entities. The funds are still outstanding, in full or in part, at the reporting date and areassessed based on their gross book-value. Independently of the contractual definitions or any collateral’s characteristics, the whole portfolio was subject to the EU Taxonomy application process. In general a) the entities herein included
are not required to disclose non-financial information (and no data is yet available following bilateral communications);
and b) the existing contractual agreements are based on general purpose provisions, which resulted in the absence ofamounts being reported for this specific segment.
▪
Non-current assets held for sale: the repossessed real estate assets (residential and commercial immovable properties), classified in this balance sheet item were subject to the EU Taxonomy application process, by the respective bookvalue as of the reporting date.
▪
Other banking book items: the guarantees given and the assets under management (AuM) were assessed for the purpose of the EU Taxonomy disclosures. The respective screening was performed following the nature of each item, in
accordance with the definitions above presented.
The trading book is not yet subject to the disclosure requirements (as per the Disclosure DA Article 10, the quantitative
disclosure requirements apply from 1 January 2026). Without prejudice, the current trading exposures mainly correspond tosovereign-debt instruments (none of each labelled with the EU Green Bond Standard). Therefore, this portfolio lacks any
type of contribution for the Millennium bcp’s alignment with the EU Taxonomy.
The assets or balance sheet items not above identified are not relevant for the EU Taxonomy application – they may be partof the KPIs denominator but do not directly contribute for any mandatory performance indicator.

The screening process leading the EU Taxonomy application

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SUSTAINABILITY REPORT 2023

The screening process to determine to what extent the above defined portfolios and assets are environmentally sustainablefollows a four-stages approach:▪

Stage 1 - eligibility: the asset shall correspond to a relevant activity considered to potentially have a substantial contribution to one or more of the environmental objectives defined in the EU Taxonomy Regulation. Those activities arecalled ‘taxonomy eligible’ – i.e., they correspond to an activity that is covered by either the Climate and/or Environmental Delegated Acts;
If the asset corresponds to an eligible activity, further screening takes place to assess its alignment with the EU Taxonomy,
for which the following criteria shall be met:▪
Stage 2 - alignment: the asset should have a substantial contribution to any of the EU Taxonomy six environmental
objectives;▪
Stage 3 - alignment: the asset cannot significantly harm any of the other environmental objectives; and▪
Stage 4 - alignment: minimum social safeguards are met.
In strict compliance with the provisions established by the Disclosures DA (and supplementary guidance provided in the EC
December 2023 FAQs), the screening process is based on actual information disclosed by the counterparties (i.e., the EU
Taxonomy KPIs applicable to non-financial undertakings) or collected through the Bank’s processes (e.g., residential collateralmanagement). Also, the way the screening is applied depends on the type of lending or investment purpose, in accordance
with:▪

General purpose lending or investing: the screening is based on the counterparties disclosures of the proportions ofrevenues (Turnover) and capital expenditures (CAPEX), respectively, resulting from or related to environmentally sustainable activities, published by the direct counterparty or respective consolidating company. Therefore, for this typeof transactions, the screening is performed twice (i.e., both for CAPEX and Turnover).
▪
Use of proceeds lending or investing: the screening is based on the Group’s own assessment of eligibility and alignment,
based on the analysis performed to the activities being financed according to the respective technical screening criteria(described in the EU Taxonomy’s delegated acts).
The screening process is performed by internal functions that are independent from the business lines and are led by the
Sustainability Functions of each Group entity. In general, the process criteria are automated in the entities’ systems being
data kept and controlled in dedicated ESG-related platforms.
The external data used (i.e., disclosed by the companies) is captured through a data provider – whenever possible or needed,
Millennium bcp has complemented such data with individual/ direct information collection from the companies’ public disclosures.
Main methodological assumptions and uncertainties
The regulatory framework is still evolving, impacting the institutions’ interpretation on the requirements’ application. This isalso demonstrated by the recent European Commission notice, from 21 December 2023, which aimed at clarifying somerequirements for the preparation of the EU Taxonomy disclosures by the financial undertakings.
Despite all the efforts the Group has been doing to collect the required information for the EU Taxonomy reporting, the data
availability remains an operational challenge. Following the Article 8 of the Disclosures Delegated Act, the Group uses themost recent information published by the counterparties – for most of the counterparties the information was publishedwith reference date of December 2022, which may cause fluctuations in the 2023 update. Also, the number of counterparties
disclosing the required data is still limited, especially for Portugal and Poland where the economic activity and balance sheet
exposures are mainly driven by Small and Medium Sized companies, not yet obliged to the non-financial reporting obligations. Adding to this limitation, the Group’s business model is significantly based on retail lending which constitutes an additional challenge in the process of determining the volumes of sustainable assets.
Against this background, Millennium bcp considers the KPIs resulting from the EU Taxonomy application, of limited comparability across banking institutions.
In what relates to the household financing, the application of the Do No Significant Harm (DNSH) criteria, especially for thephysical-risk assessment, was based on the Millennium bcp’s internal risk management practices. The assessment performed
is in line with the EU Taxonomy requirements, but the market data unavailability may lead to limitations in the accuracy of
the results.
Considering the above, the following key assumptions were made in the screening process for household financing in Portugal:▪
All the mortgage’ loans granted for the acquisition or renovation of residential immovable properties are EU Taxonomy
eligible, for the climate change mitigation objective;

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SUSTAINABILITY REPORT 2023▪

The technical screening criteria for the substantial contribution consider only the actual collected Energy performance
Certificate (EPC), corresponding to the classes A and B;▪
The DNSH screening was based on the internal risk management practices, allowing Millennium bcp to perform a location-specific assessment of physical risk factors. Therefore, only the properties that are not significantly exposed tophysical risks’ events (floods, heat stress, hurricanes & typhoons, sea level rise, water stress and wildfires) are deemed
to verify the DNSH criteria.
In what relates to household financing Polish and Mozambican assets, due to insufficiencies of the information on the specificfinality and the lack of actual EPC data, no eligibility or alignment is reported.
Summary of the main EU Taxonomy metrics
For 2023, Millennium bcp reports a mandatory eligibility ratio of 26,86%, based on the turnover ratio of the counterparties(26,98% based on the CAPEX). The 2023 figures include the households financing portfolios – following the methodologicaldefinitions above provided – and the exposure to NFRD companies, based on the actual information reported by those counterparties. The breakdown of the above information is provided in the appendix chapter 'European Union (EU) Taxonomy
alignment table'.
The assets meeting the criteria assessed by the screening process are considered as EU Taxonomy aligned and part of theGroup’s Green Asset Ratio (GAR%) – as of 31 December 2023, the Group’s GAR is 2,9% (based on the turnover KPI).
The largest contribution to the GAR% computation comes from households financing, which is the most relevant businesssegment for Millennium bcp. The exposure to counterparties in the NFRD scope – both through loans and advances andinvestment portfolio – is the second largest component of the GAR% aligned assets. If solely the exposures to NFRD companies were assessed as sustainable, the GAR% obtained would be 0,17%.
EU Taxonomy metrics – turnover based

Amount(mio EUR)

Loans and advances, debt, and equity securities

40 32017 681

26,86

1 934

2,94

Financial corporations [a]

2 686

486

4,08

158

0,24

NFRD Non-financial corporations [b]

1 216

388

0,59

115

0,17

Households [c]26 26815 934

24,21

1 657

2,52

Local governments [d]

971

648

0,98

0

0

Repossessed assets [e]

226

226

0,34

3

~0

Total assets in numerator and denominator17

65 81917 681

26,86

1 934

2,94

Non-NFRD counterparties

19.666

---

---

---

---

Derivatives

41

---

---

---

---

Interbank loans

337

---

---

---

---

Cash and other assets

5 456

---

---

---

---

Total assets in the denominator

65 819

---

---

---

---

Green Assets Ratio (GAR%)

Eligible

Eligible%

AlignedAligned %2,9 %17 Obtained by summing up a + b + c+ d +e .

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Climate & Environmental materiality assessment
Identifying risks and assessing the materiality of climate and environmental (C&E) risk factors is an essential component of
ESG risk management. The C&E Materiality Assessment exercise forms the basis for characterising the impact of C&E factors
on the BCP Group's risk profile, informing regular risk management processes.
Understanding the potential impacts of climate change and environmental degradation on its activity, both directly andthrough its customers' businesses, will enable the Group to make informed decisions on how to manage and mitigate theserisk factors, while at the same time allowing it to identify new opportunities arising from the transition to a low-carbon andenvironmentally sustainable economy.
In order to obtain an exhaustive assessment of the impacts of C&E risk factors, the C&E Materiality Assessment (MA) exercise
was carried out:
•
•
•
•
•
•

It is based on a substantially renewed methodology, geared towards better quantifying the impacts of C&E factors
on the Group's balance sheet.
It addresses transition, physical and nature-related risk factors;
It produces an approach to quantifying exposure to risk;
Adopts a forward-looking view of risk impacts, taking into account reference climate scenarios and extended time
horizons;
Covers all (i) three geographies fundamental to the Group's activity; (ii) relevant counterparty portfolios andsegments, assets held (e.g. tangible) and reputation;
It maps the impacts of C&E factors on traditional risk categories and assesses their materiality;

Overview of the methodological approachSteps

2. C&E exposure in risk
quantification

1. C&E risk factors

3. C&E Materiality Assessment Opinion

Following climate science, the use of different scenarios is particularly relevant to understanding the sensitivity of businessstrategy to different climatic and economic paths. The methodologies developed provide an assessment based on different
perspectives of the evolution of C&E variables and the respective impacts on economic and financial factors.
The results reported here for the materiality assessment of the climate and environmental risks are the result of the following
set of variables:•••

2030 as the target year/"central scenario", for all risk factors/types;
Scenario Net-Zero 2050 for forecasting transition risk results. This scenario is based on the assumption that global warming
will be limited to 1.5ºC due to the immediate introduction of ambitious climate policies and CO2 removal technologies aimed
at accelerating decarbonisation, resulting in high transition risks, in the short and medium term;
RCP 8.5 scenario for predicting physical risk outcomes. This is a purely geophysical scenario that predicts greater physical risk
as a result of the assumption that emissions will continue to increase, accentuating global warming to critical levels that leadto serious and frequent physical risk events, responsible for causing damage to assets and interrupting production processes.
The following table summarises the methodologies applied to quantifying the impacts of C&E factors and the respective
mapping of the Group's "traditional" risk categories.

C&E Risk Methodology
Climate related
Transition risk Companies
Climate related
Transition risks
Individuals

Risk Factor Mapping

PolicyTechnology

Traditional
Risk Category

CreditLiquidity
MarketReal EstateBusiness

Assessment Approach
Sectoral approach that accounts for the expected impact of cost increases on thecompany's profit margin, considering the following risk factor components: i) carbon
shock; ii) energy shock; and iii) capital expenditure shock (decarbonisation).

Impact of: i) income stress; and ii) transition risk impacts on the financed asset. The
methodology considers the clients' sector of employment as a sectoral risk.

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Climate related
Transition
risks
Real estate
Climate related
Physical risk
Companies
Climate related
Physical risk
Own Buildings& Activities

Risk related tonatureCompanies

The transition to stricter energy efficiency standards can have a negative impact on
the assessment and performance of less energy-efficient buildings. Therefore, the Energy Certificate (EC) of each building is considered: the lower the EC, the greater therisk associated with the building.

SevereChronic

CreditLiquidity
MarketReal Estate
Operations
Business

Physical climate risks can affect business continuity by impacting an organisation's
buildings, their equipment or causing any other disruption to activity related to the«assets» located in those buildings, namely staff facilities and any other services.
The methodology uses Moody's tool, Climate on Demand, to estimate the level of riskof the following physical climate events: i) Floods; ii) Thermal stress; iii) Hurricanes
and Typhoons; iv) Sea level rise; v) Water stress; and vi) Forest fires.

Biodiversity
Agroforestry Systems
Water

CreditLiquidity
MarketOperations
Business

For each of the categories considered - biodiversity, agroforestry systems and water a risk score is assigned based on two components: geographical location (taking into
account distance to sensitive areas, the aridity index and distance to bodies of water);and sectoral impacts and sectoral dependencies on ecosystem services (using the ENCORE classification tool and considering the dimensions of habitat integrity, provisionof food and other goods, and water security).

Overview of the Assessment Results
The application of these methodologies has made it possible to measure the percentage of the Group's portfolios that issensitive to C&E factors [i.e. exposure at risk, EaR] and to draw a conclusion on materiality for specific C&E risk factors: thegreater the share of EaR, the greater the exposure to C&E risk factors.
These results are a view of the gross risk, before any mitigating effect (for example, they don't take into account insurance
policies for the mortgage portfolio, nor corporate loans with public guarantees), which can significantly reduce the residual
risk.

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85% of the Group's
total assets
16% of C&E evaluated
13% of the Group's assets

19% of C&E evaluated
16% of the Group's assets

Exposureat Risk

Exposureat Risk

4% of C&E evaluated
4% of the Group's assets
Exposureat Risk

64% of the Group's
total liabilities
18% of C&E evaluated
12% of the Group's liabilities
12% of C&E evaluated
8% of the Group's liabilities
6% of C&E evaluatedExposureat Risk

4% of the Group's liabilities
Exposureat Risk

Total of assets/liabilities subject
to C&E assessment

Exposure to physical risk factors

Exposure to transition risk
factors

Exposureat Risk
Exposure to nature-related
risk factors

For the BCP Group, reputation is a category in itself. But since reputation can be affected by C&E factors, along with socialand governance factors, it must also be addressed in the C&E materiality assessment. For this reason, the Group has
developed its methodology for assessing the impact of C&E factors on reputational risk.
Reputational risks result from negative perceptions on the part of clients, counterparties, shareholders, investors, debtors,
market analysts, other relevant parties or regulators, which can negatively affect a bank's ability to maintain existing business
relationships or establish new ones and continued access to funding. The table below presents the relevant risk factors andbriefly describes the methodology developed to assess reputational risk. The assessment did not identify any relevant
problems or risk exposure.

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Assessment approach of reputational risk

ESG risk factors

Risk Factor Mapping

Assessment Methodology

Identify reputational risk factors through:Reputation and greenwashing

Reputation - greenwashing; Reputation - stakeholders• Sample of counterparties classified by four different ESG ratings to assess ESG
performance. The ratings were converted into a High-Medium-Low risk scale,with EaR corresponding to exposure to counterparties with at least two Highratings.
• Sample of products (commercial and investment offers) based on a content
analysis approach; three criteria were investigated for each product: a) relationship with the ESG concept; b) purpose of the offer; and c) description of theinformation required to access these products.

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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 fightagainst climate change. In this sense, the Bank seeks to align its reporting with the recommendations of the Task Forceon Climate-Related Financial Disclosures (TCFD), as presented in this chapter.

GOVERNANCE
To guarantee an effective management of environmental issues in the Bank (including climate change), the existence ofa governance structure transversal to the organisation is ensured, capable of responding to environmental issues andensuring a timely decision-making aligned with the strategy of BCP Group.
Ownership

Activities
Global responsibility for the BCP Group's ESG strategy, management and control framework in the Group, including the definition, approval and supervision of the effective implementation of the ESG strategy and its implementation agenda, being responsible for:•••Board of Directors

2.3
3.3
4.3

Executive Committee

5.3
6.3
7.3
8.3

Sustainability Committee
Chaired by the Chief Executive
Office, Chief Risk Officer andheads of other Divisions

Approval of corporate Policies and Principles;
Approval of the Sustainability Report;
Monitoring of the implementation of the SMP through the progress report included in the Risk Appetite Statement;•Group risk disclosure for Pillar 3 purposes;•
Approval of the Group's annual C&E materiality assessment;•
Approval of the exercises for aligning the emissions portfolio and setting targets;•
Approval of the transition Plan.
Approval of the SMP;
Monitoring of the implementation of the SMP through the progress report includedin the Risk Appetite Statement;
Establish the ESG business strategy, including aspects from customer engagement toproduct development;
Define the commercial and operational objectives to ensure the achievement of theGroup's sustainability strategy;
Implement the ESG organizational model;
Define the approaches and methodologies to identify, assess and manage the relevant ESG risk factors;
Lead the Group's communication plans and statements on ESG, including the definition of frameworks and respective commitments signed/to be signed by the Group.
•

Monitor the implementation of the SMP that includes ESG and climate changerelated components.
In addition, each local entity assists the local Executive Commission and the Sustainability
Commission in defining local ESG regulations and procedures.
•

Risk Assessment Committee
Composed of the Chief Executive
Officer, Chief Financial Officer,
Chief Risk Officer and heads ofother Divisions•••
Committee for Corporate Governance, Ethics and Sustainability (CGSES)••

Define and supervise the overall risk management framework (including ESG
risks);
Formally integrate the monitoring of ESG risks into the topics monitored by theCommission (Art. 7 – Competences, attributions and duties);
Identify risks related to climate change and incorporate policies and procedures to ensure the continuity of the Bank's activity in the event of natural disasters.
Recommend the adoption by the Board of Directors (BoD) of policies in accordance with ethical, sustainability and corporate social responsibility principles
and best practices;
Assist the BoD in assessing the progress of the Group's SMP and oversee compliance with national and international ESG, legal and regulatory requirements.
Issue opinions on annual corporate governance and sustainability reports.

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Ownership

Activities•

Sustainability Areas••

Implement, internally streamline and monitor the actions of the SMP, which
include actions related to climate change, namely in the areas of improving energy efficiency and increasing the consumption of energy from renewablesources;
Provide support to the structuring of the offer with environmental criteria;
Provide support for climate and environmental risk management in compliancewith applicable regulations, objectives, and targets.

STRATEGY
Climate Risks and Opportunities
Climate change is a risk considered relevant for BCP, with the potential to impact the Bank in the short (up to 3 years),
medium (3-8 years) and long term (9-18 years). In accordance with the classification recommended by the TCFD, andother relevant entities, the Group recognises the division of climate-related risks into physical risks and transition risks,
defining them as follows:-

Physical Risk: refers to the direct and indirect impacts of climate change on the environment, and can be classified
as:i. Severe: when it is derived from extreme weather events that cause acute destruction to
the environment, such as forest fires, floods, storms and heat waves, orii. Chronic: when it arises from progressive changes in climate and weather patterns, such as
rising sea levels, water stress and changes in precipitation patterns.
All these risk factors can result in physical damage to assets, infrastructure, and communities, as well as disrupt supply
chains, decrease levels of production and service delivery, and consequently decrease economic productivity.
−

Transition Risk: refers to the risk of any negative financial impact that results, directly or indirectly, from the misalignment between the business model/strategy of the counterparties or invested assets and a low-carbon and environmentally sustainable economy. This transition may involve changes in energy systems, regulation, taxation,and investment patterns, which can disrupt established business models and cause significant financial losses inmore vulnerable sectors or companies.
In the most recent climate-related and environmental (C&E) risk materiality analysis exercise, the Bank's approach wasconsistent with the factors defined by the TCFD, recognizing and analysing the following climate risk factors:
Risks
Risk Factors

Description

ImpactRegulatory& Legal• Risk of introducing new regulation and amending existing regulations and policies
with the aim of accelerating the decarbonisation process. For example, stricter
energy efficiency requirements, introduction of carbon footprint tax mechanisms,
policies that encourage the sustainable use of environmental resources, prohibition of the production of certain goods (e.g. combustion vehicles).
• Risk that the level, speed or nature of decarbonisation-related policy uptake willchange.
• Increased settlement and litigation costs as a result of the failure to mitigate theimpacts of climate change, the failure to adapt to climate change, and the failure
to provide sufficient climate disclosures.

Short- andmediumterm

Technological• Technological changes related to energy efficiency, low-carbon transport and increased use of non-fossil fuel sources.
• Development of technologies with less impact on the climate and environment,
leading to the obsolescence of existing technologies.
• Business models of companies based on technologies that use energy sources that
may become more expensive as a result of policy actions (e.g. through higher efficiency standards or the introduction of carbon taxes).
• Replacing existing products and services with others with lower emissions.
• Risk of unsuccessful investment in new technologies, including 'enabler' technologies that are not sufficient to support decarbonisation.

Mediumterm

Market• Changing customer behavioural patterns – increased demand for green/sustainable products and services.
• Risk that financial institutions will avoid providing equity, debt or insurance financing due to a preference for customers with lower GHG emissions.

Mediumterm

Transition

Risk Category181

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Physical• Risk that Customers have partners (e.g. suppliers) that increase their carbon footprint.

Reputation• Changing consumer preferences towards low-carbon and more sustainable alternatives.
• Risk that the Bank's green and ESG products and practices will be identified as
overly ambitious, or even false.
• Increased stakeholder concern with ESG issues.
• Risk that stakeholders (e.g., employees, suppliers, shareholders) will avoid investing in or working with a carbon-intensive and/or misaligned company.

Short term

SevereIncreased severity and frequency of extreme weather events, such as:• Floods• Heat Stress/ Heat Waves• Forest fires• Storms - Hurricanes and Typhoons

Short term

Chronic

Progressive changes in climate, such as:• Hydraulic Stress• Sea level riseLong term

Opportunities

Resources Efficiency

Reduce operating costs by:• Use of more efficient modes of transport• Reduced water use and consumption

Short term

Energy Sources• Reduce operating costs and exposure to rising prices of fossil fuel-derived energy sources, as well as exposure to rising carbon price in GHG emissions,through the use of low-carbon energy sources.
• Benefits associated with the Bank's improved reputation for implementing renewable energy sources.

Short term

Products and Services

Improve competitive positioning to reflect changing customer and stakeholder preferences, resulting in improved reputation and potential increase in customers andrevenue, through:• Development and sale of new green/sustainable services and products, including low-carbon products and services.
• Financing projects with climate, environmental and/or social benefits.

Short termMarkets• Increase revenues through access to new and emerging markets, such as markets associated with ESG investing.
• Diversification of financial assets (e.g. green bonds)

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Mediumterm

Risk Category

Risk Factors

Transmission Channels and Financial Impacts

Risk and Opportunities Management

Risk of non-compliance with stricter regulations
under the European Union's Energy Performanceof Buildings Directive, as a number of buildings
owned by the Bank and in which it operates arecovered by the Directive.

BCP has been implementing
energyefficiency
SUSTAINABILITYREPORT
2023
measures, such as the installation of LED lighting, in all the geographies in which it operates,
as well as the installation of photovoltaic panelsin the Bank's buildings.

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, may be held liable.

The BCP Group commits its customers not touse credit funds for the actions included in theEnvironmental and Social Exclusion List of the
EBRD (European Bank for Reconstruction andDevelopment) and must hold all the necessary
environmental licenses related to their activities.

The increase in fuel price in Portugal may represent an increase in operating costs related totransport, the bank's fleet and the heating ofbuildings.
Transition

Regulatory& LegalRisk of increased settlement and litigation costs
as a result of the Bank's failure to mitigate andadapt to the impacts of climate change, as wellas to provide climate disclosures.

Increased investment costs resulting from thedevelopment and adoption of new technologies
with less impact on the climate and environment.
Technology

MarketReputation

Financial losses due to early obsolescence of existing assets/technologies.

BCP is renewing its fleet, replacing them withmore efficient vehicles with less environmental
impact, and at Bank Millennium, in most of the
fleet, the vehicles have been replaced by hybrid
models.
The Bank is committed to complying with thevarious legal requirements in the field of ESG issues and implementing the best available practices to identify and manage climate and environmental risks.
Pursuant to the ECB's expectations, the Bank isdeveloping a Group-wide Transition Plan thatwill set out the several measures to be taken by
the Bank to minimise the transition risks towhich it is exposed.
In addition, the Bank has a sectoral policy that
identifies the sectors that should be excluded
from the Bank's financing, as well as the conditional and sensitive sectors to which financing
restrictions should apply.
Since 2016, BCP has been investing in phases insolutions with less environmental impact,
namely: i) installation of LED lamps; (ii) installation of photovoltaic plants; (iii) replacement of
combustion vehicles with hybrid or electricmodels; and (iv) purchase of green energy. In
this way, the Bank has been gradually adapting
to the needs and requirements of a low-carbon
economy, reducing the risk of being left with obsolete assets and postponing the investment
necessary to meet current and future requirements, which are increasingly demanding.

The Bank's Customers are increasingly seeking
green products and services and the Bank's support for the financing of projects with environmental benefits (including benefits related to climate change mitigation and adaptation).

BCP is developing low-carbon products and services and has been financing several sustainable/green projects. For example, with the Decarbonisation and Circular Economy Line, andwith special emphasis on applications to support the decarbonisation of industry, the Bankis supporting the financing of projects to reduceenergy consumption or transition to a circular
economy.

At the same time, there is a market expectationthat financial institutions will start to assess the
ESG profile of Customers and give preference tothose that present a better performance, namely
those with lower levels of GHG emissions.

The Bank is developing internal processes forthe collection of ESG data that will impact risk
rating and credit decision.

BCP faces competitive risks posed by competitors and public opinion on the subject of climatechange, which may occur in reputation risks if
stakeholders understand that the Bank is not responding adequately to the management of climate-related risks.

BCP is committed to monitoring and implementing the best available ESG practices and totransparently disclosing the model for monitoring and managing climate-related financial risks.

183

In addition, the Bank has developed a Responsible Investment Charter that defines the concepts, general principles and guidelines to guide
ESG investing and the management of associated risks at Group level.

The Bank participates in recognized sustainability indexes, such as CDP, to improve its reputation in relation to climate change.

SUSTAINABILITY REPORT 2023
Risk Category

Risk Factors

Transmission Channels and Financial Impacts
If the Bank does not adopt measures to ensure
good performance in matters of climate transition and sustainability or does not disclose themin the most appropriate way, it may be harmed
by low ESG ratings.

Risk and Opportunities Management
In 2021, BCP launched, and updates annually,
the Responsible Finance Principles, which identify the sectors that should be excluded fromthe Bank's financing (e.g., oil and coal exploration and extraction), as well as the conditioned
sectors and sensitive sectors (identified as 'at
risk' in the C&E materiality analysis), for which
financing restrictions apply.
To clarify which operations and products are
considered 'green', and to define how new
green businesses should be identified and monitored, BCP has developed an internal taxonomy– BCP's Green Taxonomy. Thus, the Bank ensures transparency in the approach and criteria
used to manage and communicate goals related
to ESG or green businesses.

SevereExtreme weather events can cause structural
damage to the properties of the Bank's Customers and the infrastructure of the Bank itself andits employees.

To mitigate this risk, for example, BCP has aBusiness Continuity Plan and insurance coverage for assets in the event of natural disasters,
to ensure stability and resilience in the event ofincidents.

Higher temperatures can increase the demandfor energy for cooling in BCP's branches andbuildings, thus incurring higher operating costs.

To mitigate this risk, BCP is implementing energy
efficiency measures in its buildings, namely the
installation of photovoltaic panels.

Physical

Chronic

Impacts on BCP's Strategy and Business
The BCP Group identifies, evaluates, controls and reports information on climate-driven risks and opportunities considering that the risk factors presented above are transmission channels that impact the 'traditional' risk categories,
namely: credit, operational, liquidity, market, reputational and business. The most significant risk in the Bank's operations, and where transition and physical risks are most material, is in the credit risk category. Thus, actions in the Bank's
loan portfolio are key to achieving the Bank's strategic objectives of financing the transition to a low-carbon and climate-resilient economy.
All risk factors recognised and analysed by the Group may result, directly or indirectly, in financial impacts for the Group,
so it is essential that BCP adopts appropriate measures and changes its strategy and financial planning to manage theidentified impacts in the most efficient way. The following table presents some of the potential financial impacts associated with each of the risk categories and factors identified by the Group, as well as examples of measures implemented
by the Bank to manage these risks and opportunities.
In addition to the measures presented above, BCP continues to develop and plan other actions to better understand theexposure to risks related to climate change in its business, and to mitigate the respective impacts. In this regard, in 2023
the Bank: In this sense, in 2023 the Bank:− Actively participated in the European Central Bank's (ECB) climate stress tests exercise, the aim of which is to assessbanks' capacity in relation to climate risk and the industry's exposure to physical and transition risks;− Has developed and continues to develop actions to align its risk management processes, activities and models with
the ECB's expectations (according to the Thematic Review).
− Updated and developed new methodologies, more robust and aligned with the best available practices, to assessclimate and environmental risks;− Carried out the second exercise of assessing the materiality of climate and environmental risks, thus deepening theunderstanding of the impacts of these factors on the Group's activities;− Developed and operationalised its internal capacity for climate stress tests;− In line with the ECB's expectations, the Bank is developing a Group-wide Transition Plan;− Has published an internal policy, 'Principles of ESG control and management' (GR0047), which provides all the concepts, principles, and guidelines necessary to manage ESG factors in the most diverse areas of the Group, namely:i) definition of the group's sectoral policies; ii) integration of ESG drivers into the credit decisioning framework; iii)
methodology for stress-testing climate risk factors; iv) framework for ESG risk management.
− Has implemented and has planned to implement actions to bring BCP's actions closer to the ECB's expectations andthe European Banking Authority' s (EBA) guidelines on climate and environmental risks, in particular addressing thepriorities identified in the context of the ECB's Thematic Review;− Strengthened the process of in-depth and detailed assessment of the materiality of physical and transition risks in184

SUSTAINABILITY REPORT 2023−

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);
Continued to invest in the development of an IT platform that aggregates and integrates all ESG data, both internaland externally obtained (for example: obtained through customer engagement or via data providers), to respondto the varied business and reporting needs.

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 themin the transition to a low carbon economy and capturing opportunities related to climate and environmental change, inalignment with the European Union Taxonomy.

RISK MANAGEMENT
The BCP Group continuously monitors regulatory and supervisory requirements regarding ESG risk topics (including
those related to climate-related risks and opportunities) and complies with relevant regulations as well as supervisory
expectations.
The main process by which the Bank assesses the impact of climate-related risk factors on the Bank's risk profile is themateriality analysis of C&E factors. The exercise is carried out on an annual basis and makes it possible to: i) identify the
proportion of the Bank's portfolios that are sensitive to climatic factors; ii) assess which climatic risks are material for
the Group; iii) map the impacts determined in the "traditional" risk categories, according to the Bank's risk taxonomy;iv) identify opportunities for business improvement; and v) identify mitigation measures that should be adopted to reduce the Bank's exposure to these risks.
Following climate science, the use of different scenarios is particularly relevant to understand the sensitivity of businessstrategy to different climate and economic pathways. The methodologies developed within the scope of the C&E materiality analysis provide an assessment based on different perspectives of the evolution of C&E variables and their impacts
on economic and financial factors.
The most recent materiality analysis carried out by the Bank took place at the end of 2023, with data referring to theyear 2022, and integrated the Net-Zero 2050 scenario for the prediction of transition risk outcomes and the RCP 8.5
scenario for the prediction of physical risk outcomes. The risk factors analysed, the needs for improvement identified
and the mitigation measures resulting from this analysis are partially presented above, under the 'Strategy' section. For
more details on the assessment process, the integrated scenarios and the results obtained, please refer to the chapter'Climate and Environmental materiality assessment'.

Management Model
The governance model for risks arising from ESG factors follows a structure based on three lines of defence which, under
the leadership of the Board of Directors (and respective delegations on the Executive Committee), ensure its adequate
assessment and management:•
The first-line functions comprise all the departments and business areas that interact with the Bank’s customers, counterparties and suppliers, collect the information and data that support the assessment of their risk
profiles (and of their respective operations) and structure the commercial solutions with characteristics associated to ESG factors and to the promotion of control of their impacts on the Bank's risk profile.
•In the second line of defence, the responsibility for risk control is assumed by the Risk Office and by the Com-185

SUSTAINABILITY REPORT 2023

pliance Office. These functions ensure the procedures for the design, implementation of the policies/methodologies/ risk management models, which are paramount in keeping the risk profile of the Group in appropriate
levels.
•
The third line of defence is ensured by Internal Audit, which is responsible for independently reviewing theproper implementation and enforcement of the principles and processes related to ESG themes.
The Executive Committee is responsible for ensuring that ESG policies and strategies are followed, through the mobilization of resources and the execution of the necessary operational and business actions. The Sustainability Commission
assists the Executive Committee in the integration of sustainability principles into decision-making and management
processes and is responsible for evaluating and approving the initiatives of the Sustainability Master Plan, as well aschanges and adaptations to the initiatives that are necessary for its implementation, and its monitoring.
The Board of Directors is responsible for the Group's ESG strategy, including defining, approving, and overseeing theeffective implementation of the risk strategy and framework and its implementation agenda. Thus, the BoD is responsible for approving the following documents: i) ESG metrics defined in the Risk Appetite Statement; ii) Group Sustainability
Master Plan; iii) Principles and policies related to sustainability and ESG themes; iv) Annual Sustainability Report; (v) risk
disclosures for Pillar 3 purposes; (vi) portfolio alignment exercises and emissions targets; and (vii) the Transition Plan.

METRICS AND TARGETS
As part of its environmental commitment, BCP has set targets to reduce carbon emissions, namely, to reduce scope 1
and scope 2 GHG emissions by 15% in 2023, 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 monitors metrics related to climate change, namely its GHG emissions (Scope 1, 2 and 3), and presents its performance and evolution in the Environmental Responsibility chapter. Scope 3 emissions for the year 2023 were calculated
both upstream, associated with suppliers, and downstream, associated with the corporate loan portfolio. The methodologies for calculating these emissions have been improved compared to those of the previous year and are duly explained in the Report, in the chapter on Decarbonisation. 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.
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) is assigned an individual KPI related to the fulfilment of the implementation plan for monitoring climate and environmental risks.
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 own operations and also of thosederiving from its credit/investment portfolio. In this context, in 2023, without prejudice to any reassessment of the decision if circumstances require or oblige it, the Bank formalized its adherence to the Science Based Targets initiative(SBTi), a global initiative that allows companies to set emission reduction targets in line with science and the level ofdecarbonization necessary to meet the goals of the Paris Agreement. The Bank is working on the development of alignment metrics as per Pillar 3 requirements.

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Highlighted:
Renewable
Power
Production

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Renewable Energy Production
The energy efficiency and transition process and the reduction of GHG emissions attributable to Millennium bcp's operations, as anorganization, are commitments made to our Stakeholders. It is in this context that, alongside the consumption of electricity fromthe public grid with a guarantee of 100% renewable production, the reinforcement of investment in the installation of its own
sources of renewable energy production that contribute to improving the Bank's ecological footprint must be understood. tooptimize costs and increase your energy autonomy.
This is how Millennium bcp, in Portugal, has already installed 2 photovoltaic plants in Taguspark, with 1 MHw of power/each - thesecond of which has been in operation since December 2022 -, and is now studying the creation of a third production unit.
The availability of the 2nd photovoltaic plant made it possible to double the production of electricity for self-consumption. These
infrastructures now have an installed capacity that guarantees around 30% of the electricity consumption of the central service
buildings located in Taguspark, having also avoided, in 2023, the emission of 811 t of CO2.

Production Centers
Consumption Taguspark Buildings (Grid + PV)% self-consumption
CO2 emissions avoided

2021
1,043 MWh

2022
1,114 MWh2023
2,342 MWh

5,380 MWh

7,071 MWh

7,346 MWh

19.4%
376 tCO215.8%
401 tCO231.9%811 tCO2In 2023, the process of installing micro photovoltaic plants in several branches
also began, and three installations have already been completed - Charneca,
Albufeira and Santarém - out of a total of eight planned.
The performance of these plants, depending on the number of photovoltaic
panels that can be installed in each location, will determine a reduction in theenergy bill of between 10% and 30% of the branch. It is estimated that thesemicro plants have the capacity to avoid CO2 emissions in an amount ranging from4 t to 10 t, which corresponds to the average CO2 capture of 10 to 20 trees per
branch.
In Poland, where all electricity supplied by the public grid is also entirely from renewable sources and with a zero contribution to
the Greenhouse Gas Protocol's Scope 2 CO2 emissions (indirect GHG emissions from the consumption of energy, including electricity,used in the company's activities), Bank Millennium launched in January 2023 its first photovoltaic plant for the production ofelectricity for self-consumption, installed on the roof of the headquarters building in Gdansk, a unit capable of meeting more than
20% of local electricity consumption needs.
In Mozambique, at Millennium bim, the pilot phase of the "green" project is being developed and implemented, both in the Matola
Municipality branch and in the Maputo headquarters building, with a completion date scheduled for 2024.

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2nd photovoltaic plant - central services in Taguspark(Portugal)

Photovoltaic plant - central services in Gdansk(Poland)189

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ACTIVOBANK190

SUSTAINABILITY REPORT 2023

ACTIVOBANKThe ActivoBank, within the context of the BCP Group's Sustainability strategy andpolicies, has been developing a holistic approach that includes processes andoperations, the offer of solutions, products and services, and its positioning andpurpose within the framework of corporate social responsibility and financial
literacy.
The ActivoBank was the first paperless bank in Portugal, reflecting the priority
given, since its inception, to sustainability themes and issues.
Hence, in 2023, the Bank's position in supporting the community was maintained
and strengthened, with the allocation of funds for investments in areas of social and/or environmental action, with emphasison the protection of the Oceans and the fight against Cyberbullying.
Also in products and services, the offer in the area of sustainability was expanded, especially in the areas of credit,
investments and cards/transactions.
All the information is available on the Bank's institutional website, allowing for the integrated monitoring of the various
initiatives in the field of sustainability (Our blue is also green | Would you agree to join the change?) and where, through the
PROATIVO seal, the various aspects of the offer and activity with an impact on sustainability are signposted.
Click here to see the aggregator page of ActivoBank for Sustainability: https://www.activobank.pt/sustentabilidade
Sustainability Initiatives
Social benefit of products and services by line of business
The ActivoBank maintained its strategy of valuing and encouraging more sustainable choices, charging differentiated interest
rates on products that address environmental issues such as Credit + Energy, EcoActivo and Electric Cars.
The Training Credit remained in the Bank’s offer, with conditions adjusted to the financing of technical specialization courses,
bachelor's, postgraduate, master's, doctorate, Erasmus, exchange, executive masters and executive education, in Portugal
and abroad.
In June, the ActivoBank launched Crédito Saúde (Health Credit), and made this product available in its offer by financing
expenses of this nature with differentiated conditions.
The ActivoBank's Investment Fund Offer includes products classified as articles 8 and 9 of the Sustainable Finance Disclosure
Regulation (SFDR) that promote or have as their main focus environmental or social objectives (please see section "SFDR",
in the chapter "Introduction").
Environmental benefit of products and services by line of business
The year 2023 is marked by the availability on ActivoBank's website and App of the entire offer of Term Deposit and Savings
products, which translated into around 95% of the amounts constituted through automatic channels.
This challenge of launching "digital journeys" was also extended to other financial products, namely with the launch of Easy
Invest, an automated investment in Open Linked Units, and Public Subscription Operations.
As for the most current day-to-day movements, to provide a new account opening option to the Customer without going to
the Active Points, the Digital Mobile Key Account Opening was launched.
In 2023, 3,494 AB Plans were contracted, using the digital contracting process, thus avoiding the printing and sending of
documents.
Also in 2023, Customers became able to make overlimit SEPA Transfers (including immediate and urgent ones) throughDigital Channels (website and App). With this development, the circuit that existed until then was changed, that is, there is
now a new method of authentication of the operation that allows transfers with an amount higher than the maximum per

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SUSTAINABILITY REPORT 2023

Customer defined daily by the Bank.
The integration of the authorized payments feature in the ActivoBank App also allowed Customers to automatically authorize
subscriptions or regular purchases with just one "click".
This new possibility has brought several advantages to the Customer, of which the following stand out:▪
the customer does not need to authorise payments individually, avoiding multiple "clicks";▪
allows having an aggregated view of all subscriptions in the ActivoBank App - improving the user experience in termsof expense control;▪
receive notices, such as those regarding subscription renewals;▪
be able to establish and/or edit the limits, and their timeframe, to be debited.
The Bank also launched the digital cards. These ActivoBank Cards are a replica of the physical Cards, and are immediately
available in the App and can be used right after being contracted, with obvious advantages, such as:
▪
▪
▪
▪
▪

consult the Card’s data, namely the CVV;
manage the intended transactions;
make online payments and transfers (only Debit Cards allow you to make payments and transfers, Credit and Prepaid
Cards only allow you to make payments);
use MB Way, for example, to make withdrawals, since it is automatically associated, and also create MB NET Cards;
associate with Apple, Android, SwatchPAY, Fitbit, and Garmin devices.

Also in the Cards, since the end of 2023, we have integrated the envelopes for sending physical AB Gold Credit Cards in kraft
paper.
Preferential financial conditions were made available for the credit purchase of more efficient windows/doors, throughpartnerships aimed at improving the energy efficiency of homes.
The domiciliation and the contracting of the salary advance were made available in the App, in a fully digital process,facilitating the request of Customers.
Launching of ESG products and/or Services
The availability of the digital contracting of the ECOActivo Credit in the App allowed simpler access to a product whose
purpose is to support Customers in choices aimed at improving the energy efficiency of their homes and environmentallyfriendly mobility.
Customers with a domiciled salary have access to sustainable mobility products under advantageous conditions, available ina showcase of articles - checklist.
In Investments, considering the Sustainable Finance Disclosure Regulation (SFDR), we have 73% of our portfolio ofInvestment Funds classified as articles 8 and 9, with an increase compared to last year (55% in the number of subscribed
Funds), which allows us to guarantee and provide Clients with a very comprehensive offer of Funds that promote
environmental and/or social sustainability or whose investment objective is exclusively sustainable.
Initiatives to improve the financial literacy of the community
Within the scope of Financial Literacy, we ensured a set of contents, which were made available in ActivoBank's digitalcommunication channels - Facebook, Youtube, Instagram, LinkedIn and TikTok. These contents were produced anddisseminated as conferences, podcasts or informative videos and images.
A partnership was also established with Observador, in which financial literacy content on Investments for branded content
publications was worked on.
Due to the scope of the platforms used, this content is available to Customers and non-Customers.

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In relation to digital literacy, we ensured a set of contents - informative videos and images - which were made available in
ActivoBank’s digital communication channels - Instagram and LinkedIn.

Involvement with the local community
During 2023, ActivoBank developed 12 social solidarity actions through its monthly item "Dar Créditos", associating a Projector Social Cause that was supported with an amount of up to 2,000 euros per month.
The amount donated was determined through a Solidarity Campaign, which consists of raising funds associated with thesubscription/contracting of ActivoBank products or services. In addition to the monetary contribution, visibility was also given
throughout the year on ActivoBank's digital media – Instagram page –, on the website and in the App to each Institution anda few months later a visit and interview was made to understand how this donation was used, which is very relevant, since
it allows to promote the importance of these institutions to the community and raise new support, or volunteers.

Supported projects:

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SUSTAINABILITY REPORT 2023

Month/
Institution
January- Participation of
Diogo Matos inthe Virtus GlobalGames

On the Cause

Contribution

Diogo is a high-performance adapted swimming athlete since
2014/2015, who started his sporting career at the age of 15 innational and international competitions and has been an
example of resilience and strength.

ActivoBank donated 1,935 euros
to contribute to Diogo Matos'
participation in the Virtus Global
Games in Vichy, a very importantmilestone in his sporting career.

February- CASA

CASA's mission is to help those who are homeless, who arepart of families at risk or families in need, through social
solidarity actions, providing close contact, food, clothing andsocial reintegration services.
Casa dos Rapazes is a centennial Private Institution of Social
Solidarity (IPSS) with a social response of a home for children
and youth, which welcomes children and young boys between
6 and 18 years of age who had to leave their family
environment for various reasons, which put them in danger.

ActivoBank donated 2,000 euros
to contribute to the new lodging
centre for CASA in Lisbon.

March- Casa dos Rapazes

April- AFIDMay- Limites Invisíveis
(Invisible Limits)

June- Pedalar sem
idade(Cycling
without age)

July
- Liga Proteção daNatureza(Association for
the Protection of
Nature)August- Rosa Vida
September- APPACDM Porto

October- Matiz

It is an IPSS, which is dedicated to initiatives of Rehabilitation,
Education, Training and Socio-professional Integration ofpeople with disabilities. It also develops a set of community
support activities and proximity services in the fields of social
assistance and solidarity, support for children and the elderly.
Currently, it provides support to more than 1.500 individuals.
Since 2015, the Invisible Limits Project has been developing
educational programs in nature with children from 3 to 10
years old, recognizing the benefits of this type of program,namely in terms of children's health and well-being, thedevelopment of socio-emotional, cognitive and motor skills
and the change in sedentary behaviour patterns.
It was in Porto, in 2018, that this non-profit movement
achieved the goal of joining the international Cycling Without
Age movement, with the arrival of the first bicycle in Portugal.
In partnership with the Bonfim Parish Council, they carry out
urban tours, on electric bicycles, with the support of their teamof volunteers (trishaw riders), who are dedicated to helping
the elderly and people with reduced mobility in theircommunities.
The LPN is a national Environmental Non-Governmental
Organization (NGO), founded in 1948, being the oldest
environmental protection association in the Iberian Peninsula.
It is a non-profit association with Public Utility status, whose
main objectives are the defence of the environment andcontribute to the conservation of the natural heritage, thediversity of species and ecosystems.
Rosa Vida is a non-profit association that promotes the
improvement of the quality of life of cancer patients.
The APPACDM do Porto - Portuguese Association of Parents
and Friends of the Mentally Handicapped Citizen is a non-profit
association, of social solidarity and voluntary initiative of
individuals, which supports people with developmental delay,
intellectual disability or disability, of all ages. Its area ofintervention extends to the entire city of Porto, where it was
created in 1969.
Matiz is an IPSS that aims to improve some aspects in the fieldof mental health care in the region of Trás-os-Montes, with a
special focus on the municipality of Mirandela, aiming tofacilitate access to it to the entire population, in an equitable
way at all stages of life.

194

ActivoBank has donated 2,000
euros so that Casa dos Rapazes
can continue to provide social
assistance to children and young
people between 6 and 18 years
old.
ActivoBank donated 1,038 euros
tocontribute
toAFID'sRehabilitation,
Education,
Training and Socio-professional
Integration
initiatives.
ActivoBank donated 2,000 euros
to contribute to the educational
programs of the Invisible Limits
Project.

ActivoBank donated 2,000 euros
to help more seniors enjoy urban
tours.

ActivoBank donated 470 euros tocontribute to the conservation of
the Natural Heritage, the diversityof species and ecosystems.

ActivoBank donated 2,000 euros
to Rosa Vida to help improve thequality of life of cancer patients.
ActivoBank donated 1,950 euros
to contribute so that APPACDM
Porto continues to support andempower People with Intellectual
Disabilities or Disability to achievea better quality of life.
ActivoBank donated 2,000 euros
to help with the purchase of a carso that Matiz can carry out home
support actions.

SUSTAINABILITY REPORT 2023

November- SaMaNe

SaMaNe is an Association that works on issues of structural
racism experienced by black and racialized mothers in Portugal
during pregnancy, childbirth and post-partum and supports
new mothers in matters of mental health and baby care.

December- CASA

CASA's mission is to help all those who are homeless.

ActivoBank donated 1,512 euros
to help SaMaNe in its mission to
supportmothers
duringpregnancy,
childbirthandpostpartum.
ActivoBank donated 20,000 euros
to support Casa in the distributionof about 4,000 meals.

In addition to the monthly support given to these social causes, during 2023 the Bank continued the support, which had
begun in 2022, to the causes of Marine Reforestation and the fight against Cyberbullying. In the Protection of the Oceanswith Ocean Alive and in the cause of combating Cyberbullying with No Bully Portugal.
These partnerships are in line with the Bank's current support and Sponsorship policy, which is 100% focused onsustainability-related causes.
Protection of Seagrass Meadows and Partnership with Ocean Alive
Since Seagrass Meadows are marine ecosystems with avery important role on the Planet, as they are carbon sinks
and habitat for several species of fish, crustaceans andbivalves, Activobank, aware of the vital importance of the
Oceans and the active contribution to their preservation,
has joined Ocean Alive, the first cooperative dedicated tothe protection of Seagrass Meadows in Portugal.
This partnership with ActivoBank in the environmental
area, which took place in 2022 and 2023, supported thepreservation of the Ferry Base Seagrass Meadow, in Tróia,
contributing to the achievement of two objectives: i) tocreate scientific knowledge to support prairie restoration
actions; (ii) encourage good practices in vessel behaviour.
In the course of the various phases of the project,significant developments have been made that have madeit possible to move from a meadow without a name,dimension and in which the state of conservation andbiodiversity totally unknown, to the full knowledge of the Meadow Base Ferry.
During the project it was possible to map it, to make a survey of the biodiversity and of the areas that were degraded. Afterthese surveys, a restoration plan was carried out that will be completed in March 2024 and will leave the entire area of the
Seagrass Meadow in a good state of conservation.
In addition to the scientific work, there were also awareness-raising activities aimed at structuring navigation in the Meadow
area. In 2023, two volunteering activities were carried out that allowed ActivoBank Customers and Employees to be involvedin these actions to raise awareness among the local community about the importance of the Seagrass Meadows and the care
to be taken in the preservation of these habitats.
The volunteering actions, which took place on the last weekend of July, totalled 12 hours of activity in the field, with theparticipation of about 16 volunteers. In total, 124 people and 33 boats participated.

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SUSTAINABILITY REPORT 2023

Also on social networks, several information about the Base Ferry Prairie Preservation project were disseminated, in orderto spread information and raise awareness among as many people as possible:

Cyberbullying and No Bully Portugal
During 2023, one of the main actions of the partnership with No Bully Portugal (supported by the Bank in 2022/2023) was
put into practice - the training of volunteers (ActivoBank Employees and University Students), so that they would be able tocarry out training actions in Primary and Secondary Schools and Universities. Between March and May, weekly grouppreparation sessions were held, with the transfer of theoretical knowledge and practical group activities to promote the fightagainst Cyberbullyng.
After the training stage, five awareness-raising sessions were held (in the areas of Porto and Lisbon) at the Campanhã School,the Águas Santas Primary and Secondary School, the Passos Manuel Primary and Secondary School and the Universidade
Nova of Lisbon.

196

SUSTAINABILITY REPORT 2023

Prizes and awards
ActivoBank was elected Powerful Brand in the Online Banking category in Portugal for the second consecutive year.
This distinction is gaining more and more notoriety, despite being an award that is only two years old, as the sustainabilityof brands is also increasingly measured by the opinion and trust that consumers place in them.
The Powerful Brand award is based on a tool that, through Marktest's market studies, measures the value of brands, basedon Key Performance Indicators (KPI), analysed in the dimensions of Innovation, Sustainability, Ethics and Brand Purpose, andActivoBank stood out in all indicators in the Online Banking category.
It was also distinguished, for the fifth consecutive time, with the "Consumer's Choice" award, in the "Digital Banking"category, with a Satisfaction Score of 89.6% and a Recommendation Score of 89.4%. The independent evaluations, which
are the result of consumer opinions, have once again highlighted the Bank's recognition among the public.
Security, transparency, ease of use, simplicity and interactivity, reduced rates/fees, trust in the brand, ease of opening an
Account and completeness of the ActivoBank App were the most valued attributes. ActivoBank achieved the best score in all
the satisfaction attributes evaluated.
In the second edition of the best Bank study, ActivoBank was once again the leader in 2023. ActivoBank secured 1st place inthe following categories: Customer Satisfaction, Current Accounts and Personal Credit, which ensured an overall quality of
72%, the highest compared to the competition.

Communication and Training
In the field of Ecology, in 2023 we joined photojournalist Daniel Rodrigues on his
adventure to travel the African continent by electric bicycle.
This action aimed to raise awareness of Climate Change, demonstrating that if it ispossible to cross Africa by bicycle, given the difficulties that are expected on thisContinent, it is also possible for each of us to adopt more sustainable habits in our daily
lives and exchange the usual means of transport for the electric bicycle.
This action was associated with the ECOActivo Personal Credit product, in which one ofthe purposes is the acquisition of electric bicycles.
In the course of 2023, ActivoBank played an important role in Social Activism, marking anniversaries with its positioning
regarding structuring causes for society:▪

Publication on Social Networks to mark Women's Day and raise awareness of gender inequalities;▪

Publication on Social Networks to mark Father's Day and to alert to different types of families;

197

SUSTAINABILITY REPORT 2023▪

Publication of Women's Empowerment related to the approach of women to financial issues.

Creativism Contest
Creativism was born from ActivoBank's desire to get closer to the causes it defends through the artistic interpretation ofyoung Portuguese talents. For that purpose, the Brand has launched, on its networks, a contest for the creation of sketchesof murals on the themes of Ocean Protection, Women's Empowerment and combating Cyberbullying.
The winners were the sketches by the artistic duo C'marie and Egrito and the graphic designer Joana Fatela, the sketches
portrayed the themes of Women's Empowerment and Protection of the Oceans, respectively.

198

SUSTAINABILITY REPORT 2023

ESG bonds

199

SUSTAINABILITY REPORT 2023

ESG Bonds
Allocation and Impact Report200

SUSTAINABILITY REPORT 2023

Index
1.

Green, Social and Sustainability Bond Framework .................................................................202

2.

Millennium bcp - Inaugural ESG Bond Issuance ......................................................................204
2.1.

Transaction’s features .....................................................................................................204

2.2.

Use of Proceeds...............................................................................................................204

2.2.1

Allocation Report.....................................................................................................204

2.2.2

External Verification of the Allocation Report ........................................................206

2.3

Impact..............................................................................................................................209

2.3.1

Impact Report..........................................................................................................209

201

SUSTAINABILITY REPORT 2023

1. Green, Social and Sustainability Bond Framework
Since 2021, Banco Comercial Português, S.A. (“BCP”, “Millennium bcp” or “Bank”) has established its Framework for issuing ESG Bonds, which represents an important and crucial tool in the integration of sustainability
into its products and financial services, with a view to redirecting funds to finance a more sustainable society.
The Framework is aligned with the four principles defined by the International Capital Markets Association(“ICMA”) for ESG bond issuance as presented below and relies on relevant eligibility criteria for loans to befinanced or refinanced in the Green and Social categories using the proceeds of the executed bond issues.
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 the issuance of BCP’s
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 ICMA 18(“ICMA Principles”):
1.
2.
3.
4.

Use of Proceeds;
Process for Project Evaluation and Selection;
Management of Proceeds;
Reporting.

Through the issuance of ESG Bonds, the Bank can access to one of the most important segments of the capital
markets and make possible to significantly reinforce its commitments and efforts in relation to sustainability.
In fact, this is an important tool to further integrate ESG matters within the Bank’s commercial 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/or Sustainability Bonds under different instruments (from
Additional Tier I to senior preferred debt, also including covered bonds 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 a positive
impact and follows the ICMA Principles.
As a result, the defined eligibility criteria and the expected impacts that should lead to important and positiveenvironmental 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.

As part of the Framework update, Millennium bcp undertakes to publicly disclose, on an annual basis, until
maturity of the exposures financed by the funds resulting from each ESG Bonds issuance:-

An Allocation Report that specifies:o How funds raised through ESG Bond issuances were applied;o Show the total amount of ESG Bonds issued;o Show the amount of proceeds allocated to each portfolio by eligible category;o Total amount of unallocated proceeds;o The percentage of proceeds aligned with the Substantial Contribution Criteria of the European Taxonomy;

18 ICMA’s https://www.icmagroup.org/green-social-and-sustainability-bonds/

202

SUSTAINABILITY REPORT 2023

o Any other information that the Bank considers relevant.
In relation to this report, an external verification of the allocation process will be carried out, inorder to validate compliance with the principles established in the Framework;-

The Impact Report should specify and quantify the environmental and/or social benefits of the ESG
Bonds. The Report must include, subject to the availability of information, an estimate of results andimpact indicators, as provided for in the Framework.

The proceeds of any ESG Bonds issued by Millennium bcp will be allocated exclusively to the Eligible Assets,in accordance with the Framework, defined in the list of Eligible Green or Social Categories, aligned to the
ICMA Principles.

203

SUSTAINABILITY REPORT 2023

2. Millennium bcp - Inaugural ESG Bond Issuance2.1. Transaction’s features
In October 2021, Millennium bcp carried out its inaugural issue of ESG Bonds, through the issuance of senior preferred bonds with Social label, which was the first transaction, exclusively of this category, executedby a Portuguese bank. Below are listed its main features:

Issuer:ISIN:
Issue Ratings (31 dezembro 2023):
Amount:Issue Date:
Maturity Date:
Call Option Date:
Coupon:Use of Proceeds:

Banco Comercial Português, S.A.
PTBCPEOM0069
Baa2 (Moody’s) BBB- (Fitch) /BBB (DBRS)€ 500M
7 October 2021
7 April 2028
7 April 2027 subject to the prior approval of the Relevant Authority
1,75% p.a., until Call Option Date, then E3m Euribor + 2,00%
An amount equivalent to the net proceeds of the Notes was used to refinance Eligible Social Assets as defined in the Framework.

For the future, and subject to prevailing market conditions, the Bank intends to continue to integrate theissuance of ESG Bonds into its Funding Plan in the capital market, namely with regard to the issuance of Senior Preferred debt.

2.2. Use of Proceeds
The Bank issues an annual report on the use of proceeds the ESG Bonds issued.

2.2.1 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 Clients;▪

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.

Millennium bcp fully allocated the proceeds from its inaugural issue of ESG Social Bonds, in the amount of€500M, to refinance part -higher than the amount issued, in order to accommodate the natural and early
amortizations of the Bonds - of its portfolio of loans granted, and partially guaranteed by the State, to support
the economy during the pandemic Covid-19 (“Covid-19 Lines”).

204

SUSTAINABILITY REPORT 2023

As of December 31, 2023, the portfolio consists of a total outstanding of around €904M and an average maturity of 2.4 years19.
In the selection process, sectors such as nuclear, mining, alcohol, tobacco, gambling and those dedicated tofossil fuels were excluded.

19 Average Maturity is calculated as the remaining term to maturity, weighted by the outstanding amount of the loan.

205

SUSTAINABILITY REPORT 2023

2.2.2 External Verification of the Allocation Report

206

SUSTAINABILITY REPORT 2023

207

SUSTAINABILITY REPORT 2023

208

SUSTAINABILITY REPORT 2023

2.3 Impact
Annually, in accordance with the Framework, BCP issues a report on the environmental and/or social benefitsof 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▪

€904 mio of financing under “Covid-19 lines”.

▪

More than 12.800 companies supported.

▪

Over 215.000 jobs impacted20.

As of December 31, 2023, the portfolio allocated to the issuance of ESG-Social Bonds includes a very diversified base of more than 12.800 Millennium bcp customers affected by the pandemic crisis, mostly micro andsmall and medium-sized companies. There is a natural concentration in the Lisbon and Porto regions and in
the manufacturing and wholesale and retail trade sectors.
We conclude that this financial support was crucial for the Portuguese economy and for the business sector,
since, in a difficult time, it contributed decisively to the beneficiary companies having the liquidity to maintaintheir activity, consequently preserving jobs.

Industry Distribution (NACE)

Geographic Distribution (Nuts III)

20 Number of jobs corresponds to the number of workers reported by each client. For those few cases where there was no information

reported, it was assumed to be 1.

209

SUSTAINABILITY REPORT 2023

Sustainability
Indexes210

SUSTAINABILITY REPORT 2023

Recognition - Sustainability Indexes
Material issue:

BANK'S REPUTATION

In 2023, the BCP Group was listed in several Sustainability indexes.
In order to promote transparency in the communication with our Stakeholders, monitor the evolution of the Sustainability
performance, identifying opportunities for improvement, and communicate the evaluation carried out by recognised
external entities, we respond to various specialised indices.
As a result of the evaluation carried out by the analyst Standard Ethics, Brupo BCP is part of the "European Banks Index",
having also been part of the "Europe's Climate Leaders 2023" ranking of the Financial Times and Statista, in Portugal and
Poland, as one of the European companies with the greatest progress in reducing GHG emissions. It is also part, among the
26 "STOXX Indices" of which it is a member, the "EURO STOXX Banks ESG-X", the "STOXX Europe 600 Banks ESG-X", the"EURO STOXX Total Market ESG-X" and the "STOXX Developed Markets Total Market ESG-X".
In Portugal, in 2023, Global Finance magazine once again distinguished Millennium bcp as the "Best Bank for Sustainable
Finance".
In its most recent assessments, the analyst Sustainalytics assigns a score of 19.7 (Low Risk) to BCP Group's ESG performance,
ISS a rating of "C-", while MCSI rates it with a rating of "A" and S&P's CSA with a rating of 56%, which corresponds to apercentile of 89 in the financial/peer group sector. EthiFinance (formerly Gaia Rating) gives it a rating of 70%, LSEG (formerly
Refinitiv) 74% and Vigeo Eiris an overall rating of 46% (which reaches 88% in assessing the quality and scope of reporting
practices).
In Poland, Bank Millennium was once again included in the Warsaw Stock Exchange's "WIG-ESG" index, in recognition of its
work in the environmental, social, economic and corporate governance dimensions.
In the 2023 edition of the CDP - Carbon Disclosure Project, the BCP Group remained, as in 2021 and 2022, in the"Management" band, with a "B" rating, after having been in the "Leadership" band in 2020 and obtained an "A-" rating.
The BCP Group is also for CDP, based on the "Supplier Engagement Rating" (SER), in this case in the 2022 edition, one of theleaders in involvement with Suppliers in Sustainability matters, having integrated, in 2023, the "Supplier Engagement Rating
Leaderboard" ranking. This distinction highlights the companies that have made the most progress in engaging their supply
chain.
BCP Group, 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%, above the 80.76% in 2022, 78.11% in 2021 and 77.79% in 2020, remaining in thegroup of companies that worldwide stand out in the implementation of gender equality, diversity and inclusion practices andpolicies.

Index/analyst

2023

MSCI (*)

2022

A

=

A

CSA S&P (formerly DJSI)

56%



62%

Carbon Disclosure Project (Climate)

B

=

B

Carbon Disclosure Project (SER)

B



A

Bloomberg Gender-Equality Index

85.3%



80.7%

Vigeo Eiris

46% (88% disclosure)=46% (88% disclosure)

EthiFinance (formerly Gaïa Rating)

70%

=

70%

LSEG (formerly Refinitiv)

74%



78%

Sustainalytics

19.7



21.6

ISS ESG

C-



D+

211

SUSTAINABILITY REPORT 2023

(examples)(*) 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.

212

SUSTAINABILITY REPORT 2023

Methodological
Notes

213

SUSTAINABILITY REPORT 2023

Environmental Indicators
GRI 301-1
The figures presented in 2023 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 andon the standard weight of a card.
Consumption of ink and toner cartridges – Total estimated based on the purchase of these materials. In Portugal, thevalues reported include ink and toner cartridges used by the Bank through Xerox.

••

GRI 302-1
The figures presented in 2023 include the operations in Portugal, Poland and Mozambique.
•
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 atwww.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

0.048 GJ/m3-

LPG

47.30 Gj/ton

0.520 ton/m3

Diesel43.00 Gj/ton

0.840 ton/m3

44.30 Gj/ton

0.750 ton/m3

1000 Litre = 1m3-

Litres - TJ

(litres/1000)*43.00*0.840

DieselLitres - TJ

(litres/1000)*44.30*0.745

PetrolLitres - TJ

(litres/1000*47.30*0.520

LPG

M3 -Tj((m3)*0.048)/1000

Natural Gas

PetrolLitres - M

3Electricity
1 kWh

3.60 MJ/kWh

GRI 303-3
The figures presented include the operations in Portugal, Poland and Mozambique. 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 2023 to 5.08€/m3.

214

SUSTAINABILITY REPORT 2023

GRI 305-1 to 305-3
The figures presented include the operations in Portugal, Poland and Mozambique. The emission factors used were the following:

Portugal
Energy and Total Heat Without disaggregation(CO2/ kWh)

Fator – 2020

Fator – 2021

Fator – 2022

Fator – 2023

0.19237 kgCO2/kWh
Source: Total– EDP Comercial

0.00000 kgCO2/kWh
Source: Total– EDP Comercial--

0.00000 kgCO2/kWh
Source: Total– EDP Comercial
0.137 kgCO2/kWh
Source: APREN

0.0000 kgCO2/kWh
Source: Total– EDP Comercial
0.137 kgCO2/kWh
Source: APREN

0.6402 kgCO2/kwh

0.6402 kgCO2/kwh

0.6402 kgCO2/kwh

0.6402 kgCO2/kwh

-

-

-

0.096 kgCO2/ kWh
Source: ADEME

-

-

-

Location-based
PolandHeat (CO2/ kWh)Mozambique
Energy and Total Heat Without disaggregation(CO2/ kWh)
Location-based:

0.096 KgCO2/ kW
Source: ADEME

For more information on the emission factors used to calculate emissions associated with Polish operations, see the ESG
report of Bank Millennium and the Bank Millennium Group for 2023.
Emission factors - Fuel (source: GHG Protocol)
CO269310.6 Kg/TJ

CH4

25.0 Kg/TJ

N2O

8.0 Kg/TJ

CO2

74110.6 Kg/TJ

CH4

3.9 Kg/TJ

PetrolDiesel

N2O

3.9 Kg/TJ

CO263105.1 Kg/TJ

CH462.0 Kg/TJ

LPG

N2O

0.2 Kg/TJ

CO256105.1 Kg/TJ

CH4

1.2 Kg/TJ

N2O

2.3 Kg/TJ

Natural Gas

Emission Factors – Travels

Emission Source

Unit

WTT PetrolL
WTT DieselL
WTT LPG
Bus travel
Taxi travelLpassenger.km
km

Air travel
passenger.km
Rail travel
Private carpassenger.km
km

SourceDEFRA 2022, Folha WTT - Fuels -> Liquid Fuels -> Petrol (average biofuel
blend)
DEFRA 2022, Folha WTT - Fuels -> Liquid Fuels -> Diesel (average biofuel
blend)
DEFRA 2022, Folha WTT - Fuels -> Gaseous Fuels -> LPG
DEFRA 2022, Folha Business travelland -> Bus -> Coach
DEFRA 2022, Folha Business travelland -> Taxi -> Regular Taxi (km)DEFRA 2022, Folha Business travel-air > International -> Average Passenger > With RF
DEFRA 2022, Folha Business travelland -> Rail -> National RailDEFRA 2022, Folha Business travelland -> Car -> Average Car -> unknown

215

Emission Factor
2022 CO2e

Emission Factor
2022 CO2;
AR4=AR5

Emission Factor 2022 CH4,
AR5

Emission Factor 2022 N2O,
AR5

0.613280.61328--0.609860.60986--0.183830.18383--

0.027271401

0.026780.000011200

0.000480201

0.208056449

0.206380.000004637

0.001671812

0.183520428

0.18270.000011200

0.000809228

0.035462964

0.03510.000078400

0.000284564

0.170568588

0.16940.000190400

0.000978188

SUSTAINABILITY REPORT 2023

Emissions – Suppliers
In comparison to the previous year, there was a substantial improvement in the quality of data regarding suppliers’ emissions. Not only is the scope of suppliers significantly expanded (around 15% of the billing to the bank) for which reported
emissions data were retrieved, but also, in estimated emissions, the sources of information provide more accurate data,
and are less reliant on sectoral estimates.
Two approaches were developed to assess BCP’s Scope 3 emissions: i) supplier-specific; and ii) spend-based. The former
was established as the preferred approach, whereas the latter was only taken into consideration when not enough data
was available to apply the first one. Both methodologies are briefly described below.
The supplier-specific approach covers close to 80% of the billing to the bank, and almost half of the suppliers, while thespend-based approach, the most conservative one, accounts for the remaining 20% of the billing to the bank.

Supplier-specificSupplier’s emissions imputed to the Bank (upstream scope 3 emissions) were calculated taking into consideration the
suppliers’ reported or estimated emissions (scope 1, 2 and 3) along with the billing to the Bank (VAT, measured in €), andthe suppliers’ total production (revenues in €). Real emissions (i.e., emissions in companies’ own reports) were used whenavailable. Otherwise, emissions were estimated using Moody’s data sources. For each Bank’s supplier (i), the imputed
emissions to the Bank are calculated as follows:

𝑈𝑝𝑠𝑡𝑟𝑒𝑎𝑚 𝑠𝑐𝑜𝑝𝑒 3 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 = (𝑆𝑐𝑜𝑝𝑒 1𝑖 + 𝑆𝑐𝑜𝑝𝑒 2𝑖 + 𝑆𝑐𝑜𝑝𝑒 3𝑖 ) ×

𝐵𝑖𝑙𝑙𝑖𝑛𝑔 𝑡𝑜 𝑡ℎ𝑒 𝐵𝑎𝑛𝑘
𝑇𝑜𝑡𝑎𝑙 𝑅𝑒𝑣𝑒𝑛𝑢𝑒𝑠𝑖

Spend-based
Whenever data was not available to apply the supplier-specific approach, the spend-based method was used.
For this method, ADEME sectoral emissions factors, attributed to each supplier according to its activity sector, along withthe billing to the Bank were considered. For each Bank’s supplier (i), the imputed emissions to the Bank are calculated asfollows:

𝑈𝑝𝑠𝑡𝑟𝑒𝑎𝑚 𝑠𝑐𝑜𝑝𝑒 3 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 = 𝐵𝑖𝑙𝑙𝑖𝑛𝑔 𝑡𝑜 𝑡ℎ𝑒 𝐵𝑎𝑛𝑘 × 𝑆𝑒𝑐𝑡𝑜𝑟𝑎𝑙 𝑒𝑚𝑖𝑠𝑖𝑠𝑜𝑛 𝑓𝑎𝑐𝑡𝑜𝑟𝑖216

SUSTAINABILITY REPORT 2023

External
Auditor’s
Report217

SUSTAINABILITY REPORT 2023

218

SUSTAINABILITY REPORT 2023

219

SUSTAINABILITY REPORT 2023

220

SUSTAINABILITY REPORT 2023

Annexes221

SUSTAINABILITY REPORT 2023

GRI table - Global Reporting Initiative

Information sources:
AR – 2023 Annual Report
SR – 2023 Sustainability Report

Declaration of use

Banco Comercial Português S.A. reported in accordance with the GRI Standards for the period from
1 January 2023 to 31 December 2023.

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'.

GRI STANDARDS

UNGC
Principles

Content, page or link

ORGANISATION AND REPORTING PRACTICES
2-1

2-2

2-3
2-4
2-5

Organization details
Entities included in
the organization's
sustainability report
Reporting period,
frequency and contact point
Reformulations of
information
External Verification

SR 23 | Economic and Governance Responsibility
SR 23 | Terms and Conditions
AR23 | Regulatory information > Consolidated financial statements
SR 23 | Introduction > Sustainability Report
SR 23 | Terms and Conditions
SR 23 | Introduction > Sustainability Report
SR 23 | External Auditors’ Report
Corporate Governance Report > Section V - External Auditor

ACTIVITIES AND WORKERS
SR 23 | Summary of Indicators
2-6

Activities, value
chain and other usiness relationships

SR 23 | Economic and Governance Accountability > Products and Services
SR 23 | Economic and Governance Accountability > Suppliers
SR 23 | Introduction > Sustainability Report
SR 23 | Methodology Note

2-7

Employees

2-8Workers who are
not employees

SR 23 | Summary of Indicators
SR 23 | Economic Responsibility and of Governance >Employees
In 2023, the Group employed 2,943 outsourced workers and trainees.

GOVERNANCE
2-9

2-10

2-11

2-12

Governance structure and its composition
Appointment andselection for thehighest governancebody
Chairperson of thehighest governancebody
Role played by thehighest governancebody

Governance structure and its composition > Section II - Part B. Corporate bodies and Committees

Corporate Governance Report > Item 16 and 17.1

Corporate Governance Report > Items 4 and 5 and Item 17

Corporate Governance Report > Items 15, 17, 18 and 21-Board of Directors

222

SUSTAINABILITY REPORT 2023

GRI STANDARDS

UNGC
Principles

Content, page or link
The management of impacts in sustainability is carried out by the Executive Committee
within the scope of the Bank's day-to-day management. Its monitoring is carried out by theCommittee for Corporate Governance, Ethics and Sustainability and by the Committee for
Risk Assessment, in the area of monitoring climate and environmental risk management.

2-13

Delegation of impact responsibility

2-14Role played by thehighest governancebody in Sustainability Reporting

With the objective of promoting a better articulation of current management decisions, involving the top management of the units integrated in each of the Business Areas, regarding Sustainability issues, the Executive Committee appointed a Sustainability Commission
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 Governance),in accordance with the guidelines of the Plan approved by Board of Directors. This Commission needs a minimum quorum for decision of at least two executive directors.

SR 23 | Introduction > Governance Model
The Bank has a Code of Conduct of the BCP Group that imperatively establishes that themembers 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 thatthey can act with full independence of mind, impartiality and exemption and that the members of the management and supervisory bodies cannot intervene in the appreciation anddecision of operations, or contracts for the acquisition or provision of services related withcompanies or persons in relation to which there is the risk of occurrence of conflicts of interest.

2-15

Conflicts of interest

Additionally, the Bank also has a Policy for the Prevention and Management of Conflicts ofInterest (Group Code GR0038), which defines the fundamental principles and processes
adopted for the identification and management of conflicts of interest occurring within theGroup. GR0038 also formalises the governance principles applicable to the provision of investment and ancillary services and activities identified.
The Bank's Articles of Association establish that the Board of Directors appoints a specialised Committee, called the Committee for Corporate Governance, Ethics and Sustainability,
to which it attributes, among others, the power to assess the systems for identification andresolution of conflicts of interests. The Audit Committee also has powers related to the
management of conflicts of interest, within the scope of which it issues a prior opinion to
the Board of Directors on the evaluation of transactions with related parties, validating thatthey are carried out under market conditions and ensuring that there are no conflicts of interest.The Regulation of the Board of Directors states in article 6 that directors, while in theexercise of their functions, have the duty to avoid situations that may give rise to conflictsof interest.
III. Economic and Governance Responsibility > Ethics and Professional Conduct

2-16

2-17

2-18
2-19
2-20

Communication ofcritical concerns
Collective nowledgeof the highest governance body
Performance assessment of the highest
governance body
Remuneration Policies
Process for determining remuneration

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 presented in
the item 27 c) of the Corporate Governance Report).
SR 23 | Introduction > Governance Model

Corporate Governance Report
Corporate Governance Report > Section III - Part D. Remunerations
Corporate Governance Report > Section III - Part D. Remunerations
Portugal:
The net annual total remuneration ratio recorded in 2023 was 21.

2-21

Annual total remuneration ratio

The ratio between the percentage increase in the net annual total remuneration of thehighest paid individual in the organisation and the median of the percentage increase in the
total annual net remuneration of all employees (excluding the highest paid) recorded was
4.94.
Notes: (i) The ratios presented above were calculated based on the fixed and variable
amounts paid, net of taxes and mandatory contributions applicable, to the organization's

223

SUSTAINABILITY REPORT 2023

GRI STANDARDS

UNGC
Principles

Content, page or linkhighest paid individual and to all employees of the organization; (ii) the total annual remuneration of the organization's highest paid individual does not include amounts not attributable to the 2023 financial year.
Poland:The annual total remuneration ratio recorded in 2023 was 40.
The ratio between the percentage increase in the annual total remuneration of the highest
paid individual in the organisation and the median of the percentage increase in the annual
total remuneration of all employees (excluding the highest paid individual) recorded was
1.42.
Mozambique:
The annual total remuneration ratio recorded in 2023 was 66.
The ratio between the percentage increase in the annual total remuneration of the highest
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 2.32.

STRATEGY, POLICIES AND PRACTICES
2-22

Declaration on sustainable development strategy

SR 23 | Joint Message from the Chairman of the Board of Directors and the Chairman of the
Executive Committee
SR 23 | Introduction > Governance Model

2-23

Policies

2-24

Incorporation of
Policies

2-25

2-26

2-27

Processes to remedy negative impacts
Mechanisms for advice and raising concerns

Compliance withlaws and regulations

Information regarding Policies and Commitments is available on the corporate website
https://ind.millenniumbcp.pt/en/Institucional/governacao/Pages/normas_regulamentos.aspx
Information regarding Policies and Commitments and how these are incorporated in the
Bank is available on the corporate website: : https://ind.millenniumbcp.pt/en/Institucional/governacao/Pages/normas_regulamentos.aspx
SR 23 | Introduction > ESG Risk Management

SR 23 | Introduction > Ethics and Professional Conduct
Total no. of significant cases of non-compliance with laws andregulations
No. of significant cases of non-compliance with laws and regulations for which fines were applied
No. of significant cases of non-compliance with laws and regulations in which non-monetary sanctions were applied
Monetary value of fines imposed in significant cases of noncompliance 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

2-28Participation in Associations

10
1
10
538,500
538,500
0

Information on the Associations to which the Bank belongs is available on the corporatewebsite: https://ind.millenniumbcp.pt/en/Institucional/sustentabilidade/Pages/comunid_externa.aspx

STAKEHOLDER ENGAGEMENT

2-29

2-30

Stakeholder engagement approach
Collective negotiation agreements

https://www.millenniumbcp.pt/en
Institutional > Sustainability > Stakeholders management
Approach to Sustainability | Relation with Stakeholders
SR 23 | Summary of Indicators

MATERIAL ISSUES
3-1

Process of defining
material issues

SR 23 | Approach to Sustainability | Relation with Stakeholders > Stakeholders Involvement and materiality Analysis

224

SUSTAINABILITY REPORT 2023

GRI STANDARDS

3-2

3-3

3-3

3-3

3-3

3-3

3-3

3-3

3-3

3-3

3-3

3-3

3-3

List of material issues
Management of material issues: Cybersecurity, privacy andinformation protection
Management of material issues: Innovation and digitalisation
Management of material issues: Ethics,
conduct and complianceManagement of material issues: Prevention of corruption and money
laundering
Management of material issues: Transparency of the information provided tocustomers about
products and services
Management of material issues: Sustainability GovernanceManagement of material issues: Resilience of the business
modelManagement of material issues: Risk
management
Management of material issues: Satisfaction and customer experience
Management of material issues: Management of thebrand and reputation
Management of material issues: Economic performance
Management of material issues: Attracting, developing
and retaining talent

UNGC
Principles

Content, page or link
SR 23 | Approach to Sustainability | Relation with Stakeholders > Stakeholders Involvement and materiality Analysis
SR 23 | Economic and Governance Accountability > Information Security
SR 23 | Economic Responsibility and of Governance > Protection and security, privacy ofdata

SR 23 | Economic and Governance Accountability > Innovation

SR 23 | Economic and Governance Responsibility > Ethics and Professional Conduct

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct

SR 23 | Economic and Governance Responsibility > Products and Services

SR 23 | Introduction > Governance Model

SR 23 | Value Creation
SR 23 | Relation with Stakeholders > SMP - Sustainability Master Plan 2023

SR 23 | Introduction > Management of ESG risks

SR 23 | Economic and Governance Responsibility > Quality Services

SR 23 | Table of Contents and Sustainability Recognitions

AR 23

SR 23 | Economic Responsibility and of Governance >Employees

CATEGORY: ECONOMICECONOMIC PERFORMANCE
201-1

Direct economic
value generated
and distributed

AR23 | Information on the BCP Group > Principal Indicators
AR23 | Financial Information > Results and Balance Sheet > Analysis

201-2

Financial implications, risks andand opportunities

SR 23 | Environmental Responsibility > Task Force on Climate-related Financial Disclosures(TCFD)
https://www.cdp.net > Search responses > Banco Comercial Português SA

225

SUSTAINABILITY REPORT 2023

GRI STANDARDS

UNGC
Principles

Content, page or link

due to climatechange201-3

Benefit plans
defined by the organisation

AR 23 |

MARKET PRESENCE

202-1

202-2

Ratio between thelowest wage and the
local minimum wage,
by gender, in the
Importantoperational units

Proportion of employees hired locally

SR 23 | Summary of Indicators

6

No. of employees
hired locally% of employees
hired locallyNo. of employees of the BoD,
EC and Senior Management
hired locally% of employees of the BoD, EC
and Senior Management hired
locally

Men

Women

Total

6,958

8,665

15,623

99,4%

99,7%

99,6%

131

40

171

91.6%

100%

93.4%

INDIRECT ECONOMIC IMPACTS

203-1

203-2

Development andimpact of investments in infrastructure and services offered
Significant indirect
economic impacts,
including the extent
of impacts

SR 23 | Social Responsibility > Share and Participate
SR 23 | Social Responsibility > Financial Literacy
SR 23 | Social Responsibility > Foundations Group BCP
SR 22 | Social Responsibility > Share and Participate
SR 23 | Social Responsibility > Financial Literacy
SR 23 | Social Responsibility > Foundations Group BCP

PURCHASING PRACTICES

204-1

Proportion of expenses with local
suppliers in important operationalunits

SR 23 | Summary of Indicators
SR 23 | Economic Responsibility and of Governance > Suppliers

ANTI-CORRUPTION

205-2

205-3

Percentage of employees trained in
the anti-corruption
policies and practicesof the organisation
Actions taken in response to corruptioncases

SR 23 | Economic and Governance Accountability > Employees > Training

10

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct
There were no cases of corruption in 2023

10

TAXES
207-1
207-2

207-3

Tax approach
Governance, Tax risk
control and management
Stakeholder engagement and managing
their concerns on
tax

SR 23 | Economic and Governance Accountability > Tax Policy
SR 23 | Economic Responsibility and of Governance > Fiscal Policy

SR 23 | Economic Responsibility and of Governance > Fiscal Policy

226

SUSTAINABILITY REPORT 2023

UNGC
Principles

GRI STANDARDS

Content, page or link

207-4

SR 23 | Economic Responsibility and of Governance > Fiscal Policy

Report by geography

CATEGORY: ENVIRONMENTAL
MATERIALS
301-1

Materials consumption

SR 23 | Environmental Responsibility > Sustainable Operations

7, 8

SR 23 | Environmental Responsibility > Energy Efficiency

7, 8

SR 23 | Environmental Responsibility > Energy Efficiency

8

SR 23 | Environmental Responsibility > Energy Efficiency

8, 9

ENERGY
302-1
302-3
302-4

Energy Consumption within the organization
Energetic intensity
Reduction of energy
consumption

WATER AND EFFLUENTS

303-1

Interactions withwater as a sharedresource

A significant portion of the water consumed in the BCP is associated with human use. In addition to this, it is also used for irrigation in the facilities. In 2023, all the water for irrigationof the green spaces in Taguspark came from the borehole.
The Group is concerned about reducing its environmental impact, which includes reducing
water consumption in all geographies where it operates.
BCP does not identify in its direct operation areas of water stress relevant to this report.
SR 23 | Environmental Responsibility > Sustainable Operations

303-2

Management of impacts related to water discharge

303-3

Water withdrawal

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 networks, and aresubsequently subject to treatment and quality monitoring by the responsible entities.
SR 23 | Environmental Responsibility > Sustainable Operations
SR 23 | Environmental Responsibility > Sustainable Operations

7, 8

The Bank's operations do not have a significant direct impact on biodiversity, protected or
restored habitats, which justifies the irrelevance of this indicator.

8

The Bank's operations do not have a significant direct impact on biodiversity, protected or
restored habitats, which justifies the irrelevance of this indicator.

8

The Bank's operations do not have a significant direct impact on biodiversity, protected or
restored habitats, which justifies the irrelevance of this indicator.

8

SR 23 | Environmental Responsibility > Sustainable Operations

7, 8

SR 23 | Environmental Responsibility > Sustainable Operations

7, 8

SR 23| Environmental Responsibility > Sustainable Operations

7, 8

SR 23| Environmental Responsibility > Sustainable Operations

8

SR 23| Environmental Responsibility > Sustainable Operations

8, 9

BIODIVERSITY

304-11

304-2

304-3

Operational facilities(owned, leased or
managed) in areas
surrounding protected areas and areas of high biodiversity value outside
protected areas
Significant impacts ofactivities, products
and services on biodiversity
Protected or restored habitats

EMISSIONS
305-1
305-2
305-3
305-4
305-5

GGE direct emissions (Scope 1)
GGE indirect emissions (Scope 2)
Other GGE indirectemissions (Scope 3)
Intensity of GGE
emissions
Reduction of GGE
emissions

WASTE

227

SUSTAINABILITY REPORT 2023

GRI STANDARDS

306-1

306-2
306-3

Waste generationand significant impacts related towasteManagement of significant impacts related to waste
Generated waste

UNGC
Principles

Content, page or link
Waste production at BCP is mostly associated with office waste (paper, cardboard and plastic). The Group is concerned about reducing its environmental impact, which includes reducing waste production in all geographies where it operates.
SR 23 | Environmental Responsibility > Sustainable Operations
SR 23| Environmental Responsibility > Sustainable Operations
SR 23| Environmental Responsibility > Sustainable Operations

8

CATEGORY: SOCIAL
WORK
SR 23 | Economic and Governance Accountability > Employees > Evolution of the workforce

401-1

New hirings andturnover2023 Recruitment<30[30-50[
>=50
Total

Men

Women

Total

403
197
17
617

608
282
17
907

1011
479
34
1 524

Men

Women

Total

<30
[30-50[

256
255

356
477

612
732

>=50

146

117

263

Total

657

950

1 607

2023
tures

401-2

401-3

Benefits for fulltime employeesthat are not provided to temporary
or part-time employees

Parental leave

depar-

6

SR 23 | Social Responsibility > Employee Benefits
The benefits identified in the Reports are granted to the Bank's employees (full-time or parttime) but are not extended to interns or outsourcers.

BCP Group
Employees that were entitled to parental leave
Employees that took parental leave
Employees that returned to work
Employees that returned to work after parental
leave ended that were still employed 12 months after their return
Employees who returned to work after parental
leave in the previous reporting period
Return rate - % of employees who returned to work
after parental leave
Retention rate - % employees who remained at the
Bank after parental leave

LABOR/MANAGEMENT RELATIONS

228

Men
133
69
67

Women
621
443
416

Total
754
512
483

58

358

416

6

6
61

432

493

97.1%

93.9%

94.3%

95.1%

82.9%

84.4%

SUSTAINABILITY REPORT 2023

GRI STANDARDS

402-1

Minimum notice periods regarding
operational changes

UNGC
Principles

Content, page or link

Minimum number of days in advance to notify employees of structural/operationalchanges: 30 days.

OCCUPATIONAL HEALTH AND SAFETY
Millennium bcp has published regulations establishing the general principles relating to theprevention of professional risks, protection of the safety, hygiene and physical and mental
health of Employees, 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 healthand safety management system

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 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 andregulatory context, as well as good voluntary implementation practices.
With a view to ensuring adequate health surveillance of Employees, Millennium bcp carriesout, according to each case, admission exams, periodic exams differentiated according togender and age group - up to the age of 50 the periodicity is every two years and annual afterthat age - occasional and complementary exams, as well as activities to promote health atwork, keeping organized the clinical records and other information elements relative to thehealth 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 andthe necessary recommendations are made.
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 theareas whose intervention is justified to resolve the recommendations made.
All Employees are made aware of the importance of looking after their own safety and healthand that of others who may be affected by their actions or omissions at work, and of theneed to immediately inform their employer of any work situation that presents a serious andimmediate danger to safety or health, as well as any defect in the protection systems.

403-2

Identification ofdangerousness,risk assessment
and investigation ofincidents

Periodically, drills are carried out to identify improvements to be introduced in emergency
procedures and also audits to buildings. In 2023, were carried out 4 drills and 6 Audits. A
significant reinforcement of the initiative plan is planned for 2024.
The Regulation in force determines that in the event of serious, immediate danger that cannot be avoided, Employees have the right to leave their workstation or a dangerous area andcannot be harmed by this fact and assumes the commitment that no action will be taken
against anyone who reveals a concern about matters related to health and safety at work or
by reporting an accident.
The Information and dissemination on the procedures and contacts to be used in situationsof danger or emergency can be found on the Internal Portal, not only in the Physical Security
Department, which has direct responsibility for these issues, but also in Human Resources
department. The process of reporting risk or accident situations can be triggered directly by
the employee or by the hierarchy, and the reporting process is different depending on thecircumstances.
In the case of accidents at work, and according to the information available in the Human
Resources area, there is a dedicated line, available 24 hours a day. Situations that are identified as accidents at work are reported to the insurance company, which investigates the circumstances underlying their origin and takes the appropriate action. Whenever the Bank hasreports of occurrences that justify its intervention, the necessary measures are taken to mitigate situations that have some level of risk associated with them.

229

6

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GRI STANDARDS

UNGC
Principles

Content, page or link
We periodically invite all employees and trainees to take specific training on the issue ofsafety and hygiene at work, with regular monitoring of the degree of completion. This training includes modules such as: Accidents at work; Ergonomics; Emergency situations; Signposting; Injuries and First Aid. This training, which is compulsory, is made available to all new
employees and trainees immediately after they join the company.
In addition to the occupational medicine doctors referred to above, there is a team of curative medicine doctors and nurses available every day at the Bank's premises in Taguspark anda doctor and a nurse at the Bank's premises in Porto. The coordination of this team is madeby the physician performing the functions of Chief Medical Officer, who reports to the Human
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 theaim 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 abetter 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 services
are provided, free of charge, to all Employees. The bank also provides services of collectionof 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 thata personalised food plan is prescribed through strategies adjusted to the lifestyle of each
employee, allowing him/her to change and adopt healthy habits in a gradual manner. The
Psychology 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.

403-3

Occupational healthservices

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 living
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.
Information and dissemination on the procedures and contacts to be used in situations ofdanger or emergency can be found on the Internal Portal, not only in the area of the Physical
Security Department, which has direct responsibility for these issues, but also in the area of
Human Resources. The process of reporting risk or accident situations can be triggered directly by the employee or by the hierarchy, and the reporting process is different dependingon the circumstances.
In the case of accidents at work, and according to the information available in the Human
Resources area, there is a dedicated line, available 24 hours a day. Situations that are identified as accidents at work are reported to the insurance company, which investigates the circumstances underlying their origin and takes the appropriate action. Whenever the Bank hasreports of occurrences that justify its intervention, the necessary measures are taken to mitigate situations that have some level of risk associated with them.
We periodically invite all employees and trainees to take specific training on the subject ofsafety and hygiene at work, with regular monitoring of the degree of completion. This training includes modules such as: Accidents at work; Ergonomics; Emergency situations; Signposting; Injuries and First Aid. This training, which is compulsory, is made available to all new
employees and trainees immediately after they join the company.
23 SR | Social Responsibility > Employee Benefits > Health and Safety

403-4

Worker participation, consultationand communication
to workers

The carrying out of internal satisfaction surveys with the various services and the possibilityof 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.

230

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GRI STANDARDS

403-5

403-6

Training of workers
in occupational
health and safety
at work

Worker health promotion

UNGC
Principles

Content, page or link
Training related to health, hygiene and safety at work, which is carried out periodically andmandatorily for all employees, in 2023 covered 311 employees, totaling 466.5 hours.
The decrease in the number of participants/hours compared to 2022 is due to the fact that,last year, e-learning with updated content was made available to all employees, while in
2023 only new employees or returnees from prolonged absence were invited to take thecourse.
Employees are called for check-ups in accordance with the rules established and alreadymentioned. Following the check-up, they are subsequently called for the occupational
health consultation. 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 withthe service provider.
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, dietand healthy living habits reflects the intention to encourage the dissemination of information aimed at promoting a healthier lifestyle with positive effects on physical, emotionaland social well-being, with repercussions on the balance between professional and personal
life.

403-7

Prevention and mitigation of health andsafety impacts
directly linked withbusiness relationships

The Bank has organised an occupational health and safety service that is responsible fordrafting and updating the Occupational Health and Safety Plan, which includes the internal
emergency plan, the specific plans for fire fighting, evacuation of premises and first aid, theoccupational risk prevention plan, the development of health promotion activities andhealth surveillance examinations.
The external entity that supports the Bank in conducting audits of workplaces ensures theidentification of any anomaly that needs to be corrected in the reports it draws up.
SR 23 | Summary of Indicators
23 SR | Social Responsibility > Employee Benefits > Health and Safety

403-9

Work accidents
In 2023 there were 56 accidents at work, one of which had serious consequences (sick leaveof more than 6 months). Total hours worked were 28,691,168.

TRAINING AND EDUCATION

404-1

Average hours of
training per year per
employee by employee category

SR 23 | Economic and Governance Accountability > Employees > Training

404-2

Competence management and lifelong
learning programmes

SR 23 | Economic and Governance Accountability > Employees > Training

404-3

Percentage of employees receiving
regular performanceand career development reviews.

6

SR 23 | Economic and Governance Accountability > Employees > Assess and recognize
Employees evaluated in 2023
Employees evaluated in theyear% Employees evaluated in theyear

DIVERSITY AND EQUAL OPPORTUNITIES

231

Men

Women

Total

6,055

7,791

14,446

95.1%

89,7%

92,1%

6

SUSTAINABILITY REPORT 2023

GRI STANDARDS

405-1

Composition of thecorporate bodiesof the company andlist of employees by
category, according
to gender, agegroup, minorities
and other diversity
indicators.

UNGC
Principles

Content, page or link

SR 23 | Summary of Indicators
SR 23 | Economic and Governance Accountability > Employees
Additionally, BCP identifies and reports its employees with disabilities.
In 2023, in Portugal, the Bank had 171 disabled people (82 men and 89 women) and in Poland 64 disabled people (23 men and 41 women).

6

SR 23 | Economic Responsibility and of Governance >Employees
Portugal405-2

Ratio of total remuneration between men andwomen by employee category.

SeniorManagement
Management
Commercials
Technicians
Other

PolandMozambiqueBase Salary(W/M)

Total remuneration(W/M)

Base Salary(W/M)

Total remuneration(W/M)

Base Salary(W/M)

Total remuneration
(W/M)

1.0

0.9

0.9

0.9

0.6

0.6

6
1.0

1.0

0.8

0.8

0.7

0.6

0.9

0.8

0.9

0.9

0.9

0.9

0.9

0.9

0.7

0.7

0.9

0.9

0.9

0.9

0.9

0.8

1.2

1.1

NON DISCRIMINATION
406-1

Discrimination cases
and actions taken

In 2023 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 ofviolation of the rightto freedomof association andcollective negotiation, and actions
taken

SR 23 | Economic Responsibility and of Governance > Suppliers
In 2023, no case was identified

3

No cases were identified in 2023

CHILD LABOUR

408-1

Operations and suppliers identified
with a risk of child
child labour, and actions taken

SR 23 | Economic Responsibility and of Governance > Suppliers
In 2023, no case was identified
No cases were identified in 2023

HUMAN RIGHTS ASSESSMENT

232

5

SUSTAINABILITY REPORT 2023

GRI STANDARDS

UNGC
Principles

Content, page or link

Operations subject
to human rights assessments

SR 23 | Social Responsibility > Human Rights

LOCAL COMMUNITIES

413-1

Operations with
programmes for
involvement of local
communities

SR 23 | Social Responsibility > Share and Participate
SR 23 | Social Responsibility > Financial Literacy
SR 23 | Social Responsibility > Foundations Group bcp

FS13

Access in sparsely
populated or economically disadvantaged areas

SR 23 | Summary of Indicators
SR 23 | Economic and Governance Responsibility

FS14

Initiatives to improve access to financial services for
disadvantaged people

SR 23 | Summary of Indicators
SR 23 | Economic and Governance Responsibility

FS15

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

SR 23 | Economic and Governance Responsibility > Ethics and Professional Conduct > Policies for the fair design and sale of financial products and services

1

PUBLIC POLICIES

415-1

No contributions are made to political parties as required by law.

Political Contributions

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct

PRODUCT AND SERVICE LABELLING

417-1

Information on
products and services required byregulations, and thepercentage of significant products andservices subject tosuch requirements

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct

CUSTOMER PRIVACY

418-1

Complaints regarding breaches of customer privacy andlosses of customer
data

Complaints received from external parties and substantiated by the organisation
Complaints from regulatory agencies
Total no. of substantiated complaints regarding breachesof customer privacy
Total no. of customer data leaks, thefts or losses thathave been identified
•
•

39*
0
39
28

*two of which attributed to Ativobank** one of which attributed to Ativobank

COMPLIANCE
Amounts of significant fines and total
number of nonmonetary sanctions
for non-compliance

SR 23 | Economic and Governance Responsibility > Ethics and Professional Conduct > Internal Audit

233

SUSTAINABILITY REPORT 2023

GRI STANDARDS

UNGC
Principles

Content, page or linkwith laws and regulations

SECTOR SUPPLEMENTPRODUCT PORTFOLIO - MATERIAL ASPECT

FS6

FS7

FS8

Percentage of specific business lines/
specific businesssegment, in total
volume, by regionand size(Monetary) volume
of products andand services withsocial benefit,
by business line
(Monetary) volume
of products andand services withenvironmental benefit, by business line

AR23 AR | Accounts and notes to consolidated accounts < Note 52 Consolidated Balance
Sheet and Income Statement Indicators by Geographical and Operating Segments

SR 23 | Economic and Governance Accountability > Products and Services
SR 23 | Environmental Accountability > Eco-friendly products and services offer

SR 23 | Economic and Governance Accountability > Products and Services
SR 23 | Environmental Accountability > Eco-friendly products and services offer

AUDIT

FS10

Percentage andnumber of companies included in theportfolio with which
it has interacted regarding social andenvironmental aspects

SR 23 | Economic and Governance Accountability > Products and Services
SR 23 | Environmental Accountability > Eco-friendly products and services offer

FS11

Percentage of assets
subject to environmental and social
assessment

SR 23 | Economic and Governance Accountability > Products and Services
SR 23 | Environmental Accountability > Eco-friendly products and services offer

GRI- Global Reporting Initiative

234

SUSTAINABILITY REPORT 2023

Table SASB - Sustainability Accounting Standards Board

SASB – Commercial Banks

Category /measureunit

Content and location of the information

Scope

DATA SECURITYFNCB230a.
1(1) Number of data
violation, (2)percentage that involved personal
identification information (PII), (3)number of affectedaccount holders

Number of data violation: 28 (one of which may be attributed to Ativobank)
Percentage that involved personal identification information: 74%*
Number,
Percentage(%)

Number of affected account holders: 145 (one of which may be attributed to
Ativobank)Portugal*Cases involving direct personal identification data were considered; Situations involving
personal data, considered indirect identifiers, are excluded, as it is understood that they do
not represent a risk of identification of the affected subjects, since there is no access by third
parties to additional information necessary to allow the identification of these subjects .

FNCB230a.
2

Description of theapproach to identify
and handle data
safety risks

n/a

The regulatory context applicable to Portugal and Poland in terms ofdata security 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, approved 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 andprocedures can be found in the 2023 Sustainability Report, Information Safety Chapter.

FINANCIAL INCLUSION AND CAPACITATION
Millennium bcp supported in 2023 2,736 projects for the development of small businesses and communities (1), with a total credit ofapproximately 522,239 thousands euros (2).
No. ofprojects

Amount(thousand €)Lines to support Entrepreneurship(Microinvest and Investe+)

61

1 483

Decarbonization and Circular Economy

14

4 045

EIB Lines

30

48 439ADN Lines

35

9 005

Credit Lines with IFAP (IFAP Shortterm and IFAP ML term)

131

11 139Lines to Finance Tourism

39

21 018

FEI Lines

1 474

310 502

IFFRU

32

34 893

Green car (Leasing and ALD)

912

43 737

Other (OSI, Madeira, Azores, SI Inovação, REC Green)

8

37 978

Projects

FNCB240a.
1(1) Number and (2)amount of pendingloans qualified forprograms conceived
to promote the development of small
companies and theCommunity

Number,Currency

More information on the number and amount of loans to businesses
with social and environmental benefits can be found in the 2023
Sustainability Report, Chapter of Products and Services (Social andEnvironmental).

235

PortugalSUSTAINABILITY REPORT 2023

SASB – Commercial BanksFNCB240a.
2

FNCB240a.
3(1) Number and (2)amount of past-due
and nonaccrualloans qualified forprograms to promote the development of small companies and of thecommunity

Number of current
accounts without
costs supplied to clients previously
without a bank oraccessing only somebasic banking
services

Category /measureunit

Content and location of the information

Number,Currency

Information on past-due and nonaccrual loans isreported in the 2023 Annual Report 2, Chapter Earnings and Balance
Sheet - Credit to Clients

Within the scope of the inclusion of individual Clients (resident andnon-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, thisaccount can be used with a debit card and through online banking. In
2023, 5,669 accounts were opened, presently accruing to 26,705 accounts.
Number

In Portugal, within the scope of Entities that incorporate the social sector, Millennium bcp keeps available the Non-Profit Association Account, a current account with special conditions that does not require
an opening minimum deposit and has no maintenance and overdraft
fees. 318 accounts with these features were opened in 2023, corresponding to a total of 5,332 accounts in the Bank's portfolio.

Scope

PortugalMore information on the Bank’s Social Inclusion offer can be found in
the 2023 Sustainability Report, Social Inclusion Chapter.

FNCB240a.4

Number of participants in financial
education initiatives
for clients without abank or having only
access to somebasic banking services

In 2023, Millennium bcp impacted more than 3.800 people throughits initiatives for the promotion of financial literacy.
NumberMore information on the number and amount of loans to small businesses and with social and environmental benefits can be found in the
Sustainability Report 2023, Chapter Products and Services.

BCP
Group

INCORPORATION OF ENVIRONMENTAL, SOCIAL AND GOVERNMENT FACTORS IN THE CREDIT ANALYSISFNCB410a.
1

FNCB410a.
2

Exposure ofcommercial and industrial credit per
sectorDescription of theapproach to incorporate environmental, social and governance factors in(ESG) the credit
analysisCurrency

n/aInformation on loans and credits to clients, per sector isreported in the 2023 Annual Report 2, Chapter Earnings and Balance
Sheet - Credit to Clients
The BCP Group offers a complete and broad range of financial products
and services, and continues, under the development of its businesslines, responsible for offering an increasing number of products andservices which incorporate 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 on greater value and higher quality of the
products and services offered to customers, meeting the needs andambitions of a market increasingly related with sustainability. In thatsense, the Portuguese operation introduced an ESG matrix in the internal risk classification for larger companies.
More information on the approach for the incorporation of ESG risks inthe credit analysis can be found in the Market Discipline Report 2023,
Chapter Environmental and Social Risks and in the Sustainability Report 2023, Chapter TCFD.

BUSINESS ETHICS

236

BCP
Group

PortugalSUSTAINABILITY REPORT 2023

SASB – Commercial BanksFNCB510a.
1

Total amount ofmonetary losses as aresult of legal proceedings associatedwith fraud, insider
trading, antitrust, anticompetitive behaviour, market manipulation, malpractice orother laws or regulations of the financial
sectorCategory /measureunit

Content and location of the information

Scope

Currency

Information on legal and internal procedures associated with fraud,
trading with privileged information, anti-trust, anti-competitive behaviour, market manipulation, malpractice can be found in the 2023
Sustainability Report, Internal Audit Chapter.

Portugal

In Portugal, a Communication of Irregularities Policy (Whistleblowing)is implemented, regulated by a specific Service Order.
FNCB510a.2

Description of thewhistleblowing
policies and proceduresn/a

In Poland and Mozambique, in accordance with the recommendations
issued 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 Irregularitiesof the Bank is available here: Institutional/Governance/Articles of Association and main rules and regulations of the Bank/Policy for theCommunication of Irregularities

BCP
Group

MANAGEMENT OF SYSTEMIC RISKFNCB550a.1

Notation of the
Global Systemically
Important Bank (GSIB), per category

Basispoints(bps)

The BCP Group and the banks part of it are not considered Global Systemically Important Bank (G-SIB).
More information on the G-SIB (2023) available here: Financial
Stability Board (FSB) - 2023 List of Global Systemically Important Banks(G-SIBs)

BCP
Group

The ICAAP is a key process within the framework of the BCP Group's
risk management function and is developed under an internal governance model that guarantees the involvement of the Board of Directors(the body responsible for approving results) and its Risk Assessment
Committee (CAvR), the EC and the Group's top management, in its various stages.

FNCB550a.2

Description of approach for incorporating mandatory
and voluntary stresstest results into capital adequacy planning, long-term corporate strategy andother business activities

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 projections of the balance sheet and results of the strategic plan andbudget, in order to ensure the sustainability of the Group in the medium term, with respect for the risk limits defined in the RAS (Risk Appetite Statement) approved by the Board of Directors.
n/a

For this purpose, the ICAAP starts from a prospective view of the impacts 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, having as a background the projected developments for the Group's activity in a medium-term timeframe (3 years). Impacts are estimated under
different scenarios, including stress scenarios with a severely penalizing evolution of macroeconomic indicators. Through this process, it ispossible to test the Group's resilience, verifying that capital levels areadequate to cover the risks to which its activities may be subject. For
this purpose, the different risks are modelled or incorporated into theframework of the Group's stress test methodology.
More information on incorporating stress test results into capital adequacy planning, long-term corporate strategy and other business activities can be found at the 2023 Annual Report, Chapter Pensions Fund
Risks and in the 2023 Sustainability Report, Chapter TCFD.

ACTIVITY METRICS

237

BCP
Group

SUSTAINABILITY REPORT 2023

Category /measureunit

Content and location of the informationFNCB000.A(1) Number and (2)value of the current
and savings accounts per segment:(a) individual and (b)small companies

Number,Currency

Informationon
Customer
Funds
can
be
the Annual Report 2023 Chapter Customer Funds.

found

in

BCP
Group

FNCB000.B(1) Number and (2)value of the loans
per segment: (a) individual, (b) small
companies and (c)companies (mortgage loans as well as
revolvingcreditloans,should be excluded from the disclosure scope).

Number,Currency

Informationon
Customer
Funds
can
be
the Annual Report 2023, in Chapter Credit to Clients.

found

in

BCP
Group

SASB – Commercial Banks

238

Scope

SUSTAINABILITY REPORT 2023

Table UNGP - 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?

A2
Incorporating respect for humanrightsHow 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 organizedwithin the company and why?
A2.2 What kind of human rights issues are
discussed by top management and theBoard, and why?
A2.3 How are employees and service providers made aware of how respect for humanrights should be considered 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 toachieve respect for human rights and what
has changed as a result of that learning?

The BCP Group assumes its commitment to the promotion of
Human Rights through the Human Rights Policy, published in2014 and revised several times, as a result of internalreflection process and evaluation of good practices, namely in
2023
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 ofbest practices in this matter (see the Human Rights chapter).
The various commitments to Human Rights cover mainly, but
not exclusively, all those who work at the Bank, including
employees, as well as suppliers and business partners,
customers and the local communities, namely through thedevelopment of partnerships and initiatives that contribute to
the promotion of human rights

The Committee for Corporate Governance, Ethics andSustainability ( that depends from the Board of Directors) andthe Commission for Human Resources and for Sustainability(that depend from the Executive Committee) are thegovernance 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 wasto 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
The BCP Group, within the scope of its Human Rights Policy,
establishes its commitment to the following themes:

B1.
Declaration of Relevant Themes•

State the main human rights issues associated with the company's activities and business relationships during the reporting period.

Prohibition of forced labour, child labour andhuman trafficking;•Non-discrimination and prohibition of harassment;•

Freedom of association and of collective
bargaining;•

Remuneration;•

Relations with interested parties (employees andshareholders clients, suppliers and partners andthe community).

B2.
Identification of Relevant Themes
Describe how key human rights issues were determined, including any
input from stakeholders.

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 wereidentified based on the main national and internationalreferences and regulations, such as the Universal Declarationof Human Rights or the Ruggie Framework and based on thebest practices in the market.
The information on Human Rights reported relates to thethree countries where Group BCP operates: Portugal / Poland

B3.

239

SUSTAINABILITY REPORT 2023

Choice of local geographies
If the report on key human rights topics focuses on specific geographies,
explain how this choice was made.

/ Mozambique Whenever such does not happen, such fact isduly identified.

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.

Through the various mechanisms implemented, or throughother means, no severe impacts on Human Rights arising fromthe activity of the BCP Group were identified.

PART C: MANAGEMENT OF RELEVANT THEMES ON HUMAN RIGHTS

C1.
Specific Policies

Does the company have any specific policy that addresses its most relevant human rights issues? If yes, which
one/which are they?
C1.1 How does the company convey the relevance and meaning of such policies to those
who must implement them?

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 humanrights themes the company should promote,when and how to do it?
C2.2 During the reporting period, whichstakeholders whose involvement in relation
to each relevant human rights issue did thecompany promote and why?

The BCP Group has a Human Rights Policy that establishes theapproach 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 thecompany Intranet.

Millennium bcp seeks to actively involve its stakeholders in thedevelopment of its activity, including issues related to Human
Rights.
In addition to the current involvement practices (see chapter
Approach to Sustainability), all issues identified through thevarious existing mechanisms for this purpose are subject toanalysis and subsequent implementation of improvements,
whenever this proves to be necessary and capable of adding
value.

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?

C3.
Assessment of
Impacts

How does the company identify changes
in each relevant human rights issue overtime?
C3.1 During the reporting period, were there
any notable trends or patterns in impacts related to a relevant issue, and if so, what werethey?
C3.2 During the reporting period, did any serious impacts related to a relevant issue occur and, if so, what were they?

C4.
Include findings
and implement
actions

Millennium bcp guarantees the analysis and follow-up of allissues related to Human Rights identified through the specificand confidential internal communication channel. In addition,
all situations detected by or communicated to the internal
audit function are also evaluated. Are also considered thesituations identified through the Client Ombudsman.
The self-assessment process conducted during 2021 andcompleted in 2022 also represents a potential source of
information for identifying changes in issues related to Human
Rights.
In 2023, no significant changes or serious impacts related to
Human Rights were identified.

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?

As mentioned in item C2. Involvement of Stakeholders, allissues identified by stakeholders are subject to analysis andoriginate actions for improvement and development ofsolutions/resolution of identified problems, if applicable.

C4.2 When tensions arise between preventing or mitigating impacts related to a relevant
issue and other business objectives, how are
they handled?

In 2023, the implementation of improvement actions in thegeographies continued, based on the results of the selfassessment.
.

C4.3 During the reporting period, what
measures did the company implement toprevent or mitigate potential impacts related
to each relevant issue?

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SUSTAINABILITY REPORT 2023

C5.
Follow-up performance

C6.
Remediation

How does the company know if its efforts regarding each relevant humanrights 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 base guidelines and expected conduct forgroups 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 canbe verified by answering questionnaires or visiting places
where the activity is carried out.

How does the company offer effective
solutions to people who, through theiractions and decisions, are harmed interms 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 theresults?
C6.4 During the reporting period, what were
the trends and patterns of complaints or concerns and related results in relation to eachrelevant issue and what lessons learned?
C6.5 During the reporting period, did thecompany provide or facilitate the remediation of any actual impacts related to a material issue, and if so, what are typical or significant examples?

241

The Bank encourages 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) the
Client Ombudsman. Situations that are reported throughother channels are also analysed and, whenever necessary,trigger improvement actions.
In 2023, there were no complaints or concerns expressed byany group of stakeholders in terms of Human Rights.

SUSTAINABILITY REPORT 2023

Table regarding the alignment with the recommendations from the TCFD - Task Force on
Climate-Related Financial Disclosures
PillarGovernance
How we manage theclimate-related risks andopportunities
and opportunities

Strategy
How we manage thecurrent and potential impacts of climate-relatedrisks
and opportunities

Risks and opportunities
How we identify, asses
and manage theclimate-related risks andopportunities

Metrics and targets
How we assess andmanage the climate-relatedrisks andopportunities

Recommendationsa) Describe Management's oversight of climate-related risks and opportunities.
b) Describe management's role in assessing and managing climate-related risks and opportunities.

a) Describe the climate-related risks and opportunities identified by the Organization for the short, medium and long term.
b) Describe the impact of climate-related risks andopportunities on the Organization's business, strategy and financial planning.
c) Describe the resilience of the organization’s strategy, considering the different climate-related scenarios, including the 2ºC or lower scenario.

a) Describe the organization’s process for identifying
and assessing climate-related risks.
a) Describe the organization’s process to manage climate-related risks.
c) Describe how the Organization's climate-related
risk identification, assessment and management processes are integrated into overall risk management.

a) Disclose the metrics used by the organization toassess climate-related risks and opportunities, in linewith the risk management strategy and process.
b) Disclose GHG emissions (scopes 1, 2 and 3) and theassociated risks.
c) Describe the objectives used by the organization to
manage climate-related risks and opportunities andassess its performance against the objectives.

242

Sources of Reference• 2023 Sustainability Report > Environmental Responsibility > TCFD
• CDP Climate Change 2023- C1 Governance• 2023 Annual Report > Risk Management• 2023 Sustainability Report >Environmental Responsibility > 2023 Sustainability Master Plan - Environmental
Action Plan
• 2023 Sustainability Report >Environmental Responsibility > Sustainable
Operations• 2023 Sustainability Report > Environmental Responsibility > TCFD
• CDP Climate Change 2023- C2 Risk andOpportunities, C3 Business Strategy• 2023 Sustainability Report > Environmental Responsibility > TCFD
• CDP Climate Change 2023- C2 Risk andOpportunities, C3 Business Strategy• 2023 Sustainability Report > Environmental Responsibility > Sustainable Operations• 2023 Sustainability Report > Environmental Responsibility > TCFD
• CDP Climate Change 2023- C4 Targets
and Performance, C6 Emissions data

SUSTAINABILITY REPORT 2023

Alignment with the CMVM model of report for the disclosure of non-financial information

Requirement

Chapter/section
Part I - Information on the Policies adopted
Description of the Company's general policy
regarding sustainability issues, with an indication of any changes to the previously approved

A - Introduction

B – Corporate
Model

Description of the methodology and thereasons for its adoption in reporting non-financial information, as well as any changes
that may have occurred in relation to previous years and the reasons that motivatedthem.

SR 23 | Introduction > Sustainability Policy
SR 23 | Approach to Sustainability | Relation with
Stakeholders | Relation with Stakeholders > Sustainability Master Plan (SMP) 2022

SR 23 | Introduction > Sustainability Policy
SR 23 | Relation with Stakeholders > SMP - Sustainability Master Plan 2023

General description of the business modeland form of organization of the Company/Group, indicating the main businessareas and markets in which it operates (ifpossible, using organization charts,
graphics or functional tables).

SR 23 | Creation of Value

1. Identification of the main risks associatedwith the subject matter of the report andarising from the Company's activities, products, services or commercial relationships,
including, where applicable and wheneverpossible, supply chains and outsourcing.

SR 23 | Introduction > Management of ESG risks

SR 23 | Introduction > Governance Model
AR 23 | Business Model

SR 23 | Economic Responsibility and of Governance >Employees
SR 23 | Social Responsibility > Human Rights
SR 23 | Environmental Responsibility > TCFD
SR 23 | Introduction > Management of ESG risks

2. Indication of the way those risks are identified and manage d by the company.

C - Main Risk
Factors

1. Explanation on the internal functional
distribution regarding competences, including
thecorporate bodies, commissions, committees, or divisions responsible for the identification/management /monitoring of therisks.

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct > Internal
Audit
SR 23 | Introduction > Management of ESG risks
SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct > Internal
Audit
SR 23 | Environmental Responsibility > TCFD
SR 23 | Introduction > Management of ESG risks

2. Express indication of the new risks identified by the company versus what wasreported in previous years and well as of
the risks that stopped being risks.

SR 23 | Economic Responsibility and of Governance >Employees
SR 23 | Social Responsibility > Human Rights
SR 23 | Environmental Responsibility > TCFD

3. Indication and brief description of themain opportunities that are identified by
the Company in the context of the themes
object of reporting.

SR 23 | Introduction > Strategic Plan 2021/2024
SR 23 | Environmental Responsibility > TCFD

D - Implemented Policies

i. ENVIRONMENTAL
POLICIES

1. Description of the Company's strategic
objectives and the main actions
to be taken to achieve them.

SR 23 | Environmental Responsibility

2. Description of the main performance indicators defined.

SR 23 | Environmental Responsibility

3. Indication versus the previous year,of the degree of fulfilment of those objectives, at least by reference to:i. Sustainable use of resources

SR 23 | Environmental Responsibility > Sustainable
Operations

ii. Pollution and climate changes

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Requirement

Chapter/section

Pagesiii. Circular Economy and waste management
iv. Protection of biodiversity(cont.)(cont.)
Requirement

Chapter/section
Part I - Information on the Policies adopted

ii. SOCIAL
AND POLITICALPOLICIESSR 23 | Social Responsibility > Sharing and participate
SR 23 | Social Responsibility > Financial Literacy
SR 23 | Social Responsibility > Foundations Group BCP
1. Description of the Company's strategic objectives and the main actions to be taken to achievethem.

SR 23 | Economic Responsibility and of Governance >Suppliers

2. Description of the main performance indicators
defined.

SR 23 | Introduction > Sustainable Finance Disclosures(SFDR)SR 23 | Economic Responsibility and of Governance >Products and services

SR 23 | Approach to Sustainability | Relation with Stakeholders
SR 23 | Economic Responsibility and of Governance > Fiscal Policyi. SR 23 | Social Responsibility > Sharing and participate
i. SR 23 | Social Responsibility > Financial Literacy
3. Indication versus the previous year,of the degree of fulfilment of those objectives, atleast by reference to:i. SR 23 | Social Responsibility > Foundations Group BCP

i. Commitments of the company towards theCommunityiii. SR 23 | Economic Responsibility and of Governance >Products and services

ii. Outsourcing and suppliers

iv. SR 23 | Economic Responsibility and of Governance >Products and services

iii. Consumers
iv. Responsible investment
v. Stakeholders
vi. Fiscal Informationii. SR 23 | Economic Responsibility and of Governance >Suppliers

iv. SR 23 | Introduction > Sustainable Finance Disclosures (SFDR)
v. SR 23 | Approach to Sustainability | Relation with
Stakeholders
vi. SR 23 | Economic Responsibility and of Governance >Fiscal Policy

iii. EMPLOYEESAND GENDER
EQUALITYAND NONDISCRIMINATION

1. Description of the Company's strategic objectives and the main actions to be taken to achievethem.

SR 23 | Economic Responsibility and of Governance >Employees

2. Description of the main performance indicators
defined.

SR 23 | Economic Responsibility and of Governance >Employees

3. Indication versus the previous year,of the degree of fulfilment of those objectives, atleast by reference to:i. SR 23 | Economic Responsibility and of Governance >Employees

i. Office:iii. SR 23 | Social Responsibility > Benefits for Employees> Health and Safety

ii. Work organizationiii. Health and Safety

iv. SR 23 | Summary of Indicators

iv. Social Relations

SR 23 | Economic Responsibility and of Governance >Employees> Training

v. Training

IV. HUMAN
RIGHTSii. SR 23 | Social Responsibility > Foundations Group BCP

vi. Equality

vi. SR 23 | Economic Responsibility and of Governance >Employees

1. Description of the Company's strategic objectives and the main actions to be taken to achievethem.

SR 23 | Social Responsibility > Human Rights

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SUSTAINABILITY REPORT 2023

2. Description of the main defined performance indicators.

SR 23 | Social Responsibility > Human Rights

3. Indication versus the previous year,of the degree of fulfilment of those objectives, atleast by reference to:

SR 23 | Social Responsibility > Human Rights

i. Due diligence procedures

SR 23 | Table UNGP- UN Guiding Principles Reporting
Framework

ii. Measures for the Prevention of Risks
iii.
Legal
proceedingsof human rights

forviolation(cont.)(cont.)
Requirement

Chapter/section
Part I - Information on the Policies adopted

V. FIGHT
AGAINST CORRUPTION AND
BRIBERY ATTEMPTS

1. Prevention of Corruption

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct

2. Prevention of money laundering(for issuing companies subject
to this regime)

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct

3. Codes of Ethics

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct

4. Management of Conflicts of Interest

SR 23 | Economic Responsibility and of Governance > Ethics and Professional Conduct> Conflictsof Interest Policies

Part II- Information on Standards/Guidelines followed
1. IDENTIFICATION OF STANDARDS/GUIDELINES FOLLOWEDIN THEREPORTING OF NON-FINANCIAL INFORMATION

23 SR | Introduction > Sustainability Report

2. IDENTIFICATION OF THE SCOPE AND METHODOLOGY TO
CALCULATE THE INDICATORSSR 23 | Introduction > Sustainability Report

SR 23 | Introduction > Evolution of the Non-Financial Reporting

SR 23 | Methodology Note

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Table of alignment with PRB - Principles for Responsible Banking
In June 2022, Banco Comercial Português, S.A. joined the United Nations Environment Programme - Finance Initiative (UNEPFI) and subscribed the Principles for Responsible Banking (PRB). For the 2023 fiscal year, BCP Group reports its first mandatory
self-assessment template against the 6 Principles for Responsible Banking: 1. Alignment; 2. Impact and Target Setting; 3. Clientsand Customers; 4. Stakeholders; 5. Governance and Culture; 6. Transparency and Accountability.

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 (SDG), the Paris Climate Agreement andrelevant national and regional frameworks.

Business model
Describe (high-level) your bank’s business model, including the main customer segments served, types of products and services provided,
the main sectors and types of activities across the main geographies in which your bank operates or provides products and services.
Please also quantify the information by disclosing e.g. the distribution of your bank’s portfolio (%) in terms of geographies, segments (i.e.
by balance sheet and/or off-balance sheet) or by disclosing the number of customers and clients served.

Response

Links and references

The BCP Group’s decision center is in Portugal, but it is also present in the following markets: Poland,
Mozambique and China (Macau). In Angola and France (through its shareholder position in Banco
Millennium Atlântico and in Banque BCP), BCP Group holds financial participations that consolidates using
the asset consolidation method. In Portugal, it operates with the brand Millennium bcp - with the legalname of Banco Comercial Português, S.A. (BCP) - and it is currently the largest Portuguese private sectorbank. The Group operates and acts with respect for people and institutions, focusing on the clients,
pursuing a mission of excellence, trust, ethics, sustainability and responsibility. All its banking operations
develop their activity under the Millennium brand and its international presence is ensured throughrepresentation offices and/or commercial protocols.
The BCP Group conducts its banking activities and financial services in Portugal and abroad, with special
focus on Retail Banking, Corporate Banking and Private Banking business. The Group offers a vast rangeof financial products and services: current accounts, payment systems, savings and investment products,
private banking, asset management, investment banking and loans - including mortgage loans andpersonal loans - commercial banking, leasing, factoring and insurance, among others.
BCP Group in Portugal
In Portugal, Millennium bcp has 2.7 million clients and it is focused on the retail and companies’ markets,providing services to its customers in a segmented manner. The Bank makes products available tocustomers through its network of branches and digital platforms, offering a wide range of products andservices.
BCP Group in Poland
In Poland, Bank Millennium also servs about 2.8 million clients and has a well distributed network ofbranches and strong digital platforms, all supported by a modern multi-channel infrastructure, on areference service quality, with high brand recognition.
BCP Group in Mozambique
In Mozambique, the BCP Group operates through Millennium bim, a universal bank that has about 1.2
million clients. Millennium bim is the reference bank in this country, being associated with innovation,strong penetration in terms of electronic banking and capacity to attract new customers, as well as beinga reference in terms of profitability and capitalization.
BCP Group in Macau
The activity of the existing branch in Macau was expanded in 2010, through the attribution of a full license(onshore), and counts with 2 thousand and 600 Clients.
In 2023, the BCP Group reported that credit to individuals represented 61.3% of the total amount of its
loans (mortgage loans were 80.4% and personal loans were 19.6%), while credit to companies was 38.7%of the total amount of the portfolio (including activities in all geographies). For Portugal, these values were
54.6% (89.0% mortgage loans and 11.0% personal loans) and 45.4%, respectively. The main sectors inMillennium bcp’s lending portfolio are: Wholesale business (3.69%), Real estate activities (3.65%), Retail
Business (3.13%), Construction (2.71%), Financial intermediation (2.65%), Machinery, equipment andbasic metallurgical (2.50%) and Restaurants and hotels (2.50%).

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Strategy alignment
Does your corporate strategy identify and reflect sustainability as strategic priority/ies for your bank?
☒ Yes
☐ No
Please describe how your bank has aligned and/or is planning to align its strategy to be consistent with the Sustainable Development
Goals (SDGs), the Paris Climate Agreement, and relevant national and regional frameworks.
Does your bank also reference any of the following frameworks or sustainability regulatory reporting requirements in its strategic
priorities or policies to implement these?
☒ UN Guiding Principles on Business and Human Rights☒ International Labour Organization fundamental conventions☒ UN Global Compact☐ UN Declaration on the Rights of Indigenous Peoples☒ Any applicable regulatory reporting requirements on environmental risk assessments, e.g. on climate risk - please specify which ones:
Taxonomy eligibility and alignment, EBA Pillar 3☐ Any applicable regulatory reporting requirements on social risk assessments, e.g. on modern slavery - please specify which ones: -----------------------☐ None of the above

Response

Links and references

BCP Group defines sustainability as a strategic priority in its business model, strategic plan and in its
Sustainability Master Plan (SMP), which defines the bank’s sustainability strategy. The Bank is committed
to promoting a culture of environmental, social and economic responsibility, namely to fight climatechange, the preservation of natural resources, biodiversity and the environment and social inequalities,
together with the strategic goals of digital and technological innovation.
Millennium bcp’s intervention is structured through three major axes: Environment - implementation of
measures fostering a fair and inclusive transition to a decarbonized economic development model,
including the incorporation of the environmental aspect into the bank's risk models; Social - involvementwith both, the external and internal communities, to create shared value; Corporate governance integration of sustainability principles into the Bank's decision-making processes. Therefore, as an integral
part of its business model, Millennium bcp takes on the commitment to create social value by developing
actions to – and with – the various stakeholder groups, with the goal of, directly and indirectly, contributeto the economic and social development of the countries in which it operates.
The Bank includes Sustainability as one of the vectors of the “Excelling 24” Strategic Plan: Millennium bcp
is sustainability-driven, meaning that it is adapting its business model to increase positive differentiation
towards the community’s and its clients’ rising expectations on sustainability, while capturing associatedbusiness opportunities and addressing regulatory demands.
In the wake of the subscription, in 2005, of the United Nations Global Compact Principles, BCP Group also
committed to support its 10 Principles establishing a set of values in what concerns Human Rights, Labour
Conditions, Environment, Ethics and Anti-Corruption.
BCP Group is committed to align its activities with the Paris Climate Agreement and the objective oflimiting the increase in average temperature to below 1.5ºC. The Bank has signed BCSD Portugal’s
manifest “Towards COP27”, which recognizes the importance of decarbonizing economic development
models and complying with the Paris Agreement. The Bank has also signed, in 2019, the “Letter ofCommitment for Sustainable Financing” promoted by the Portuguese Government and, in 2020, the“Lisbon European Green Capital Commitment”, both national initiatives promoting sustainability goals. In
2023, the BCP Group signed the Science Based Targets initiative (SBTi) Commitment Letter, assuming thecommitment to drive sustainable growth by setting science-based emissions reduction targets.
Furthermore, the Bank acknowledges the importance of the Sustainable Development Goals (SDGs) of
the United Nations. Considering that the pursuit of these 17 objectives implies a joint effort of states andprivate entities, namely companies, the Bank assumes the commitment to work actively towards asustainable, socially inclusive and environmentally responsible development in all territories where it
operates.
At this stage, Millennium bcp has identified the following SDGs as priorities for the implementation of the2030 Agenda for Sustainable Development: (i) SDG 4 - Quality education, (ii) SDG 7 - Affordable and clean
energy, (iii) SDG 8 - Decent work and economic growth, (iv) SDG 10 - Reduced inequalities and (v) SDG 13- Climate action.

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SUSTAINABILITY REPORT 2023

Principle 2: Impact and Target Setting
We will continuously increase our positive impacts while reducing the negative impacts on, and managing the risks
to, people and environment resulting from our activities, products and services. To this end, we will set and publish
targets to the areas where we can have the most significant impacts.

2.1 Impact Analysis (Key Step 1)
Show that your bank has performed an impact analysis of its portfolio/s to identify its most significant impact areas and determine priority
areas for target-setting. The impact analysis shall be updated regularly1 and fulfil the following requirements/elements (a-d)2:a)

Scope: What is the scope of your bank’s impact analysis? Please describe which parts of the bank’s core business areas,
products/services across the main geographies that the bank operates in (as described under 1.1) have been considered in theimpact analysis. Please also describe which areas have not yet been included, and why.

Response
BCP Group has conducted an impact analysis of its Portuguese portfolio, which represents more than half of theGroup’s total business. The analysis includes the core business segments of Millennium bcp: its Retail, Business,
Corporate and Investment portfolios.

Links
and
references

The Bank used UNEP FI’s Impact Analysis tool to perform the impact assessment. The Context Module was filled in forPortugal and allowed an understanding of the country’s reality and main need areas. The Consumer Banking
Identification Module was filled in with data from the Bank’s Retail portfolio and the Institutional Banking Identification
Module was filled in twice, separately, once for the Business and Corporate portfolios and another for the Investment
portfolio of Millennium bcp. The results of each module were analyzed and overlayed to assess the priority impact
areas/topics for the Bank.
The remaining portion of BCP’s geographies are not yet assessed due to a lack of available data to perform a detailed
analysis. The BCP Group plans to expand its impact analysis to include all countries where it is active and disclose thisinformation in the future.

b)

Portfolio composition: Has your bank considered the composition of its portfolio (in %) in the analysis? Please provide proportional
composition of your portfolio globally and per geographical scopei) by sectors & industries3 for business, corporate and investment banking portfolios (i.e. sector exposure or industry breakdown in%), and/orii) by products & services and by types of customers for consumer and retail banking portfolios.

If your bank has taken another approach to determine the bank’s scale of exposure, please elaborate, to show how you have considered
where the bank’s core business/major activities lie in terms of industries or sectors.

Response
The portfolio analysis performed by Millennium bcp included its Retail banking and its Institutional banking portfolios,
which together represent 90.1% of the Bank’s total portfolio in Portugal, and are distributed according to the following
table (in net operating revenue):
Business segment

Links
and
references

Portugal

Retail Banking

62.8%

Institutional Banking

27.3%

Business Banking

63.0%

Corporate Banking

5.5%

Investment Banking

31.5%

1

That means that where the initial impact analysis has been carried out in a previous period, the information should be updated accordingly, the scope expanded as well as the quality of the impact analysis improved over time.
2

Further guidance can be found in the Interactive Guidance on impact analysis and target setting.
‘Key sectors’ relative to different impact areas, i.e. those sectors whose positive and negative impacts are particularly strong, areparticularly relevant here.
3

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Composition of Millennium bcp’s retail portfolio:
Total % of portfolio based onamounts

Total % of portfolio based on
number of customers

Current accounts

35.3%

40.7%

Savings

27.8%

11.2%

Credit

36.9%

48.1%

Credit cards

1.6%

58.8%

Consumer loans & overdraft

8.4%

17.3%

Home loans /mortgages

87.4%

7.5%

Vehicle related loans

0.5%

0.4%

Others

2.1%

16.0%

Products & services

The Business & Corporate banking portfolio of Millennium bcp includes the loans the bank has to SMEs, corporates
and multinationals. The analysis included 96.2% of total business & corporate portfolio due the limit of 50 sectors
imposed by the UNEP FI’s Impact Analysis tool. The sectoral breakdown is as follows:
Sector% outstanding amount

Manufacturing

18.5%

Wholesale and Retail Trade

16.1%

Real Estate Activities

10.9%

Financial and Insurance Activities

9.1%

Accommodation and Food Service Activities

8.8%

Construction

7.5%

Professional, Scientific and Technical Activities

7.4%

Transportation and Storage

4.2%

Electricity, Gas, Steam and Air Conditioning Supply

2.8%

Agriculture, Forestry and Fishing

2.3%

Aministrative and Support Service Activities

2.1%

Human Health and Social Work Activities

1.9%

Arts, Entertainment and Recreation

1.3%

Water Supply; Sewage, Waste Management and Remediation Activities

1.1%

Information and Communication

0.8%

Education

0.8%

Other Service Activities

0.3%

Mining and Quarrying

0.3%

For the investment banking portfolio of Millennium bcp, the analysis included only the Bank’s investments in Portugal,
specifically in Non-Financial Corporations, Financial Institutions and Sovereigns. The last one represents 68% of thisportfolio. Subsequently, the portfolio was analysed using UNEP FI’s Impact Analysis tool that, since it was limited to a
maximum of 50 NACE sectors, covered 98.2% of the defined portfolio. The sectoral breakdown is as follows:
Sector% outstanding amountPublic Administration and Defense; Compulsory Social Security

67.9%

Professional, Scientific and Technical Activities

10.0%

Financial and Insurance Activities

9.5%

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Manufacturing

4.4%

Electricity, Gas, Steam and Air Conditioning Supply

3.0%

Transportation and Storage

0.6%

Real Estate Activities

0.6%

Mining and Quarrying

0.5%

Wholesale and Retail Trade

0.5%

Water Supply, Sewerage, Waste Management and Remediation activities

0.5%

Construction

0.4%

Aministrative and Support Service Activities

0.2%

Arts, Entertainment and Recreation

0.1%

c)

Context: What are the main challenges and priorities related to sustainable development in the main countries/regions in which yourbank and/or your clients operate?4 Please describe how these have been considered, including what stakeholders you have engaged
to help inform this element of the impact analysis.

This step aims to put your bank’s portfolio impacts into the context of society’s needs.

Response

Links and references

Millennium bcp used the third version of UNEP FI’s Impact Analysis Tool to assess the main challenges andpriorities related to sustainability in Portugal, the main geography of the Bank’s activities. The Context Module
was automatically filled in for Portugal and from its results the Bank can observe that the main need areas, andrespective topics are (based on information from the statistical datasets):•

Availability, accessibility, affordability, quality of resources & services - Water, Housing and
Healthcare & Sanitation;•

Infrastructure;•

Climate stability;•

Biodiversity & Healthy ecosystems - Waterbodies and Habitat;•

Circularity - Resource intensity and Waste.

Adding to these results, the Bank considered the findings of its materiality matrix and complementary exercises
involving its stakeholders, which allowed for a more contextualized view of the exercise outcomes (for more
information refer to Principle 4: Stakeholders).

Based on these first 3 elements of an impact analysis, what positive and negative impact areas has your bank identified? Which (at leasttwo) significant impact areas did you prioritize to pursue your target setting strategy (see 2.2)5? Please disclose.

Response

Links and references

Millennium bcp filled in the UNEP FI’s Impact Analysis Tool modules as mentioned above, and reached thefollowing results:
Retail portfolio - the main potential key impact areas for this portfolio are:•(i) Availability, accessibility, affordability, quality of resources & services - potential positive andnegative impacts;•(i) Socio-economic convergence - potential positive impact;•(i) Climate stability and (ii) Circularity - potential negative impact areas.

Business & Corporate porfolios - the main potential key impact areas for the sectorial analysis of theseportfolios are:•(i) Health & Safety, (ii) Availability, accessibility, affordability, quality of resources & services, (iii)
Livelihood, (iv) Equality & Justice, (v) Strong institutions, Peace & Stability, (vi) Climate stability, (vii)
Biodiversity & Healthy ecosystems and (viii) Circularity - potential positive and negative impacts;

4

Global priorities might alternatively be considered for banks with highly diversified and international portfolios.
To prioritize the areas of most significant impact, a qualitative overlay to the quantitative analysis as described in a), b) and c) will be
important, e.g. through stakeholder engagement and further geographic contextualisation.
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SUSTAINABILITY REPORT 2023•

(i) Healthy economies and (ii) Socio-economic convergence - potential positive impact areas;•(i) Integrity & Security of person - potential negative impact area.

Investment portfolio - the main potential key impact areas for the sectorial analysis of this portfolio are:•(i) Integrity & Security of person, (ii) Health & Safety, (iii) Availability, accessibility, affordability,
quality of resources & services, (iv) Livelihood, (v) Equality & Justice, (vi) Strong institutions, Peace &Stability, (vii) Climate stability, (viii) Biodiversity & Healthy ecosystems and (ix) Circularity - potential
positive and negative impact areas;•(i) Healthy economies, (ii) Infrastructure and (iii) Socio-economic convergence - potential positive
impact areas.

These areas of environmental, social and economic positive and negative potential impacts were assessed by
the Bank, as well as each correspondent potential impact topic. The results from each portfolio were comparedand then overlayed with the results from the Context Module (main need areas for Portugal), as well asinterpreted in the context of the Bank’s activities and main strategies.
The main result of this analysis was the identification of the three main impact topics for Millennium bcp:
Climate Stability, Resource Intensity and Housing.
d)

For these (min. two prioritized impact areas): Performance measurement: Has your bank identified which sectors & industries as wellas types of customers financed or invested in are causing the strongest actual positive or negative impacts? Please describe how youassessed the performance of these, using appropriate indicators related to significant impact areas that apply to your bank’s context.
In determining priority areas for target-setting among its areas of most significant impact, you should consider the bank’s current
performance levels, i.e. qualitative and/or quantitative indicators and/or proxies of the social, economic and environmental impacts
resulting from the bank’s activities and provision of products and services. If you have identified climate and/or financial
health&inclusion as your most significant impact areas, please also refer to the applicable indicators in the Annex.
If your bank has taken another approach to assess the intensity of impact resulting from the bank’s activities and provision of products
and services, please describe this.

The outcome of this step will then also provide the baseline (incl. indicators) you can use for setting targets in two areas of most significant
impact.

Response

Links and references

Millennium bcp has assessed its performance regarding all the potential impact areas of its portfolios, while
keeping its focus on the three main impact topics prioritized by the Bank.
2023 BCP SustainabilClimate Stability

ity Report

Climate Stability has been a topic of attention for the Bank for years now, and it is one of the main focuses of
the Bank’s sustainability strategy. BCP is committed to the Paris Agreement and the objective of limiting theincrease in average temperature to below 1.5ºC. It is also committed to achieve carbon neutrality by 2030, for
its direct emissions. The results from Milllennium bcp’s exercise using the Impact Analysis Tool and a thoroughanalysis of its financed and invested sectors indicate that:•

The sectors that have the most potential negative impacts this topic are “Real estate activities” and“Construction of buildings”.

•

The sectors that have the most potential positive impacts on this topic are “Regulation of andcontribution to more efficient operation of businesses” and “Electricity, gas, steam and air
conditioning supply”.

Millennium bcp’s sustainability framework already includes a deep analysis of the Bank’s performance in several
climate-related indicators. In 2023, the Bank reduced its GHG operational emissions by 7%, for its Portuguese
activities. In Portugal, 100% of the electricity consumed comes from renewable sources, 10.5% of the fleet isalready electric or hybrid and this number is expected to rise in the next years. In 2022, Millennium bcp built its
second photovoltaic plant in Portugal and in 2023 had approved the project to start building the third one.
The Bank has also established a Green, Social and Sustainability Bond Framework. Regarding the sectors it
finances, Millennium bcp has a list of projects and sectors excluded from or with conditioned access to credit
due to their environmental impacts (e.g., coal energy production).
Resource Intensity
Regarding the impact topic “Resource Intensity”, the results from the Impact Analysis Tool reveal that:•

The sectors that have the most potential negative impacts this topic are also “Real estate activities”
and “Construction of buildings”.

•

The sectors that have the most potential positive impacts on this topic are “Regulation of andcontribution to more efficient operation of businesses” and “Retail trade, except of motor vehicles
and motorcycles”.

The dematerialization of operations has been one of the main priorities of the Bank in the past years. Millennium
bcp monitors the levels of resource use of its own activities and has a list of projects and sectors excluded fromcredit for not complying with environmental requirements (e.g., coal mining, oil exploration and companies and251

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SUSTAINABILITY REPORT 2023

activities related to wood extraction and commercialization derived from protected areas in native tropicalforests).
Regarding the Bank’s own operations, there has been a reduction of printing, as well as of water and materials’
consumption. In the last five years, the Bank reduced the water consumption from its own operations by 42%
and reduced the use of materials by 44% (-45% use of cardboard/paper and -64% use of ink cartridges andtoners). The Bank has also eliminated the use of single-use plastics.
Housing
Housing is a topic of significant concern for the Bank, as it is associated with the most relevant share of thecredit it provides to consumers. Millennium bcp’s portfolio impact analysis’ results show that “Home loans/mortgages” is a product with key positive impact in the topic “Housing” and represents 87% of Millennium
bcp’s Retail Banking credit. From this value, 17% is associated with houses that have an energy classification of
A+, A or B. Millennium bcp offers special credit conditions to housing with energy classification of A+, A and B..
The Bank has launched housing related consumer loans to promote the energy efficiency of properties, as well
as a green real estate promotion product.
The Bank adopted, in the name of transparency in its relationship with customers, the voluntary code of conduct
adopted by European Consumer Associations about on time information to be provided in the context ofmortgage credit contracts.
In social terms, the Bank also provides special conditions of mortgage loans to its employees.

Self-assessment summary:Which of the following components of impact analysis has your bank completed, in order to identify the areas in which your bank has
its most significant (potential) positive and negative impacts?6
Scope:☒ Yes☐ In progress☐ No

Portfolio composition:☒ Yes☐ In progress☐ No

Context:☒ Yes☐ In progress☐ No

Performance measurement:☒ Yes☐ In progress☐ No

Which most significant impact areas have you identified for your bank, as a result of the impact analysis?
Climate Stability, Resource Intensity and Housing
How recent is the data used for and disclosed in the impact analysis?
☐

Up to 6 months prior to publication☐

Up to 12 months prior to publication☒

Up to 18 months prior to publication☐

Longer than 18 months prior to publication

Open text field to describe potential challenges, aspects not covered by the above etc.: (optional)

6

You can respond “Yes” to a question if you have completed one of the described steps, e.g. the initial impact analysis has been carriedout, a pilot has been conducted.

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2.2 Target Setting (Key Step 2)
Show that your bank has set and published a minimum of two targets which address at least two different areas of most significant impactthat you identified in your impact analysis.
The targets1 have to be Specific, Measurable (qualitative or quantitative), Achievable, Relevant and Time-bound (SMART). Please disclose
the following elements of target setting (a-d), for each target separately:a)Alignment: which international, regional or national policy frameworks to align your bank’s portfolio with2 have you identified as
relevant? Show that the selected indicators and targets are linked to and drive alignment with and greater contribution toappropriate Sustainable Development Goals, the goals of the Paris Agreement, and other relevant international, national or regionalframeworks.
You can build upon the context items under 2.1.

Response

Links and references

Millennium bcp subscribed two documents “Guidelines to accelerate sustainable finance in Portugal”
and “Engagement Letter for the Sustainable Funding in Portugal”, issued within the scope of the “Thinktank on Sustainable Finance in Portugal”, promoted by the Ministries of Environment, Finances andEconomy in the context of the Portuguese “Route to Carbon Neutrality” in 2050. The Bank also
subscribed the "Lisbon European Green Capital Commitment", promoted by CML (Lisbon City Council),
as a commitment to promote climate action and sustainability, to meet the targets set by the Paris
Agreement and accelerate the path to carbon neutrality.
In 2022, and within the framework of the initiatives promoted by BCSD Portugal, Millennium bcp
subscribed the manifesto "Towards COP27" 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, signing also the manifesto "For an Agreement at COP15", noting in this case the urgency of
adopting a Global Biodiversity Strategy to stop the loss of biodiversity by 2030 and promote the recoveryof natural ecosystems.
The sustainability-related targets already established by the Bank are in alignment with theseframeworks and committments, as well as with the Sustainable Development Goals (SDG) associatedwith each impact topic: SDG 13 - Climate Action (Climate Stability), SDG 12 - Responsible Consumption
and Production (Resource Intensity) and SDG 11 - Sustainable Cities and Communities (Housing).

b)Baseline: Have you determined a baseline for selected indicators and assessed the current level of alignment? Please disclose theindicators used as well as the year of the baseline.
You can build upon the performance measurement undertaken in 2.1 to determine the baseline for your target.
A package of indicators has been developed for climate change mitigation and financial health & inclusion to guide and support
banks in their target setting and implementation journey. The overview of indicators can be found in the Annex of this template.
If your bank has prioritized climate mitigation and/or financial health & inclusion as (one of) your most significant impact areas, it
is strongly recommended to report on the indicators in the Annex, using an overview table like below including the impact area, allrelevant indicators and the corresponding indicator codes:
Impact area

Indicator code

Response…
Climate change
mitigation…
…

Impact area

Indicator code

Financial health &inclusion…

Response…
…

In case you have identified other and/or additional indicators as relevant to determine the baseline and assess the level of alignment
towards impact driven targets, please disclose these.

Response

Links and references

Millennium bcp is currently working on the development of SMART targets for each of the three mostsignificant impact topics chosen by the Bank and following UNEP FI’s guidelines on target setting.
The current indicators being used to assess the Bank’s performance on these topics and respective
baseline values are:Climate stability

GHG Emissions (Scope 1): 2,205 tCO2e (2023)



GHG Emissions (Scope 2): 0 tCO2e (2023)



Share of fleet that is hybrid/electric: 10.5% (2023)

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Green project finance: 38.3% (2023)

Impact area

Indicator code

Climatechange mitigation

Response

A.1.1(Climate strategy)Yes

A.1.2 (Paris alignment target)

In progress. – The Bank is committed to the Paris
Agreement and the objective of limiting the increase in average temperature to below 1.5ºC. It isalso committed to achieve carbon neutrality by
2030, for its direct emissions.

A.1.5 (Business opportunities and financial products)

Yes. Examples of these products include: Green
mortgage loans; Loans, leasing and renting promoting electric mobility; Renewable energy consumer
loans; Decarbonisation and Circular Economy Credit
Line; Green Real Estate Promotion Credit; ESG/SRI
investment funds.

Resource intensity
Water consumption: 106,387 m3 (2023)

Materials consumption: 680 t (2023)



Share of credit to houses with energy certifications of A+, A or B: 8.9% (2023)

Housingc)

SMART targets (incl. key performance indicators (KPIs)3): Please disclose the targets for your first and your second area of mostsignificant impact, if already in place (as well as further impact areas, if in place). Which KPIs are you using to monitor progress
towards reaching the target? Please disclose.

Response

Links and references

Millennium bcp is currently working on the development of SMART targets for each of the three mostsignificant impact topics chosen by the Bank and following UNEP FI’s guidelines on target setting.
The current targets established by the Bank are:Climate stabilityCarbon neutrality of direct emissions by 2030 (Portugal);



-



Set alignment targets (Scope 1, 2 and 3) according to SBTi;

Fleet with 80% hybrid/electric cars by 2030;



>50% reduction in exposure to coal and petroleum products;

>50% Green project finance;

Increase of sustainability-linked bonds (SLBs) and ESG bond issuance.

Resource intensity
Implement solutions to enable the re-use of water;Limit increase in water consumption to 2% in 2024;

1

Operational targets (relating to for example water consumption in office buildings, gender equality on the bank’s management board
or business-trip related greenhouse gas emissions) are not in scope of the PRB.
2Your bank should consider the main challenges and priorities in terms of sustainable development in your main country/ies of operation for the purpose of setting targets. These can be found in National Development Plans and strategies, international goals such as
the SDGs or the Paris Climate Agreement, and regional frameworks. Aligning means there should be a clear link between the bank’s
targets and these frameworks and priorities, therefore showing how the target supports and drives contributions to the national andglobal goals.
3
Key Performance Indicators are chosen indicators by the bank for the purpose of monitoring progress towards targets.

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SUSTAINABILITY REPORT 2023



Decrease materials consumption by 7% in 2024.



Align the requirements for housing credit with the EU’s Energy Performance of Buildings
Directive, by introducing minimum standards based on the energy performance of new
and existing buildings and promoting renovations for energy efficiency improvement.

Housingd)Action plan: which actions including milestones have you defined to meet the set targets? Please describe.
Please also show that your bank has analysed and acknowledged significant (potential) indirect impacts of the set targets within
the impact area or on other impact areas and that it has set out relevant actions to avoid, mitigate, or compensate potential negative
impacts.

Response

Links and references

Millennium bcp has developed a Sustainability Master Plan which defines, aligned with the strategy, theactions and initiatives to achieve its environmental, social and governance goals and targets. Within thescope of those goals, the Bank aims to rationalize and improve its consumption profile, namely energy,
water and materials, mainly based on a logic of dematerializing processes and preserving natural resources.
Millennium bcp in 2024 will begin the construction, approved in 2023, of its third solar power plant. As aneffort to reduce Scope 1 emissions, the Bank promotes a bus transport service between Tagus and Lisbon,
as well as a hybrid way of working (option to work from home some days of the week) to reduce emissions
from transportation. Practices such as the reduction of local printing and the digitalisation of incoming
processes, with operations being opened directly in the systems and applications, contribute to a decreaseof materials consumption.

Principles of Responsible
Financing

The Bank also plans to continue increasing the offer of mortgage loans that promote sustainable living
standards.
Within the scope of Millennium bcp’s lending portfolio, the Bank seeks to increase the percentage offunding for environmentally sustainable projects and organisations, having published in 2021 the Principles
for Responsible Financing that identify, among other aspects, the excluded projects and sectors/projects
constrained in the scope of the financing policy promoted by the Bank. Included in the scope of financed
sustainable activities are Wind, Hydro, Solar and Biomass, as well as the financing of investments in urban
waste collection and treatment plants, in drinking water distribution and wastewater treatment networks(ETAR, in Portuguese), waste treatment plants, among others.

Self-assessment summary
Which of the following components of target setting in line with the PRB requirements has your bank completed or is currently in aprocess of assessing for your…

Alignment

Baseline

SMART targets

Action plan

First area of most significant
impact: Climate Stability

Second area of most significant impact: Resource Intensity

Third area of impact: Housing

☐ Yes

☐ Yes

☐ Yes

☒ In progress☒ In progress☒ In progress

☐ No

☐ No

☐ No

☐ Yes

☐ Yes

☐ Yes

☒ In progress☒ In progress☒ In progress

☐ No

☐ No

☐ No

☐ Yes

☐ Yes

☐ Yes

☒ In progress☒ In progress☒ In progress

☐ No

☐ No

☐ No

☐ Yes

☐ Yes

☐ Yes

☒ In progress☒ In progress☒ In progress

☐ No

☐ No

☐ No

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2.3 Target implementation and monitoring (Key Step 2)
For each target separately:Show that your bank has implemented the actions it had previously defined to meet the set target.
Report on your bank’s progress since the last report towards achieving each of the set targets and the impact your progress resulted in, using
the indicators and KPIs to monitor progress you have defined under 2.2.
Or, in case of changes to implementation plans (relevant for 2nd and subsequent reports only): describe the potential changes (changes
to priority impact areas, changes to indicators, acceleration/review of targets, introduction of new milestones or revisions of action plans)and explain why those changes have become necessary.

Response

Links and references

Millennium bcp has been gradually implementing the measures defined in its Sustainability Master
Plan (SMP), as well as keeping track of its environmental, social and governance committments. This
constitutes the first mandatory report published by the BCP Group - after the voluntary one publishedin the Sustainability Report 2022 - and, as previously mentioned, the Bank is still working on thedevelopment of SMART targets for each of the three most significant impact topics, following UNEP
FI’s guidelines on target setting. Millennium bcp plans to disclose detailed information on thesetargets implementation and monitoring in following reports.

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SUSTAINABILITY REPORT 2023

Principle 3: Clients and Customers
We 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 Client engagement
Does your bank have a policy or engagement process with clients and customers4 in place to encourage sustainable practices?
☒ Yes☐ In progress☐ No

Does your bank have a policy for sectors in which you have identified the highest (potential) negative impacts?
☒ Yes☐ In progress☐ No

Describe how your bank has worked with and/or is planning to work with its clients and customers to encourage sustainable practices
and enable sustainable economic activities5. It should include information on relevant policies, actions planned/implemented to supportclients’ transition, selected indicators on client engagement and, where possible, the impacts achieved.
This should be based on and in line with the impact analysis, target-setting and action plans put in place by the bank (see P2).

Response

Links and references

The BCP Group places sustainability and ethical, inclusive and responsible business practices as cardinalpoints in the cartography of its values and corporate culture, focusing on its clients and working together
with them to create lasting and consistent social value, while protecting the environment, the climate
and biodiversity.

Code of Conduct

The Group’s Code of Conduct is applicable to all of the Bank’s business divisions and geographies, and it
ensures that the Bank treats its clients and customers responsibly and with integrity at all times. BCP
Group works to offer a quality service to customers, increasingly digital and with high levels of security.
The Bank is also certified by laws and regulations like the MiFID II, which ensure that the Bank follows
the required processes and control mechanisms and helps identify issues and action areas.
Every two years, the Bank performs a Stakeholder consultation process, which includes representative
samples of its (i) Shareholders; (ii) Customers; (iii) Employees; (iv) Community; (v) Suppliers and (vi)Media. This exercise allows the Bank to understand its Customers’ perception of the significance of theBank's impacts, but also their main needs and expectations regarding the organisation's performance interms of sustainability. This consultation contributes to the (re)definition of material issues forMillennium bcp, reflected in the Materiality Matrix and the Sustainability Master Plan. This Planaddresses the following customer-related dimensions and respective action lines:Service quality and Customer satisfaction: optimise satisfaction levels;



Raising awareness and informing Customers on products and services: integrate aspects ofsustainability of the proposed investments into communication with Customers;

Offering inclusive and sustainable products: Reinforce the Sustainable/ESG products andservices’ offer that promotes the transition of the economy towards a sustainable model.

Customer Charter
2023 BCP Sustainability Report
2023 BCP Annual Report

The BCP Group is constantly seeking to be near its Customers by means of diversified distribution
channels to adequately respond to the contact needs between the Customer and the Bank. As part of its
social commitment, the Bank promotes accessibility for people with special needs to its various contact
channels.
BCP uses its different platforms to communicate with its Clients and Customers about sustainabilityrelated topics, including its available Sustainable/ESG products.

4

A client engagement process is a process of supporting clients towards transitioning their business models in line with sustainability
goals by strategically accompanying them through a variety of customer relationship channels.
5

Sustainable economic activities promote the transition to a low-carbon, more resource-efficient and sustainable economy.

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3.2 Business opportunities
Describe what strategic business opportunities in relation to the increase of positive and the reduction of negative impacts your bank has
identified and/or how you have worked on these in the reporting period. Provide information on existing products and services,
information on sustainable products developed in terms of value (USD or local currency) and/or as a % of your portfolio, and which SDGs
or impact areas you are striving to make a positive impact on (e.g. green mortgages – climate, social bonds – financial inclusion, etc.).

Response

Links and references

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. The Bankis also aware that the implementation of social and environmental criteria and standards in thecommercial offer is reflected in more efficient risk management, reputation value and higher qualityof the products and services offered to Customers, meeting the needs and ambitions of a market
increasingly concerned with sustainability.
ActivoBank, held by Millennium bcp and part of BCP Group in Portugal, also has a financing strategy
adjusted to the needs of its Customers, with adjusted pricing for loans based on choices that addressenvironmental issues, thus seeking to encourage Customers to make more sustainable choices within
their consumption projects.
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, the consideration of
Sustainability/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 BCP Group’s commitment to sustainability, promoting the necessarychanges for the development of a fair, inclusive and decarbonized future.
BCP Group in Portugal
In 2021, Millennium bcp established its Green, Social and Sustainability Bond Framework, aiming tofinance projects that lead to important and positive environmental and social effects, within the scopeof the UN’s SDGs 1, 4, 7, 8, 10 and 13. The Bank also provides the following products with ESG criteria:
Green mortgage loans; Loans, leasing and renting promoting electric mobility; Renewable energy
consumer loans; Decarbonisation and Circular Economy Credit Line; Green Real Estate Promotion
Credit; ESG/SRI investment funds.
The Bank seeks to increase the prevalence of funding for environmentally sustainable projects andorganisations, having published in 2021 the Principles for Responsible Financing that identify, among
other aspects, the excluded projects and sectors/projects constrained in the scope of the financing
promoted by the Bank. In 2023 the percentage of 'green' financing in the total project finance portfolio
was 38.3%.
BCP Group in MozambiqueMillennium bim has developed Smart IZI, a totally digital service, in the form of a Mobile Banking
application, through which individual Customers can obtain information and submit operations
wherever and whenever they need (including subscription, registration and use). 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 alongwith IZI’s other functionalities, the Bank has contributed to resource savings and a reduction ofnegative environmental impacts, while improving accessibility to the Bank’s services.
BCP Group in Poland
Bank Millennium launched the strategic EU green finance project, under which it prepared productand process infrastructures to effectively support businesses in their sustainable development,
implementation of green investments and energy transition. This contributed to projects such as:
Millennium TFI Funds; WWF Millennium Mastercard credit card; Biznesmax Guarantee Programme;
Mój Elektryk programme; Green loans for photovoltaic projects.
A few years ago, the Bank decided to significantly reduce its exposure to the coal industry and not tofinanc new projects, with these constraints expressed in the Environmental Policy.

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2023 BCP Annual Report

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Principle 4: Stakeholders
We will proactively and responsibly consult, engage and partner with relevant stakeholders to achieve society’s
goals.

4.1 Stakeholder identification and consultation
Does your bank have a process to identify and regularly consult, engage, collaborate and partner with stakeholders (or stakeholder
groups6) you have identified as relevant in relation to the impact analysis and target setting process?
☒ Yes☐ In progress☐ No

Please describe which stakeholders (or groups/types of stakeholders) you have identified, consulted, engaged, collaborated or partneredwith for the purpose of implementing the Principles and improving your bank’s impacts. This should include a high-level overview of how
your bank has identified relevant stakeholders, what issues were addressed/results achieved and how they fed into the action planning
process.

Response

Links and references

The 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 expectationsof its Stakeholders.

2023 BCP Sustainability Report

Every two years, Millennium bcp performs a Stakeholder consultation. This process involves, througha representative sampling, the main interested parties, namely: (i) Shareholders; (ii) Customers; (iii)
Employees; (iv) Community; (v) Suppliers and (vi) Media, in an exercise that allows to understandtheir 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. This consultation contributes tothe (re)definition of material issues for the Bank, reflected in the Materialty Matrix and theSustainability Master Plan.

(Chapter: Relation with Stakeholders)

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.
This exercise resulted, among the 22 subjects under assessment, in a list of 12 material subjects,
reviewed and approved by the Executive Committee of BCP to guide the development of plans andstrategies with an impact on the Bank's future action. The 12 material subjects were:

Cyber-security, privacy and information protection;

Innovation and digitalization;

Ethics, conduct and compliance;Anti-corruption and anti-money laundering;Transparency of the information provided to Customers on products and services;

Sustainability Governance;Resilience of the business model;



Risk management;Satisfaction and Customer experience;

Brand management and reputation;



Economic performance;

Attracting, developing and retaining talent.

The identification and continuous monitoring of the subjects considered material - the most recent
performed in 2022/2023 - has made it possible to identify the areas of action that should berecognised as a priority for the Bank in the field of Sustainability and has also made it possible toidentify and characterise opportunities for improvement, making a strong contribution to adapting
the Sustainability strategy to new realities, challenges and requirements.

6

Such as regulators, investors, governments, suppliers, customers and clients, academia, civil society institutions, communities, representatives of indigenous population and non-profit organizations

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SUSTAINABILITY REPORT 2023

Principle 5: Governance & Culture
We will implement our commitment to these Principles through effective governance and a culture of responsiblebanking.

5.1 Governance Structure for Implementation of the Principles
Does your bank have a governance system in place that incorporates the PRB?
☒ Yes

☐ In progress☐ No

Please describe the relevant governance structures, policies and procedures your bank has in place/is planning to put in place to manage
significant positive and negative (potential) impacts and support the effective implementation of the Principles. This includes informationabout

which committee has responsibility over the sustainability strategy as well as targets approval and monitoring (including
information about the highest level of governance the PRB is subjected to),

details about the chair of the committee and the process and frequency for the board having oversight of PRB implementation(including remedial action in the event of targets or milestones not being achieved or unexpected negative impacts being
detected), as well asremuneration practices linked to sustainability targets.

Response
Under the Sustainability Master Plan (SMP), BCP has been reviewing and improving its governance model for
Sustainability and Responsible Business.
In this context, in 2020, it created the Sustainability Commission (SC), a body dependent on the Executive
Committee (ExCo) and chaired by the Chief Executive Officer (CEO), which is responsible for assessing,following up and monitoring the implementation of the Bank’s Sustainability strategy - which includes the
economic, social, environmental and climate change dimensions - having, specifically, the following tasks:

Links
referencesand2023 BCP Sustainability ReportTo advise the ExCo in the integration of Sustainability principles (Environmental, Social andCorporate Governance) in the Bank's decision-making and management processes;

2023 Corporate Governance ReportTo analyse and approve the initiatives necessary for the implementation of actions aimed atmaterialising 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;

Remuneration Policies

To supervise and monitor 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 performanceindicators 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) were also approved, thebody 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 formonitoring 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) 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 BoD 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 forestablishing an internal control system of, translated into a set of strategies, policies, processes, systems andprocedures with the aim of ensuring the medium and long-term sustainability of the institution and theprudent exercise of its activity and ensuring that it is applied consistently in all the Bank's subsidiaries andbranches, in Portugal or in international operations.
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 overall 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 thecreation, of situations of conflict of interest and, through those rules and alignment, contributing to the ethicaland sustainable development of the Company. These rules are detailed in the Remuneration Policies of theemployees 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 underconsideration is the execution level of the Sustainability Master Plan (SMP).

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5.2 Promoting a culture of responsible banking
Describe the initiatives and measures of your bank to foster a culture of responsible banking among its employees (e.g., capacity building,e-learning, sustainability trainings for client-facing roles, inclusion in remuneration structures and performance management andleadership communication, amongst others).

Response

Links and references

BCP’s Code of Conduct guarantees that the entities of the Group and the members of its Management andSupervisory bodies, as well as its employees, guide their actions on principles of respect for people's rights,
of preservation of social and environmental sustainability and of culture and institutional values,committing themselves to behave in an upstanding and honest manner in all relations they establish
among themselves, with customers, or any other person or entity with whom they relate. This Code of
Conduct enshrines the main values and behaviour standards and corporate responsibility to be observedby all the companies part of the BCP Group and enumerates the preventive measures aimed at preventing
discrimination and harassment in the workplace. The BCP Group has also in place an Anti-Corruption andAnti-Bribery Policy.

Code of Conduct
Anti-corruption and Antibribery Policy(v. 2023)

In 2021, in order to promote the bank’s commitment to reinforce training in Sustainable Financing directed
to its employees at the different levels of the organisation, Millennium bcp held an universal training on
Sustainability in Portugal, which is now part of the courses given to new employees (5,815 employees in
2021, 509 in 2022 and 213 in 2023).
In 2022, and to ensure that the Board of Directors has sufficient knowledge to effectively manage
sustainability issues, 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.
The development of the personal and professional competences of the employees is one of the Bank's
priorities considering the need to ensure its ongoing alignment with the strategic goals defined by theorganization. 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.

5.3 Policies and due diligence processes
Does your bank have policies in place that address environmental and social risks within your portfolio?7 Please describe.
Please describe what due diligence processes your bank has installed to identify and manage environmental and social risks associatedwith your portfolio. This can include aspects such as identification of significant/salient risks, environmental and social risks mitigationand definition of action plans, monitoring and reporting on risks and any existing grievance mechanism, as well as the governancestructures you have in place to oversee these risks.

Response

Links and references

BCP has an annual process to identify, assess and manage more than 60 types of risks. ESG risk drivers,
which have acquired growing relevance within the scope of the Bank's activity - both due to thedensification of the legal, regulatory and supervisory framework and requirements, and to the deepeningof good practices in risk management - are part of this process.

2023 BCP Sustainability
Report

The Risk Officer annually leads the risk identification and assessment process, with support from otherGroup divisions. The process consists of a self-assessment exercise of the risks impacts to the BCP Groupand 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.
The risk management process has been adapted in a manner consistent with the strategic priority givenby the Bank to ESG matters, which is reflected in its Strategic Plan “Excelling 24”.
Additionally, the Bank developed its first climate and environmental materiality assessment, thus
deepening the understanding of these factors' impacts on the Group's activities, and integrating it in thedefinition of actions and decision-making for its management and mitigation, and in the identification ofbusiness opportunities that emerge from the dynamics of transition to a low carbon economy.

2023 Market Discipline
Report“Excelling 24” StrategicPlan

BCP Group priorities and ambitions regarding social and environmental risks are also addressed in its
Sustainability Master Plan 2023, in particular in the risk management dimension, with lines of action andmeasures very directly related to the approach to risks and their integration in the business, among which
the following stand out:

7

Applicable examples of types of policies are: exclusion policies for certain sectors/activities; zero-deforestation policies; zero-tolerance
policies; gender-related policies; social due diligence policies; stakeholder engagement policies; whistle-blower policies etc., or any applicable national guidelines related to social risks.

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SUSTAINABILITY REPORT 2023

assess the impact of climate and environmental factors on the different risk typologies;

establish processes for monitoring the evolution of the climate and environmental risk factors;develop a management and control framework for climate and environmental risk factors,
including the definition of a governance model;



implement the capacity for climate stress tests.

Self-assessment summary:
Does the CEO or other C-suite officers have regular oversight over the implementation of the Principles through the bank’s governancesystem?
☒ Yes

☐ No

Does the governance system entail structures to oversee PRB implementation (e.g. incl. impact analysis and target setting, actions toachieve these targets and processes of remedial action in the event targets/milestones are not achieved or unexpected neg. impacts aredetected)?
☒ Yes

☐ No

Does your bank have measures in place to promote a culture of sustainability among employees (as described in 5.2)?
☒ Yes☐ In progress

☐ No

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Principle 6: Transparency & Accountability
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.

6.1 Assurance
Has this publicly disclosed information on your PRB commitments been assured by an independent assurer?
☐ Yes☐ Partially☒ No

If applicable, please include the link or description of the assurance statement.

Response

Links and references

6.2 Reporting on other frameworks
Does your bank disclose sustainability information in any of the listed below standards and frameworks?
☒

GRI

☒

SASB

☒

CDP

☐

IFRS Sustainability Disclosure Standards (to be published)

☒

TCFD

☒

Other: UNGP

Response

Links and references

6.3 Outlook
What are the next steps your bank will undertake in next 12 month-reporting period (particularly on impact analysis8, target setting9 andgovernance structure for implementing the PRB)? Please describe briefly.

Response

Links and references

Millennium bcp plans to continue the analysis of its portfolio, utilizing the Assessment
Module of the UNEP FI’s Impact Analysis Tool and setting targets for its three prioritized
impact topics. The Bank will continue to work on improving and implementing its
sustainability strategy and achieve the established sustainability targets, while
continuing to focus on its alignment with the Paris Agreement, the UN’s SDGs, and thePrinciples for Responsible Banking. The Bank is also currently working on its responseto the new requirements arising from the CSRD.

8

For example outlining plans for increasing the scope by including areas that have not yet been covered, or planned steps in terms of
portfolio composition, context and performance measurement
9

For example outlining plans for baseline measurement, developing targets for (more) impact areas, setting interim targets, developing
action plans etc.

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6.4 Challenges
Here is a short section to find out about challenges your bank is possibly facing regarding the implementation of the Principles for
Responsible Banking. Your feedback will be helpful to contextualise the collective progress of PRB signatory banks.
What challenges have you prioritized to address when implementing the Principles for Responsible Banking? Please choose what you
consider the top three challenges your bank has prioritized to address in the last 12 months (optional question).
If desired, you can elaborate on challenges and how you are tackling these:☐ Embedding PRB oversight into governance☐ Customer engagement☐ Gaining or maintaining momentum in the bank

☐ Stakeholder engagement☐ Getting started: where to start and what to focus on in the
beginning☒ Data availability☒ Conducting an impact analysis☐ Access to resources☐ Assessing negative environmental and social impacts☐ Choosing the right performance measurement methodology/ies☐ Setting targets☐ Other: …

☒ Data quality☐ Reporting☐ Assurance☐ Prioritizing actions internallyIf desired, you can elaborate on challenges and how you are tackling these:264

SUSTAINABILITY REPORT 2023

Table of alignment with the CSRD (Corporate Sustainability Reporting Directive) and ESRS(European Sustainability Reporting Standards)
This exercise is the result of the analysis between the information presented in this Report and the requirements arising fromthe European Sustainability Reporting Standards (ESRS).

C ORRESPONDENCE TABLE BETWEEN THE M ILLENNIUM BCP M ATERIAL T HEMES AND THE ESRS T HEMESBCP Material Issues

ESRS thematic

Attracting, developing and retaining
talentESRS S1 Own workforce

ESRS Sub theme
Work Conditions
Equal treatment and opportunities for all

ESRS S4 Final consumers and users

Information-related impacts for consumers and/or
end-users

Transparency of the information
provided to customers about products and services
Customer satisfaction and experience

Ethics, conduct and compliance

ESRS S4 Final consumers and users

Information-related impacts for consumers and/or
end-users
Business Culture
Protection of whistle-blowers
Political context and lobbying activities

ESRS G1 Business Conduct
Managing supplier relationships, including payment
practices

Prevention of corruption andmoney laundering
Cyber-security, privacy and information protection
Innovation and digitalisation
Sustainability Governance
Resilience of the business model
Risk management
Management of the brand and reputation
Economic performance

ESRS G1 Business Conduct

Corruption and bribery

No match-

No match
No match
No match
No match-

No match-

No match-

D ISCLOSURE REQUIREMENTS
Disclosure requirements

Title

Contents, page or link

1. GENERAL INFORMATIONESRS 2: GENERAL DISCLOSURE
BASE OF PREPARATION
23 SR | Introduction > Sustainability Report
23 SR | Economic and Governance Responsibility
BP-1

General basis for the preparation of sustainability
statements

AR23 AR | Regulatory information > Consolidated financial statements
SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Introduction > Sustainability Report

BP-2

Disclosures in relation to specific circumstances

SR 23 | Methodological Note

GOVERNANCE

GOV-1

The role played by the management and supervisory bodies;

Governance structure and its composition > Section II- Part B. Corporate bodies and Committees
SR 23 | Introduction > Governance Model
SR 23 | Summary of Indicators

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SR 23 | Introduction > Governance Model

GOV-2

Information provided and sustainability issues addressed by the company's management and supervisory bodies

SR 23 | GRI Table > GRI 2-13
SR 23 | GRI Table > GRI 2-16
SR 23 | GRI Table > GRI 2-24
III. Economic and Governance Responsibility > Ethics
and Professional Conduct

GOV-3

Integration of sustainability performance into incentive schemes

Corporate Governance Report > Section III - Part D.
Remunerations

GOV-4

Declaration on diligence duty

SR 23 | Introduction > Governance Model

GOV-5

Risk management and internal controls for sustainability reporting

SR 23 | Introduction > Governance Model

STRATEGY
SR 23 | Creation of ValueSR 23 | Summary of Indicators
SBM-1

SR 23 | Economic and Governance Accountability >Products and Services

Strategy, business model and value chain

SR 23 | Economic Responsibility and of Governance >Suppliers
SR 23 | Economic Responsibility and of Governance>Employees
SR 23 | Introduction > Strategic Plan
SBM-2

SR 23 | Introduction > Governance Model

Stakeholder interests and views

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Introduction > Management of ESG risks

SBM-3

Material impacts, risks and opportunities andtheir interaction with strategy and businessmodel

23 SR | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
RS 23 | Environmental Responsibility > Climate & Environmental Materiality Assessment

SR 23 | Environmental Responsibility > Task Force on
Climate-related Financial Disclosures (TCFD)
MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES
IRO-1

IRO-2

Description of the processes for identifying andassessing material impacts, risks and opportunities

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis

Disclosure requirements contained in ESRS covered by the company's sustainability statement

SR 23 | ESRS Table

3. ENVIRONMENTAL INFORMATIONESRS E1: CLIMATE CHANGES10
GOVERNANCEESRS 2 GOV-3

Integration of sustainability performance into incentive schemes

Corporate Governance Report > Section III - Part D.
Remunerations
SR 23 | Environmental Responsibility > Task Force on
Climate-related Financial Disclosures (TCFD)

10 As it is a potentially material topic and on which the regulator has a special focus of monitoring, the BCP Group chooses to report

information regarding Climate Change.
.

266

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STRATEGY

E1-1

SR 23 | Environmental Responsibility > De-carbonisation

Climate change mitigation transition plan

SR 23 | Environmental Responsibility > Task Force on
Climate-related Financial Disclosures (TCFD)
SR 23 | Introduction > Strategic Plan 2021/2024

ESRS 2 SBM-3

Material impacts, risks and opportunities andtheir interaction with strategy and businessmodel

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Environmental Responsibility > Climate & Environmental Materiality Assessment
SR 23 | Environmental Responsibility > Task Force on
Climate-related Financial Disclosures (TCFD)

MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIESSR 23 | Introduction > Management of ESG risks

ESRS 2 IRO-1

Description to the processes for identifying andassessing material impacts, risks, and opportunities climate-related

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Environmental Responsibility > Climate Materiality Assessment
23 SR | Environmental Responsibility > Task Force on
Climate-related Financial Disclosures (TCFD)

E1-2

Policies related to climate change mitigation andadaptation

SR 23 | Introduction > Governance Model
SR 23 | Environmental Responsibility
SR 23 | Environmental Responsibility > Sustainable Operations

E1-3

Actions and resources related to climate change
policies

SR 23 | Environmental Responsibility > De-carbonisation
23 SR | Environmental Responsibility > Energy Efficiency
SR 23 | Environmental Responsibility > Task Force on
Climate-related Financial Disclosures (TCFD)METRICS AND TARGETS
23 SR | Approach to sustainability| Relation with
Stakeholders > SMP - Sustainability Master Plan
SR 23 | Environmental Responsibility > Sustainable Operations
E1-4

Targets related to climate change mitigation andadaptation

SR 23 | Environmental Responsibility > De-carbonisation
SR 23 | Environmental Responsibility > Energy Efficiency
SR 23 | Environmental Responsibility > Task Force on
Climate-related Financial Disclosures (TCFD)

E1-5

E1-6

E1-7
E1-8

E1-9

Power consumption and energy combination

SR 23 | Environmental Responsibility > Sustainable Operations
SR 23 | Environmental Responsibility > Energy Efficiency

Gross Scope 1, 2, 3 GHG emissions and total GHG
emissions

SR 23 | Environmental Responsibility > Sustainable Operations
SR 23 | Environmental Responsibility > De-carbonisation

GHG removal and GHG mitigation projects financed through carbon credits

Currently, the Bank does not have information to respond to the indicator.

Internal carbon pricing

Currently, the Bank does not have information to respond to the indicator.

Anticipated financial effects of material, physicaland transition risks and potential climate-related
opportunities

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis

267

SR 23 | Environmental Responsibility > Task Force on
Climate-related Financial Disclosures (TCFD)

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3. SOCIAL INFORMATIONESRS S1: OWN WORKFORCESTRATEGY
SR 23 | Introduction > Strategic Plan 2021/2024
ESRS 2 SBM-2

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis

Stakeholder interests and views

SR 23 | Social Responsibility > Employee Benefits

ESRS 2 SBM-3

Material impacts, risks and opportunities andtheir interaction with strategy and businessmodel

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Economic Responsibility and of Governance>Employees
SR 23 | Social Responsibility > Employee Benefits

MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIESSR 23 | Introduction > Governance Model
S1-1

SR 23 | Economic Responsibility and of Governance>Employees

Policies related with own workforce

SR 23 | Social Responsibility > Employee Benefits
SR 23 | Social Responsibility > Human Rights

S1-2

Processes for engaging with own workers andworkers' representatives on impacts

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Economic Responsibility and of Governance>Employees
SR 23 | Social Responsibility > Employee Benefits

S1-3

Processes for remediating negative impacts andchannels for workers to express concerns themselves

SR 23 | Approach to Sustainability | Relation with
Stakeholders
SR 23 | Economic Responsibility and of Governance>Employees
SR 23 | Social Responsibility > Employee Benefits
SR 23 | Social Responsibility > Human Rights

S1-4

Taking action on material impacts on own labour
and approaches to mitigate material risks andlook for material opportunities related to the labour itself, as well as the effectiveness of suchmeasures

SR 23 | Approach to Sustainability | Relation with
Stakeholders
SR 23 | Economic Responsibility and of Governance>Employees
SR 23 | Social Responsibility > Employee Benefits
SR 23 | Social Responsibility > Human Rights

METRICS AND TARGETS
SR 23 | Summary of Indicators

S1-5

Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

23 SR | Approach to sustainability| Relation with
Stakeholders > SMP - Sustainability Master Plan
SR 23 | Economic Responsibility and of Governance>Employees
SR 23 | Social Responsibility > Employee Benefits
SR 23 | Summary of Indicators

S1-6

SR 23 | Economic Responsibility and of Governance>Employees

Features of the company’s employees

SR 23 | GRI Table > GRI 401-1
SR 23 | GRI Table > GRI 405-1
S1-7

Characteristics of self-employed persons in thecompany’s own workforce

S1-8

Coverage of collective bargaining and social dialogue

SR 23 | GRI Table > GRI 2-8
SR 23 | Summary of Indicators

SR 23 | Summary of Indicators
S1-9

SR 23 | Economic Responsibility and of Governance>Employees

Diversity metrics

23 SR | GRI Table > GRI 405-1

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S1-10

Appropriate salaries

S1-12

Disabled persons

S1-13

S1-15

S1-16

SR 23 | Summary of Indicators
SR 23 | Summary of Indicators
SR 23 | Economic Responsibility and of Governance>Employees

Metrics on training actions and skills development

SR 23 | GRI Table > GRI 405-1
SR 23 | Economic and Governance Accountability > Employees > Training
SR 23 | Economic and Governance Accountability > Employees > Assess and recognize
SR 23 | GRI Table > GRI 404-3
SR 23 | Social Responsibility > Employee Benefits

Work-life balance metrics

Remuneration metrics (Pay disparity and total remuneration)

SR 23 | Economic Responsibility and of Governance>Employees
SR 23 | GRI Table > GRI 2-21
SR 23 | GRI Table > GRI 405-2

ESRS S4: FINAL CONSUMERS AND USERSSTRATEGY
SR 23 | Introduction > Strategic Plan 2021/2024
ESRS 2 SBM-2

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis

Stakeholder interests and views

SR 23 | Economic and Governance Accountability >Quality Services

ESRS 2 SBM-3

Material impacts, risks and opportunities andtheir interaction with strategy and businessmodel

SR 23 | Approach to sustainability| Relation with
Stakeholders > SMP - Sustainability Master Plan
SR 23 | Economic and Governance Accountability >Products and Services
SR 23 | Economic and Governance Accountability >Quality Services

MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIESSR 23 | Introduction > Governance Model
S4-1

Policies related with final consumers and users

SR 23 | Economic and Governance Accountability >Products and Services
SR 23 | Social Responsibility > Human Rights

S4-2

S4-3

Processes for engaging with consumers and endusers on impacts

Processes for remediating negative impacts andchannels for final consumers and users express
concerns themselves

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Economic and Governance Accountability >Quality Services
SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Economic and Governance Accountability >Products and Services
SR 23 | Economic and Governance Accountability >Quality of Service
SR 23 | Social Responsibility > Human Rights
SR 23 | Introduction > Strategic Plan 2021/2024

S4-4

Adoption of measures on material impacts andapproaches to mitigate material risks and seekmaterial opportunities related to consumers andend-users and effectiveness of such actions andapproaches

SR 23 | Approach to sustainability| Relation with
Stakeholders > SMP - Sustainability Master Plan
SR 23 | Economic and Governance Accountability >Products and Services
SR 23 | Economic and Governance Accountability >Quality of Service

METRICS AND TARGETS

S4-5

Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

4. INFORMATION ON GOVERNANCEESRS G1: BUSINESS CONDUCT

269

23 SR | Economic and Governance Accountability >Products and Services
23 SR | Economic and Governance Accountability >Quality of Service

SUSTAINABILITY REPORT 2023

GOVERNANCEESRS 2 GOV-1

The role played by the management and supervisory bodies;

Governance structure and its composition > Section II- Part B. Corporate bodies and Committees
SR 23 | Introduction > Governance Model
SR 23 | Economic Responsibility and of Governance >Ethics and Professional Conduct

MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIESESRS 2 IRO-1

Description of the processes for identifying andassessing material impacts, risks, and opportunities

SR 23 | Introduction > Management of ESG risks
SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
Governance structure and its composition > Section II- Part B. Corporate bodies and Committees
SR 23 | Introduction > Governance Model
SR 23 | Economic Responsibility and of Governance >Ethics and Professional Conduct

G1-1

Corporate Culture and Business Conduct Policies

SR 23 | Introduction > Governance Model
SR 23 | Economic Responsibility and of Governance >Ethics and Professional Conduct
SR 23 | Social Responsibility > Human Rights

G1-2

Management of relations with suppliers

SR 23 | Economic Responsibility and of Governance >Suppliers

G1-3

Prevention and detection of corruption and bribery

SR 23 | Economic Responsibility and of Governance >Ethics and Professional Conduct

METRICS AND TARGETS
G1-4

Confirmed corruption or bribery incidents

SR 23 | Economic Responsibility and of Governance >Ethics and Professional Conduct
SR 23 | GRI Table > GRI 2-27

G1-5

G1-6

Political influence and lobbying activities

SR 23 | Economic Responsibility and of Governance >Ethics and Professional Conduct
SR 23 | GRI Table > GRI 415-1
SR 23 | Economic Responsibility and of Governance >Suppliers

Payment practices

CYBER-SECURITY, PRIVACY AND INFORMATION PROTECTION
GOVERNANCE-

SR 23 | Economic and Governance Accountability > Information Security-

SR 23 | Economic and Governance Accountability >Protection and privacy of data

STRATEGY
SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis-

SR 23 | Economic and Governance Accountability > Information Security

Material impacts, risks and opportunities

SR 23 | Economic and Governance Accountability >Protection and privacy of data
MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES-SR 23 | Economic and Governance Responsibility > Information Security

Policies

SR 23 | Economic and Governance Responsibility >Protection and privacy of data
SR 23 | Approach to Sustainability | Relation with
Stakeholders-

SR 23 | Economic and Governance Responsibility > Information Security

Actions to manage the theme

SR 23 | Economic and Governance Responsibility >Protection and privacy of data
METRICS AND TARGETS

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Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

SR 23 | Economic and Governance Responsibility > Information Security
SR 23 | Economic and Governance Responsibility >Protection and privacy of data

INNOVATION AND DIGITALIZATIONSTRATEGY-

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis

Material impacts, risks and opportunities

SR 23 | Economic and Governance Responsibility > Innovation

MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES-SR 23 | Approach to Sustainability | Relation with
Stakeholders

Actions to manage the theme

SR 23 | Economic and Governance Responsibility > Innovation

METRICS AND TARGETS
Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

SR 23 | Economic and Governance Responsibility > Innovation

SUSTAINABILITY GOVERNANCE
STRATEGY-

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis

Material impacts, risks and opportunities

SR 23 | Introduction > Governance Model
MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES-SR 23 | Approach to Sustainability | Relation with
Stakeholders

Actions to manage the theme

SR 23 | Introduction > Governance Model
METRICS AND TARGETS
Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

SR 23 | Summary of Indicators
SR 23 | Introduction > Governance Model

RESILIENCE OF THE BUSINESS MODELMANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIESSR 23 | Creation of Value-SR 23 | Introduction > Strategic Plan 2021/2024

Actions to manage the theme

SR 23 | Approach to Sustainability | Relation with
Stakeholders

METRICS AND TARGETS
Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

SR 23 | Introduction > Strategic Plan 2021/2024

RISK MANAGEMENT
GOVERNANCE-

SR 23 | Introduction > Governance Model-

SR 23 | Management of ESG risks

STRATEGY-

Policies-

Material impacts, risks and opportunities

SR 23 | Management of ESG risks
SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis
SR 23 | Management of ESG risks

MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES-Actions to manage the theme

SR 23 | Management of ESG risks

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SR 23 | Approach to Sustainability | Relation with
Stakeholders
METRICS AND TARGETS
Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

SR 23 | Management of ESG risks

MANAGEMENT OF THE BRAND AND REPUTATIONSTRATEGY-

SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis

Material impacts, risks and opportunities

SR 23 | Table of Contents and Sustainability Recognitions

MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES-SR 23 | Approach to Sustainability | Relation with
Stakeholders

Actions to manage the theme

SR 23 | Table of Contents and Sustainability Recognitions

METRICS AND TARGETS
Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

23 SR | Table of Contents and Sustainability Recognitions

ECONOMIC PERFORMANCESTRATEGY
SR 23 | Approach to Sustainability | Relation with
Stakeholders > Materiality Analysis-

AR23 | Information on the BCP Group > Principal Indicators

Material impacts, risks and opportunities

AR23 | Financial Information > Results and Balance
Sheet > Profitability Analysis
MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIESSR 23 | Creation of ValueSR 23 | Introduction > Strategic Plan 2021/2024-

SR 23 | Approach to Sustainability | Relation with
Stakeholders

Actions to manage the theme

AR23 | Information on the BCP Group > Principal Indicators
AR23 | Financial Information > Results and Balance
Sheet > Profitability Analysis

METRICS AND TARGETS
Targets related to the management of material
negative impacts, the promotion of positive impacts, and the management of material risks andopportunities

272

AR23 | Information on the BCP Group > Principal Indicators
AR23 | Financial Information > Results and Balance
Sheet > Profitability Analysis

SUSTAINABILITY REPORT 2023

Table of Commitments

COMMITMENTS AND PRINCIPLES ASSUMED BY MILLENNIUM BCP
Objective interms of time

Fulfilment / Reporting

Led lighting - Installation of LED lighting in all buildings (indoor and outdoor, if applicable).

Dec. 2025

85% (1)

Solar Photovoltaic - Installation of photovoltaic solar energy production equipment in buildings with an adequate sun
exposure and availability.

Dec. 2030

100% (2)Water re-use - Implementation of solutions for water re-use.

Dec 2021

100%

Commitment

LISBON Green
CapitalSingle-use plastics - Eliminate the use of single-use plastics.
(2020)

Dec. 2021

100%

Awareness - Disclosure to the employees and/or associates of the Lisbon’s objectives concerning environment andclimate action.

Dec. 2020

100%

Electric and/or hybrid vehicles - Increase the promotion of de-carbonisation in private vehicles and in operational fleets.

2025: 30%
2030: 80%

10.5% (electric and hybrid)

Car Pool - have at the Employees' disposal a pool of cars that can be reserved and used as needed for business trips.

Dec. 2020

19.2% of the current fleet

Commitment

Objective interms of time

Fulfilment / Reporting

2025: 30%
2030: 80%

10.52% (electric and hybrid)

Car Pool - have at the Employees' disposal a pool of cars that can be reserved and used as needed for business trips.

Dec. 2020

19.2% of the current fleet

Commitment

Objective interms of time

Fulfilment / Reporting

Promote the debate on Sustainability and on the environmental, social and governance risks and opportunities at thelevel of the Board of Directors (BoDs), so that these risks and opportunities are considered in the definition of therespective strategies

2030

i. Reinforcement of the Commitment with Sustainability
as per the 2024 Strategic Plan; ii. Review of theGovernance Model on Sustainability themes.

Promote training in Sustainable Financing addressed to employees in different levels of the organization, with a focus
on the area of ​credit risk analysis, financial products, commercial and/or production.

2030

i. Ongoing Activity / SR 2023: Chapter "Economic andGovernance Accountability" Training Section"

Follow-up the review of the criteria of SME Leader and SME Excellence, to gradually incorporate sustainability issues
into these criteria and accept the possibility of creating a Green SME or a Sustainable SME category.

2030

Millennium bcp continues to monitor developments on
the theme, particularly within the scope of the annual
meeting held to review the PME Leader and PME
Excellence criteria in which Banks and other partners
participate.

Promote a gradual integration of environmental, social and governance criteria in investment assessments.

2030

i. Continuous integration activity – In which an opinion isrequested from the Sustainability Function in the New
Product Approval Process and in the decision on
financing and investment operations with relevanceand/or impact on ESG matters. It is a processintegrated into internal regulations relating to the
management and control of ESG factors, which
includes the Principles of Responsible Financing, aframework for these factors in credit origination and a
responsible investment charter;ii. More information available on the SR 2023 - Chapter“Risks Management”.

Follow-up and participate in future works related with the Think tank on Sustainable Funding.

2030

i. Regular Participation in the meetings of the WorkGroup / SR 2023: Chapter "Introduction", Section"Partnerships", sub-section "Work Groups".

Objective interms of time

Fulfilment / Reporting

Business Mobility
Pact for the City of Electric and/or hybrid vehicles - Increase the promotion of de-carbonisation in private vehicles and in operational fleets.
Lisbon (PMEL) (3)(2019)Engagement
Letter for the
Sustainable
Funding (Min. ofEnvironment, Financeand Economy)(2019)

Principles

1. Establish a high-level corporate leadership for Gender Equality.

i. Plan for Gender Equality 2024; Being led by a woman commitment "Superação 24";
iii. SR 2023: Chapter "Economic and GovernanceAccountability" Employees” Section

2. Treat women and men fairly at work - respect and support Human Rights and non-discrimination.

i. Plan for Gender Equality 2024; Policy for Diversity andEqual Opportunities; Human Rights Policy; SR 2023:
Chapter "Economic Responsibility and Governance",
Section "Employees";
Chapter "Social Responsibility", Section "Human
Rights"; Annex "UNGP - UN Guiding Principles
Reporting Framework".
i. Occupational Health and Safety Policy; Training in
Occupational Health and Safety;iii. SR 2023: Table "GRI - Global Reporting Iniciativeand UNGC - United Nations Global Compact".

3. Ensure health, safety and well-being for male and female employees.

Women's
Empowerment
Principles(2020)

Ongoing

4. Promote education, training and professional development of women

5. Implement business development, supply chain and marketing practices that promote women’s empowerment.

6. Promote equality through community initiatives and advocacy.

7. Measure and publicly report the organization's progress in terms of gender equality.

273

i. Career development programs aimed at employeeswith the greatest potential and talent (Power On,
Ingenius);
ii. SR 2023: Chapter "Economic and GovernanceAccountability" Section “Training".
i. Process for the inclusion of ESG criteria in theselection of Suppliers;
ii. Targeted campaigns/dedicated offering, female
empowerment initiatives/conferences;iii. SR 2023: Chapter "Economic Responsibility andGovernance", Sections "Employees", "Products andServices";
Chapter "Social Responsibility", Section "Benefits to
Employees".
i. Member of the Steering Committee of WEP Portugal;ii. Initiatives/conferences of female empowerment;
iii. SR 2023: Chapter "Economic and GovernanceAccountability" Employees” Section
i. Plan for Gender Equality 2024; SR 2023: Chapter"Economic and Governance Accountability" Employees”
SectionSUSTAINABILITY REPORT 2023

Objective interms of time

Principles

Human Rights

1. Companies must support and respect the protection of internationally proclaimed human rights.

i. Human Rights Policy;ii. Sustainability Guidelines for Suppliers;
iii. SR2023: Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "UNGP UN Guiding Principles Reporting Framework".

Human Rights

2. Companies must ensure they are not complicit in human rights abuses.

i. Collective Labour Agreements;
ii. Sustainability Guidelines for Suppliers;
iii. SR 2023: Chapter "Economic Responsibility andGovernance", Section "Employees";and Annex "UNGP - UN Guiding Principles Reporting
Framework".

Work

3. Companies must defend freedom of association and the effective recognition of the right to collective bargaining.

i. Human Rights Policy;ii. Sustainability Guidelines for Suppliers;
iii. SR2023: Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "UNGP UN Guiding Principles Reporting Framework".

Work

4. The elimination of all forms of forced and compulsory labour.

i. Human Rights Policy;ii. Sustainability Guidelines for Suppliers;
iii. SR2023: Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "UNGP UN Guiding Principles Reporting Framework".

Work

5. The effective abolition of child labour.

UN Global
Compact(2005)

Work

Ongoing

6. The elimination of discrimination in relation to employment and occupation.

i. Human Rights Policy;
ii. Policy for Diversity and Equal Opportunities;iii. SR2023: Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "UNGP UN Guiding Principles Reporting Framework".
i. Environmental Policy;
ii. Principles for a responsible financing: underconditions and excluded projects;iii. Sustainability Policy;
iv. Inclusion of C&A risks in the financing process;v. SR 2023: Chapter "Environment".

Environment

7. Companies must support a preventative approach to environmental challenges.

i. Incentives for sustainable mobility, increase in social
and/or environmental awareness actions among
Employees, installation of 2 photovoltaic plants in
Taguspark; environmental monitoring of a set of KPIs
(as an Organization), inclusion of C&A risks in thefinancing process (as a Financing entity);ii. Environmental Policy;
III. Principles for a responsible financing: underconditions and excluded projects
iv. Sustainability Policy;v. SR 2023: Chapter "Environment".

Environment

8. Companies should undertake initiatives to promote greater environmental responsibility.

i. Incentives for sustainable mobility, increase in social
and/or environmental awareness actions among
Employees, installation of 2 photovoltaic plants in
Taguspark; environmental monitoring of a set of KPIs
(as an Organization), inclusion of C&A risks in thefinancing process (as a Financing entity);ii. Environmental Policy;
III. Principles for a responsible financing: underconditions and excluded projects
iv. Sustainability Policy;v. SR 2023: Chapter "Environment".

Environment

9. Companies must encourage the development and dissemination of environmentally friendly technologies.

i. Anti-Corruption and Anti-Bribery Policy;
ii. Code of Conduct;iii. SR 2023: Chapter "Economic Responsibility andGovernance", Section "Employees", Annexes "GRI Global Reporting Initiative and UNGC - United Nations
Global Compact", "UNGP - UN Guiding Principles
Reporting Framework".

Anti-corruption

10. Companies should work against corruption in all its forms, including extortion and bribery.

Objective interms of time

Commitment

UNEP-FI
Principles for
Responsible
Banking(2022)

Fulfilment / Reportingi. Human Rights Policy; Policy for Diversity and Equal
Opportunities;iii. Self assessment Human Rights (bi-annual
realization);
iv. SR2023: Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "UNGP UN Guiding Principles Reporting Framework".

Fulfilment / Reporting

1. Aligning business strategy to be consistent with and contribute to the needs of individuals and the goals of society, as
expressed in the Sustainable Development Goals, the Paris Climate Agreement and relevant national and regionalframeworks.

SR 2023: Annex for “Principles for Responsible
Banking"

2. Continuously increase positive impacts while reducing negative impacts and managing risks to people and theenvironment resulting from their activities, products and services. To do this, they must define and publish goals where
they can have the most significant impact.

SR 2023: Annex for “Principles for Responsible
Banking"
SR 2023: Annex for “Principles for Responsible
Banking"

3. Work responsibly with their customers and users to encourage sustainable practices and enable economic activities
that create shared prosperity for current and future generations.
Ongoing
4. Pro actively and responsibly consult, engage and partner with relevant stakeholders to achieve the company’s goals.

SR 2023: Annex for “Principles for Responsible
Banking"

5. Implement commitments to these principles through effective governance and a responsible banking culture.

SR 2023: Annex for “Principles for Responsible
Banking"

6. Periodically analyse the individual and collective implementation of these principles and adopt a policy oftransparency and responsibility in relation to their positive and negative impacts and their contribution to the company’s
objectives.

SR 2023: Annex for “Principles for Responsible
Banking"274

SUSTAINABILITY REPORT 2023

Recommendations

TCFD(2019)

Recommended climate-related financial disclosures: Governance, Strategy, Management, Metrics and objectives.

Fulfilment / Reporting

Ongoing

SR 2023: Annex “Task Force on Climate related
Financial Disclosures"

Objective interms of time

Recommendations

CEO Guide to
Human Rights WBCSD(2019)

Objective interms of time

Protect
1. States have a duty to protect people against human rights abuses by third parties, including companies. They are
expected to prevent, investigate, punish and address abuses through appropriate policies, legislation, regulation andadjudication.
Respect
2. Companies have a responsibility to human rights. They must address adverse human rights impacts that may result
from their own activities and business relationships.

Ongoing

Remedy3. Affected people must have access to remediation. States and companies have roles to play in ensuring access toremediation when negative impacts occur.

SR 2023: Chapter "Social Responsibility", Section"Human Rights"; Annex "UNGP - UN Guiding Principles
Reporting Framework"
SR 2023: Chapter "Social Responsibility", Section"Human Rights"; Annex "UNGP - UN Guiding Principles
Reporting Framework"

Objective interms of time

Principles

Fulfilment / Reporting
SR 2023: Chapter "Social Responsibility", Section"Human Rights"; Annex "UNGP - UN Guiding Principles
Reporting Framework"

Fulfilment / Reporting

1. Ethics and Legal Compliance
1.1 RESPECT in its actions the 10 Principles of the United Nations Global Compact, the Universal Declaration of
Human Rights and the Fundamental Principles and Rights at Work of the International Labour Organization.
1.2 ACT in compliance with the laws and standards that regulate their activity at national and international level, adopting
the principle of greater demands in the case of selection between national legislation and international standards.
1.3 COMPLY and promote compliance with good practices in terms of ethical conduct.
1.4 NOT TOLERATE, the participation, in a direct or indirect manner, in any corruption, fraud, money laundering, bribery
or extortion.
1.5 RESPECT the rules of fair competition and provide reliable and transparent information to all partners.
1.6 DEFINE procedures to identify and approach conflicts of interest which may adversely affect the business relations.
1.7 RESPECT AND ENFORCE intellectual property rights.
1.8 PROTECT, and not use or make unauthorized third-party data available.

i. Corporate Principles and Policies;
ii. Articles of Association and main rules andregulations;iii. SR 2023: Chapter "Economic Responsibility andGovernance "; Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "SASB Sustainability Accounting Standards Board".

i. Corporate Principles and Policies;
ii. Articles of Association and main rules andregulations;iii. SR 2023: Chapter "Economic Responsibility andGovernance "; Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "SASB Sustainability Accounting Standards Board", UNGP UN Guiding Principles Reporting Framework".

2. Human Rights
2.1 RESPECT and promote Human Rights.
2.2 DO NOT TOLERATE the violation of human rights, refusing any form of harassment, discrimination,coercion, abuse,violence or exploitation in their sphere of influence.
2.3 MAKE appropriate efforts to prevent the use of raw materials in their products that directly or indirectly financepractices that violate human rights.

3. Labour Rights

Charter ofPrinciples fromBCSD Portugal(2018)

3.1 RESPECT labour rights and reject any form of forced or child labour.
3.2 SUPPORT the freedom of association and the recognition of the right to collective bargaining.
3.3 PROVIDE fair and equitable remuneration, ensuring payment of a decent salary and balance between professional,
family and personal life.
3.4 PROMOTE equal opportunities and treatment in terms of employment and professional functions.
3.5 ENSURE conditions for a work environment free from discrimination, moral or sexual harassment, threats andphysical or psychological aggression.
3.6 PROVIDE knowledge and training for their workers, and recognize and value the qualifications acquired to performtheir duties.

4. Prevention, Health and Safety
4.1 IDENTIFY, CONTROL AND PREVENT risks and take the necessary preventive measures to avoid accidents andoccupational diseases.
4.2 ENCOURAGE behaviours that promote the physical and psychological well-being and safety of its direct and indirect
workers.
4.3 ENSURE means of protection and training in prevention, health and safety for workers.

5 Environment
5.1 PROMOTE the continuous improvement of processes, products and services, through the identification, monitoringand mitigation of environmental risks associated with its activities, aiming at reducing negative impacts on climate, air,water, soil, biodiversity, territory and communities.
5.2 REDUCE the consumption of natural resources and the generation of waste, maximizing process efficiency, reuse
and recycling.
5.3 PROMOTE environmental responsibility, the use of innovative and clean technologies and engagement withstakeholders to adapt to global challenges

6. Management
6.1 Continuously IMPROVE management processes and practices, adopting measures to comply with the principles
enshrined here.
6.2 ENCOURAGE the value chain to respect and promote principles equivalent to those in this Charter.
6.3 COMMUNICATE sustainability performance regularly and transparently, namely relevant information on economic,
environmental, social, ethical and management performance.
6.4 ENCOURAGING the involvement with interested parties by listening and dialogue.

(1) Inside the Branches, the light bulbs are replaced by LED whenever respective maintenance is necessary.
(2) M illennium bcp installed a second Photovoltaic Plant with 1 M W of power in Taguspark, doubling its own energy production capacity.
(3) Common goals with Lisbon European Green Capital

275

i. Corporate Principles and Policies;
ii. Articles of Association and main rules andregulations;iii. SR 2023: Chapter "Economic Responsibility andGovernance "; Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "SASB Sustainability Accounting Standards Board", UNGP UN Guiding Principles Reporting Framework".
Ongoingi. Corporate Principles and Policies;
ii. Articles of Association and main rules andregulations;iii. SR 2023: Chapter "Economic Responsibility andGovernance "; Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "SASB Sustainability Accounting Standards Board", UNGP UN Guiding Principles Reporting Framework".

i. Corporate Principles and Policies;
ii. Articles of Association and main rules andregulations;iii. SR 2023: Chapter "Economic Responsibility andGovernance "; Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "SASB Sustainability Accounting Standards Board", UNGP UN Guiding Principles Reporting Framework".

i. Corporate Principles and Policies;
ii. Articles of Association and main rules andregulations;iii. SR 2023: Chapter "Economic Responsibility andGovernance "; Annexes "GRI - Global Reporting Initiativeand UNGC - United Nations Global Compact", "SASB Sustainability Accounting Standards Board", UNGP UN Guiding Principles Reporting Framework".

SUSTAINABILITY REPORT 2023

EUROPEAN UNION (EU) TAXONOMY TABLES

0. Summary of KPIs to be disclosed by credit institutions under Article 8 of the EU Taxonomy Regulation

276

SUSTAINABILITY REPORT 2023

1.1. Assets for the calculation of GAR based on turnover

Million EUR

Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Water and marine resources (WTR)

31 December 2023
Circular economy (CE)

Pollution (PPC)

Biodiversity and Ecosystems (BIO)

Of which towards Taxonomy-relevant sectors (Taxonomy-

Of which towards Taxonomy-relevant

Of which towards Taxonomy-relevant

Of which towards Taxonomy-relevant

Of which towards Taxonomy-relevant

Of which towards Taxonomy-relevant

eligible)

sectors (Taxonomy-eligible)

sectors (Taxonomy-eligible)

sectors (Taxonomy-eligible)

sectors (Taxonomy-eligible)

sectors (Taxonomy-eligible)

Total [gross]

Of which environmentally sustainable

Of which environmentally

carrying
amount(Taxonomy-aligned)sustainable (Taxonomy-aligned)

Of which Of which
Use of transitiona
Proceedsl

Of which
Use of

Of whichenabling

Proceeds

Of which environmentally
sustainable (Taxonomy-

Of which environmentally
sustainable (Taxonomy-aligned)aligned)Of which
Use of

Of which
Use of

Of whichenabling

Proceeds

Of whichenabling

Proceeds

Of which environmentally

Of which environmentally

sustainable (Taxonomy-aligned)sustainable (Taxonomy-aligned)

Of which
Use of

Of whichenabling

Proceeds

Of which
Use of

Of whichenabling

Proceeds

TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Of which environmentally sustainable(Taxonomy-aligned)
Of which Of which
Use of transitiona

Of whichenabling

Proceedsl

Of whichenabling

GAR - Covered assets in both numerator anddenominator
1

Loans and advances, debt securities and equity

40 320

17 024

1 934

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 681

1 934

1 826

0

0

2

Financial undertakings

2 686

486

158

158

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

486

158

158

0

0

3
4

Credit institutions
Loans and advances

912
239

158
0

158
0

158
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

158
0

158
0

158
0

0
0

0
0

5

Debt securities, including UoP

673

158

158

158

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

158

158

158

0

0

instruments not HfT eligible for GAR calculation

6

Equity instruments

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

7
8

Other financial corporationsof which investment firms

1 773
691

328
199

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

328
199

0
0

0
0

0
0

0
0

9

Loans and advances

328

199

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

199

0

0

0

0

10

Debt securities, including UoP

196

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

11
12

Equity instrumentsof which management companies

167
9

0
7

0
0

0

0
0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
7

0
0

0

0
0

0
0

13

Loans and advances

8

7

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

7

0

0

0

0

14

Debt securities, including UoP

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

15
16

Equity instrumentsof which insurance undertakings

0
17

0
5

0
0

0

0
0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
5

0
0

0

0
0

0
0

17

Loans and advances

17

5

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

5

0

0

0

0

18

Debt securities, including UoP

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

0
388
165

0
115
8

11
0

0
0
0

0
0
0

0
0

0
0

0
0

0
0
0

0
0
0

0

0
0
0

0
0

0
0

0
0

0
0

0
0

0
0

0

222
0
15 934

108
0
1 657

1 657

0
0
0

0
0
0

0

0

0

0

0

0

0

0

19
20
21

Equity instruments
Non-financial undertakings
Loans and advances

0
1 216
444

0
376
165

0
115
8

11
0

0
0
0

0
0
0

0
11
1

0
0
0

22
23
24

Debt securities, including UoP
Equity instruments
Households
of which loans collateralised by773
0
35 222212
015 934

108
0
1 657

0
0
0

0
0
0

11
0
0

0
0
0

0

1 657

0

0
0
0

26 26815 772

1 656

1 656

0

0

0

0

0

0

0

0

0

0

15 772

1 656

1 656

0

0

0
28
971

0
28
2

0
0
0

0
0
0

0
0
0

0
0
0

0

0

0

0

0

0

0

0

646

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0
28
648

0
0
0

0
0
0

0
0
0

0
0
0

0
971

0
2

0
0

0
0

0
0

0
0

0
646

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
648

0
0

0
0

0
0

0
0

226

226

3

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

226

3

0

0

0

25 499

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 024

1 934

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 681

1 934

1 826

0

0

25
26
27
28
29
30
31

32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47

residential immovable propertyof which building renovation loansof which motor vehicle loans
Local governments financing
Housing financing
Other local government financing
Collateral obtained by taking possession:residential and commercial immovable
properties
Assets excluded from the numerator for GAR
calculation (covered in the denominator)
Financial and Non-financial undertakings
SMEs and NFCs (other than SMEs) not
subject to NFRD disclosure obligations
Loans and advancesof which loans collateralised bycommercial immovable propertyof which building renovation loans
Debt securities
Equity instruments
Non-EU country counterparties not subject
to NFRD disclosure obligations
Loans and advances
Debt securities
Equity instruments
Derivatives
On demand interbank loans
Cash and cash-related assets
Other categories of assets (e.g. Goodwill,commodities etc.)
48 Total GAR assets
49 Assets not covered for GAR calculation
Central governments and Supranational
50
issuers
51
Central banks exposure
52
Trading book

11

0

0

0

11

19 66618 72516 938
99
0
1 776
11
941
835
53
53
41
337
689
4 767
65 81919 47114 791
3 857
823

53 Total assets
85 290
17 024Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations

1 934

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 681

1 934

1 826

0

0

54 Financial guarantees
55 Assets under management56
Of which debt securities

0
673
237

0
41
34

0
6
3

0
0
0

0
0
0

0
4
3

0
1
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
42
34

0
7
3

0
0
0

0
0
0

0
4
3

57

423

7

3

0

0

1

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

8

3

0

0

1

Of which equity instruments

277

SUSTAINABILITY REPORT 2023

Million EUR

Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Water and marine resources (WTR)

31 December 2023
Circular economy (CE)Of which towards Taxonomy-relevant sectors (Taxonomyeligible)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Total [gross]

Of which environmentally sustainable

Of which environmentally

carrying
amount(Taxonomy-aligned)sustainable (Taxonomy-aligned)

Of which Of which
Use of transitiona
Proceedsl

Of whichenabling

Of which
Use ofProceeds

Of whichenabling

Of which environmentally
sustainable (Taxonomy-

Of which environmentally
sustainable (Taxonomy-aligned)aligned)Of which
Use ofProceeds

Of whichenabling

Of which
Use ofProceeds

Of whichenabling

Pollution (PPC)

Biodiversity and Ecosystems (BIO)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which environmentally

Of which environmentally

sustainable (Taxonomy-aligned)sustainable (Taxonomy-aligned)

Of which
Use ofProceeds

Of whichenabling

Of which
Use ofProceeds

Of whichenabling

TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Of which environmentally sustainable(Taxonomy-aligned)
Of which Of which
Use of transitiona
Proceedsl

Of whichenabling

GAR - Covered assets in both numerator anddenominator
12
3
4

Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
Financial undertakings
Credit institutions
Loans and advances

40 320

17 024

1 934

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 681

1 934

1 826

0

0

2 686
912
239

486
158
0

158
158
0

158
158
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

486
158
0

158
158
0

158
158
0

0
0
0

0
0
0

5
6

Debt securities, including UoP
Equity instruments

673
0

158
0

158
0

158

0
0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

0
0

0
0

0

0
0

158
0

158
0

158

0
0

0
0

7
8

Other financial corporationsof which investment firms

1 773
691

328
199

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

328
199

0
0

0
0

0
0

0
0

9
10
11
12

Loans and advances
Debt securities, including UoP
Equity instrumentsof which management companies

328
196
167
9

199
0
0
7

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

199
0
0
7

0
0
0
0

0
0

0
0
0
0

0
0
0
0

13
14
15
16

Loans and advances
Debt securities, including UoP
Equity instrumentsof which insurance undertakings

8
1
0
17

7
0
0
5

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

7
0
0
5

0
0
0
0

0
0

0
0
0
0

0
0
0
0

17
18
19

Loans and advances
Debt securities, including UoP
Equity instruments

17
0
0

5
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

5
0
0

0
0
0

0
0

0
0
0

0
0
0

20
21

0

0

0

0

0

0

0

0

0

0

0

0

0

1 216
444

376
165

115
8

11
0

0
0

0
0

11
1

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

388
165

115
8

11
0

0
0

0
0

22

Debt securities, including UoP

773

212

108

11

0

0

11

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

222

108

11

0

0

23
24

Equity instruments
Households
of which loans collateralised by0
35 2220
15 934

0
1 657

0
0

0
0

0
0

0
0

0

0

0
0

0
0

0

0

0

0

0

0

0
0

0

0

0
0

0

1 657

0
15 934

0
1 657

1 657

0
0

0
0

26 26815 772

1 656

1 656

0

0

0

0

0

0

0

0

0

0

15 772

1 656

1 656

0

0

0
28
971

0
28
2

0
0
0

0
0
0

0
0
0

0
0
0

0

0

0

0

0

0

0

0

646

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0
28
648

0
0
0

0
0
0

0
0
0

0
0
0

0
971

0
2

0
0

0
0

0
0

0
0

0
646

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
648

0
0

0
0

0
0

0
0

226

226

3

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

226

3

0

0

0

25 499

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 024

1 934

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 681

1 934

1 826

0

0

25
26
27
28
29
30
31

Non-financial undertakings
Loans and advances0

residential immovable propertyof which building renovation loansof which motor vehicle loans
Local governments financing
Housing financing
Other local government financing
Collateral obtained by taking possession:residential and commercial immovable

properties
Assets excluded from the numerator for GAR
32
calculation (covered in the denominator)
33
34
35
36
37
38
39

Financial and Non-financial undertakings
SMEs and NFCs (other than SMEs) not
subject to NFRD disclosure obligations
Loans and advancesof which loans collateralised bycommercial immovable propertyof which building renovation loans
Debt securities
Equity instruments

19 66618 72516 938
99
0
1 776
11

41
42

Non-EU country counterparties not subject
to NFRD disclosure obligations
Loans and advances
Debt securities

835
53

43
44
45

Equity instruments
Derivatives
On demand interbank loans

53
41
337

46

Cash and cash-related assets
Other categories of assets (e.g. Goodwill,40

47

commodities etc.)
48 Total GAR assets
49 Assets not covered for GAR calculation
Central governments and Supranational
50
issuers
51
Central banks exposure
52

Trading book

941

689
4 767
65 81919 47114 791
3 857
823

53 Total assets
85 290
17 024Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations

1 934

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 681

1 934

1 826

0

0

54 Financial guarantees
55 Assets under management56
Of which debt securities

0
673
237

0
41
34

0
6
3

0
0
0

0
0
0

0
4
3

0
1
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
42
34

0
7
3

0
0
0

0
0
0

0
4
3

57

423

7

3

0

0

1

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

8

3

0

0

1

Of which equity instruments

278

SUSTAINABILITY REPORT 2023

1.2. Assets for the calculation of GAR based on CapEx

Million EUR

Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Water and marine resources (WTR)

Of which towards Taxonomy-relevant sectors(Taxonomy-eligible)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which environmentally sustainable

Of which environmentally(Taxonomy-aligned)sustainable (Taxonomy-aligned)

Of which environmentally
sustainable (Taxonomy-

Total [gross]carrying
amountOf which
Use ofProceeds

Of which
Use of

Of which
Of whichtransitional enabling

Proceeds

31 December 2023
Circular economy (CE)

Pollution (PPC)

Biodiversity and Ecosystems (BIO)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which towards Taxonomy-relevant
sectors (Taxonomy-eligible)

Of which environmentally

Of which environmentally
sustainable (Taxonomy-

sustainable (Taxonomy-aligned)aligned)Of which
Of which
Use ofenabling
Proceeds

Of whichenabling

Of which
Use ofProceedsaligned)Of which
Use of

Of whichenabling

Proceeds

TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Of which environmentally

Of which environmentally sustainable

sustainable (Taxonomy-aligned)(Taxonomy-aligned)

Of which
Use of

Of whichenabling

ProceedsOf
whichenablin

Of which Of which
Of which
Use of transition
enablingal

Proceedsg

GAR - Covered assets in both numerator anddenominator
1

Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation

40 32017 104

1 963

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 761

1 963

1 826

0

0

2
3

Financial undertakings
Credit institutions

2 686
912

486
158

158
158

158
158

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

486
158

158
158

158
158

0
0

0
0

4
5
6
7

Loans and advances
Debt securities, including UoP
Equity instruments
Other financial corporations

239
673
0
1 773

0
158
0
327

0
158
0
0

0
158

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
158
0
327

0
158
0
0

0
158

0
0
0
0

0
0
0
0

8
9
10
11

of which investment firms
Loans and advances
Debt securities, including UoP
Equity instruments

691
328
196
167

199
199
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

199
199
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

12
13
14
15
16

of which management companies
Loans and advances
Debt securities, including UoP
Equity instrumentsof which insurance undertakings

9
8
1
0
17

7
7
0
0
5

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

7
7
0
0
5

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
11

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

5
0
0
467

0
0
0
145

0
0

0
0
0
0

0
0
0
0

0
0
0
0

1
11
0
0

0
0
0
0

0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

220
247
0
15 934

16
129
0
1 657

0
0
0
0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17
18
19
20

Loans and advances
Debt securities, including UoP
Equity instruments
Non-financial undertakings

17
0
0
1 216

5
0
0
456

0
0
0
145

21
22
23
24

Loans and advances
Debt securities, including UoP
Equity instruments
Households

444
773
0
35 222220236
015 934

16
129
0
1 657

1 657

0
0
0
0

0

0
0
0
0

0

0
0
0
0

1 657

0
0
0
0

26 26815 772

1 656

1 656

0

0

0

0

0

0

0

0

0

0

15 772

1 656

1 656

0

0

0
28
971

0
28
2

0
0
0

0
0
0

0
0
0

0
0
0

0

0

0

0

0

0

0

0

646

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0
28
648

0
0
0

0
0
0

0
0
0

0
0
0

0
971

0
2

0
0

0
0

0
0

0
0

0
646

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
648

0
0

0
0

0
0

0
0

226

226

3

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

226

3

0

0

0

25 499

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 104

1 963

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 761

1 963

1 826

0

0

17 104

1 963

1 826

0

0

657

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17 761

1 963

1 826

0

0

0
0
0

0
1
0

0
15
13

0
2
0

0
1
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

0
49
30

0
22
15

0
0
0

0
1
0

0
16
13

0

0

2

2

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

20

7

0

0

2

25
26
27
28
29
30
31

32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47

of which loans collateralised byresidential immovable propertyof which building renovation loansof which motor vehicle loans
Local governments financing
Housing financing
Other local government financing
Collateral obtained by taking possession:residential and commercial immovable
properties
Assets excluded from the numerator for GAR
calculation (covered in the denominator)
Financial and Non-financial undertakings
SMEs and NFCs (other than SMEs) not
subject to NFRD disclosure obligations
Loans and advancesof which loans collateralised bycommercial immovable propertyof which building renovation loans
Debt securities
Equity instruments
Non-EU country counterparties not subject
to NFRD disclosure obligations
Loans and advances
Debt securities
Equity instruments
Derivatives
On demand interbank loans
Cash and cash-related assets
Other categories of assets (e.g. Goodwill,commodities etc.)
48 Total GAR assets
49 Assets not covered for GAR calculation
Central governments and Supranational
50
issuers
51
Central banks exposure
52

Trading book

0
11

0

0

0

0

0

11
0
11

19 66618 72516 938
99
0
1 776
11
941
835
53
53
41
337
689
4 767
65 81919 47114 791
3 857
823

53 Total assets

85 290Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
00055 Assets under management
673
48
21
56
Of which debt securities
237
30
15
57

11

Of which equity instruments

423

18

6

279

SUSTAINABILITY REPORT 2023
Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Water and marine resources (WTR)

31 December 2022
Circular economy (CE)

Pollution (PPC)

Biodiversity and Ecosystems (BIO)

Of which towards Taxonomy-relevant sectors

Of which towards Taxonomy-relevant

Of which towards Taxonomy-relevant

Of which towards Taxonomy-relevant

Of which towards Taxonomy-relevant

Of which towards Taxonomy-relevant(Taxonomy-eligible)

sectors (Taxonomy-eligible)

sectors (Taxonomy-eligible)

sectors (Taxonomy-eligible)

sectors (Taxonomy-eligible)

sectors (Taxonomy-eligible)

Total
Million EUR[gross]TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Of which environmentally sustainable

Of which environmentally

Of which environmentally

Of which environmentally

Of which environmentally

Of which environmentally

Of which environmentally sustainable(Taxonomy-aligned)sustainable (Taxonomy-aligned)sustainable (Taxonomy-aligned)sustainable (Taxonomy-aligned)sustainable (Taxonomy-aligned)sustainable (Taxonomy-aligned)(Taxonomy-aligned)

Of which

Of which

Of which

Of whichcarrying
amountOf which
Use ofProceeds

Of whichtransitionalOf

Of whichwhich

Use ofenabling

Proceeds

Of which

Use ofenabling

Proceeds

Of which

Use ofenabling

Proceeds

Of which

Use ofenabling

Proceeds

Of which

Use ofenabling

Proceeds

Of
Of whichwhichenabling

Use ofProceeds

Of whichtransitional

Of whichenabling

GAR - Covered assets in both numerator anddenominator
1

Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation

39 86216 780

1 240

1 237

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

16 780

1 240

1 237

0

0

2
3

Financial undertakings
Credit institutions

2 647
751

283
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

283
0

0
0

0
0

0
0

0
0

4
5
6
7

Loans and advances
Debt securities, including UoP
Equity instruments
Other financial corporations

246
506
0
1 895

0
0
0
283

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
283

0
0
0
0

0
0

0
0
0
0

0
0
0
0

8
9
10
11

of which investment firms
Loans and advances
Debt securities, including UoP
Equity instruments

847
281
566
0

162
162
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0

0
0
0
0

162
162
0
0

0
0
0
0

0
0
0

0
0
0
0

0
0
0
0

12
13
14
15
16

of which management companies
Loans and advances
Debt securities, including UoP
Equity instrumentsof which insurance undertakings

30
29
1
0
13

29
29
0
0
7

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0

0
0
0
0
0

29
29
0
0
7

0
0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0
0

7
0
0
12

0
0
0
0

0
0

0
0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0
0

0
0
0
0

0
0

0
0
0

0
0
0

0
0

0
0
0

0
0
0

0
0
0

0
0

0
0
0

12
0
0
16 156

0
0
0
1 237

0
0

0
0
0
0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17
18
19
20

Loans and advances
Debt securities, including UoP
Equity instruments
Non-financial undertakings

13
0
0
1 111

7
0
0
12

0
0
0
0

0
0
0

0
0
0
0

21
22
23
24

Loans and advances
Debt securities, including UoP
Equity instruments
Households

560
548
2
34 62812
00
16 156

0
0
0
1 237

0
0

0
0

0
0

1 237

0

0

0
0
0
0

0

0
0
0
0

0

0
0
0
0

1 237

0
0
0
0

26 25816 018

1 237

1 237

0

0

0

0

0

0

0

0

0

0

16 018

1 237

1 237

0

0

0
28

0
28

0
0

0
0

0

0

0

0

0

0

0

0

0
28

0
0

0
0

0
0

0
0

25
26
27

of which loans collateralised byresidential immovable propertyof which building renovation loansof which motor vehicle loans

0

0

0

0

0

0

0

0
0

28

Local governments financing

1 151

3

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

3

0

0

0

0

29
30

Housing financing
Other local government financing
Collateral obtained by taking possession:

0
1 151

0
3

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
3

0
0

0
0

0
0

0
0

31

residential and commercial immovable

327

327

3

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

327

3

0

0

0

26 566

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

16 780

1 240

1 237

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

16 780

1 240

1 237

0

0

16 780

1 240

1 237

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

16 780

1 240

1 237

0

0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

0
0

properties
Assets excluded from the numerator for GAR
32
calculation (covered in the denominator)
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47

Financial and Non-financial undertakings
SMEs and NFCs (other than SMEs) not
subject to NFRD disclosure obligations
Loans and advancesof which loans collateralised bycommercial immovable propertyof which building renovation loans
Debt securities
Equity instruments
Non-EU country counterparties not subject
to NFRD disclosure obligations
Loans and advances
Debt securities
Equity instruments
Derivatives
On demand interbank loans
Cash and cash-related assets
Other categories of assets (e.g. Goodwill,commodities etc.)
48 Total GAR assets
49 Assets not covered for GAR calculation
Central governments and Supranational
50
issuers
51
Central banks exposure
52
Trading book53 Total assets

20 48719 88118 166
26
0
1 703
11
607
532
22
53
60
212
593
5 213
66 42817 031
10 8355 429
767
83 459Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
00055 Assets under management
0
0
0
56

Of which debt securities

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

57

Of which equity instruments

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

280

SUSTAINABILITY REPORT 2023

2.1. GAR sector information based on turnover (only the sectors with eligible not-null exposures are presented)
Climate Change Mitigation (CCM)

Breakdown by sector - NACE four digits (code and label)

Water and marine resources (WTR)

Circular economy (CE)

Pollution (PPC)

Biodiversity and Ecosystems (BIO)TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amountMillionEUR
22.22 Manufacture of plastic packing goods

Climate Change Adaptation (CCA)

Non-Financial corporates

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

0,8

0

0,8

0

0

0

0

0

0

0

0

0

0,8

0

1,6

0

1,6

0

0

0

0

0

0

0

0

0

1,6

0

0,000100,0001

0

0

0

0

0

0

0

0

0

0,0001

0

4,8

0

4,8

0

0

0

0

0

0

0

0

0

4,8

0

0,5

0

0,5

0

0

0

0

0

0

0

0

0

0,5

0

30.20 Manufacture of railway locomotives and rolling stock

0,000400,0004

0

0

0

0

0

0

0

0

0

0,000433.20 Installation of industrial machinery and equipment

0,7

0

0,7

0

0

0

0

0

0

0

0

0

0,7

0

35.11 Production of electricity

116,7

1,2

116,7

0

0

0

0

0

0

0

0

0

116,7

1,2

41.20 Construction of residential and non-residential buildings

1,8

0

1,8

0

0

0

0

0

0

0

0

0

1,8

0

42.11 Construction of roads and motorways

50,6

0

50,6

0

0

0

0

0

0

0

0

0

50,6

0

42.12 Construction of railways and underground railways

8,2

0

8,2

0

0

0

0

0

0

0

0

0

8,2

0

42.13 Construction of bridges and tunnels

11,2

0

11,2

0

0

0

0

0

0

0

0

0

11,2

0

42.99 Construction of other civil engineering projects n.e.c.

19,5

0

19,5

0

0

0

0

0

0

0

0

0

19,5

0

43.21 Electrical installation

0,2

0

0,2

0

0

0

0

0

0

0

0

0

0,2

45.11 Sale of cars and light motor vehicles

0,1

0

0,1

0

0

0

0

0

0

0

0

0

0,1

0

46.76 Wholesale of other intermediate products

5,8

0,4

5,8

0

0

0

0

0

0

0

0

0

5,8

0,4

49.10 Passenger rail transport, interurban

28,3

0

28,3

0

0

0

0

0

0

0

0

0

28,3

0

49.20 Freight rail transport

11,7

0

11,7

0

0

0

0

0

0

0

0

0

11,7

0

49.31 Urban and suburban passenger land transport

2,2

0

2,2

0

0

0

0

0

0

0

0

0

2,2

0

50.20 Sea and coastal freight water transport

1,0

0

1,0

0

0

0

0

0

0

0

0

0

1

0

52.21 Service activities incidental to land transportation

33,8

0

33,8

0

0

0

0

0

0

0

0

0

33,8

52.29 Other transportation support activities

0,01

0

0,01

0

0

0

0

0

0

0

0

0

0,01

0

53.10 Postal activities under universal service obligation

0,1

0,01

0,1

0

0

0

0

0

0

0

0

0

0,1

0,01

61.30 Satellite telecommunications activities

8,6

0

8,6

0

0

0

0

0

0

0

0

0

8,6

0

62.01 Computer programming activities

0,01

0

0,01

0

0

0

0

0

0

0

0

0

0,01

0

62.02 Computer consultancy activities

5,7

0

5,7

0

0

0

0

0

0

0

0

0

5,7

68.10 Buying and selling of own real estate

3,9

0

3,9

0

0

0

0

0

0

0

0

0

3,9

0

70.10 Activities of head offices

641,9

113,8

641,9

0

0

0

0

0

0

0

0

0

641,9

113,8

71.11 Architectural activities

23.41 Manufacture of ceramic household and ornamental articles
24.51 Casting of iron27.51 Manufacture of electric domestic appliances
29.32 Manufacture of other parts and accessories for motor vehicles

0

0

0

0

0,000200,0002

0

0

0

0

0

0

0

0

0

0,0002077.39 Renting and leasing of other machinery, equipment and tangible goods n.e.c.
0,1

0

0,1

0

0

0

0

0

0

0

0

0

0,1

0

80.20 Security systems service activities

0,3

0

0,3

0

0

0

0

0

0

0

0

0

0,3

0

84.13 Regulation of and contribution to more efficient operation of businesses 10,6

0

10,6

0

0

0

0

0

0

0

0

0

10,6

0

86.10 Hospital activities

0

0,2

0

0

0

0

0

0

0

0

0

0,2

0

0,2

281

SMEs and other NFC not

MillionEUR

Of whichenvironmentally
sustainable

SUSTAINABILITY REPORT 2023

2.2. GAR sector information based on CapEx (only the sectors with eligible not-null exposures are presented)
Climate Change Mitigation (CCM)

Breakdown by sector - NACE four digits (code and label)

Water and marine resources (WTR)

Circular economy (CE)

Pollution (PPC)

Biodiversity and Ecosystems (BIO)TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates

SMEs and other NFC not

Non-Financial corporates(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

(Subject to NFRD)

subject to NFRD

[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amount[Gross] carrying amountMillionEUR
22.22 Manufacture of plastic packing goods

Climate Change Adaptation (CCA)

Non-Financial corporates

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

MillionEUR

Of whichenvironmentally
sustainable

0,8

0

0,8

0

0

0

0

0

0

0

0

0

0,8

0

1,6

0

1,6

0

0

0

0

0

0

0

0

0

1,6

0

0,000100,0001

0

0

0

0

0

0

0

0

0

0,0001

0

4,8

0

4,8

0

0

0

0

0

0

0

0

0

4,8

0

0,5

0

0,5

0

0

0

0

0

0

0

0

0

0,5

0

30.20 Manufacture of railway locomotives and rolling stock

0,000400,0004

0

0

0

0

0

0

0

0

0

0,000433.20 Installation of industrial machinery and equipment

0,7

0

0,7

0

0

0

0

0

0

0

0

0

0,7

0

35.11 Production of electricity

116,7

1,2

116,7

0

0

0

0

0

0

0

0

0

116,7

1,2

41.20 Construction of residential and non-residential buildings

1,8

0

1,8

0

0

0

0

0

0

0

0

0

1,8

0

42.11 Construction of roads and motorways

50,6

0

50,6

0

0

0

0

0

0

0

0

0

50,6

0

42.12 Construction of railways and underground railways

8,2

0

8,2

0

0

0

0

0

0

0

0

0

8,2

0

42.13 Construction of bridges and tunnels

11,2

0

11,2

0

0

0

0

0

0

0

0

0

11,2

0

42.99 Construction of other civil engineering projects n.e.c.

19,5

0

19,5

0

0

0

0

0

0

0

0

0

19,5

0

43.21 Electrical installation

0,2

0

0,2

0

0

0

0

0

0

0

0

0

0,2

45.11 Sale of cars and light motor vehicles

0,1

0

0,1

0

0

0

0

0

0

0

0

0

0,1

0

46.76 Wholesale of other intermediate products

5,8

1,5

5,8

0

0

0

0

0

0

0

0

0

5,8

1,5

49.10 Passenger rail transport, interurban

28,3

0

28,3

0

0

0

0

0

0

0

0

0

28,3

0

49.20 Freight rail transport

11,7

0

11,7

0

0

0

0

0

0

0

0

0

11,7

0

49.31 Urban and suburban passenger land transport

2,2

0

2,2

0

0

0

0

0

0

0

0

0

2,2

0

50.20 Sea and coastal freight water transport

1,0

0

1,0

0

0

0

0

0

0

0

0

0

1

0

52.21 Service activities incidental to land transportation

33,8

0

33,8

0

0

0

0

0

0

0

0

0

33,8

52.29 Other transportation support activities

0,01

0

0,01

0

0

0

0

0

0

0

0

0

0,01

0

53.10 Postal activities under universal service obligation

0,1

0,01

0,1

0

0

0

0

0

0

0

0

0

0,1

0,01

61.30 Satellite telecommunications activities

8,6

0

8,6

0

0

0

0

0

0

0

0

0

8,6

0

62.01 Computer programming activities

0,01

0

0,01

0

0

0

0

0

0

0

0

0

0,01

0

62.02 Computer consultancy activities

5,7

0

5,7

0

0

0

0

0

0

0

0

0

5,7

68.10 Buying and selling of own real estate

3,9

0

3,9

0

0

0

0

0

0

0

0

0

3,9

0

70.10 Activities of head offices

641,9

141,9

641,9

0

0

0

0

0

0

0

0

0

641,9

141,9

71.11 Architectural activities

0,000200,0002

0

0

0

0

0

0

0

0

0

0,0002077.39 Renting and leasing of other machinery, equipment and tangible goods n.e.c.

0,1

0

0,1

0

0

0

0

0

0

0

0

0

0,1

0

80.20 Security systems service activities

0,3

0

0,3

0

0

0

0

0

0

0

0

0

0,3

0

84.13 Regulation of and contribution to more efficient operation of businesses

10,6

0

10,6

0

0

0

0

0

0

0

0

0

10,6

0

86.10 Hospital activities

0,2

0

0,2

0

0

0

0

0

0

0

0

0

0,2

0

23.41 Manufacture of ceramic household and ornamental articles
24.51 Casting of iron27.51 Manufacture of electric domestic appliances
29.32 Manufacture of other parts and accessories for motor vehicles

282

0

0

0

0

SMEs and other NFC not

MillionEUR

Of whichenvironmentally
sustainable

SUSTAINABILITY REPORT 2023

3.1. GAR KPI stock based on turnover
Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Proportion of total covered assets funding Taxonomy-

Proportion of total covered assets funding

relevant sectors (Taxonomy-eligible)

Taxonomy-relevant sectors (Taxonomy-eligible)

Proportion of total covered assets funding% (compared to total covered assets in the denominator)

Taxonomy-relevant sectors (Taxonomy-aligned)

Water and marine resources (WTR)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)

31 December 2023
Circular economy (CE)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Pollution (PPC)

Biodiversity and Ecosystems (BIO)TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Proportion of total covered assets funding

Proportion of total covered assets funding

Proportion of total covered assets funding Taxonomy-

Taxonomy-relevant sectors (Taxonomy-eligible) Taxonomy-relevant sectors (Taxonomy-eligible)

relevant sectors (Taxonomy-eligible)

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets funding

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

Taxonomy-relevant sectors (Taxonomy-

Proportion of(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)aligned)total assets
coveredOf which Useof Proceeds

Of which

Of whichtransitional enabling

Of which Use Of which

Of which Use Of which

Of which Use Of which

Of which Use Of which

Of which Use Of which

Of which Useof Proceeds

enablingof Proceeds

enablingof Proceeds

enablingof Proceeds

enablingof Proceeds

enablingof Proceeds

Of which

Of whichtransitional enabling

GAR - Covered assets in both numerator and denominator
1

Loans and advances, debt securities and equity instruments

42%

5%

5%

0%

0%

2%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

44%

5%

5%

0%

0%

18%
17%

6%
17%

6%
17%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

18%
17%

6%
17%

6%
17%

0%
0%

0%
0%

3%

Loans and advances
Debt securities, including UoP
Equity instruments

0%
23%

0%
23%

0%
23%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
23%

0%
23%

0%
23%

0%

0%

0%
0%
0%

0%
0%
0%

0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

Other financial corporations

18%
29%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

18%
29%

0%
0%

0%
0%

0%
0%

0%
0%

2%

Loans and advances
Debt securities, including UoP
Equity instruments

61%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

61%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

12
13
14

of which management companies

87%
99%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

87%

Loans and advances
Debt securities, including UoP

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

15
16

Equity instrumentsof which insurance undertakings

0%
32%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
32%

0%
0%

0%

0%
0%

0%
0%

0%
0%

17
18

Loans and advances
Debt securities, including UoP
Equity instruments

32%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

32%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

12%

1%
0%

0%
0%
0%

0%
0%
0%

1%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

12%

1%
0%

1%

0%
0%
0%

38%
50%

1%

1%

0%
0%
0%

0%
0%
0%

1%
1%
1%

0%

0%

0%

0%

0%

0%

0%

0%

0%

2
3
4
5
6
7
8
9
10
11

19
20
21
22
23
24

not HfT eligible for GAR calculation
Financial undertakings
Credit institutionsof which investment firms

Non-financial undertakings
Loans and advances
Debt securities, including UoP
Equity instruments
Households

25

of which loans collateralised by residential immovable
property

26

of which building renovation loans

27
28
29

of which motor vehicle loans
Local governments financing

30

Other local government financing
Collateral obtained by taking possession: residential

31

Housing financing

and commercial immovable properties
32 Total GAR assets

0%
0%

0%
0%
38%
50%
31%

4%
17%

0%
0%
99%

0%
0%

32%

4%
17%

47%

1%
1%
0%
1%

0%
45%

0%
5%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
45%

0%

5%

5%

5%

0%
0%

0%
0%

0%
41%

60%

6%

6%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

60%

6%

6%

0%

0%

31%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

100%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

67%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

67%

0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

1%
0%

0%

0%

0%

0%

0%

67%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

67%

0%

0%

0%

0%

1%

100%

1%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

100%

1%

0%

0%

0%

0%

26%

3%

3%

0%

0%

1%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

27%

3%

3%

0%

0%

47%

283

SUSTAINABILITY REPORT 2023
Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Proportion of total covered assets funding

Proportion of total covered assets funding

Taxonomy-relevant sectors (Taxonomy-eligible)

Taxonomy-relevant sectors (Taxonomy-eligible)

Water and marine resources (WTR)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)

31 December 2022
Circular economy (CE)
Proportion of total covered assets funding

Pollution (PPC)

Biodiversity and Ecosystems (BIO)TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Proportion of total covered assets funding

Proportion of total covered assets funding

Proportion of total covered assets funding Taxonomy-

Taxonomy-relevant sectors (Taxonomy-eligible) Taxonomy-relevant sectors (Taxonomy-eligible) Taxonomy-relevant sectors (Taxonomy-eligible)

relevant sectors (Taxonomy-eligible)

Proportion of total covered assets funding

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets funding

Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

Taxonomy-relevant sectors(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)% (compared to total covered assets in the denominator)

Proportionof total
assetscoveredOf which
Use ofProceeds

Of which

Of whichtransitional

enabling

Of which
Use ofProceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of whichtransitional

enabling

GAR - Covered assets in both numerator and denominator
1

Loans and advances, debt securities and equity instruments

42%

3%

3%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

42%

3%

3%

0%

0%

2

Financial undertakings

11%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

11%

0%

0%

0%

0%

3

Credit institutions

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

1%

4

Loans and advances

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

5
6

Debt securities, including UoP
Equity instruments

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

1%
0%

7
8

Other financial corporations

15%
19%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

15%
19%

0%
0%

0%
0%

0%
0%

0%
0%

2%

58%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

58%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%

0%
0%
0%

0%
0%

11

Loans and advances
Debt securities, including UoP
Equity instruments

12of which management companies

96%

0%

0%

0%

0%

0%

0%

0%

0%

99%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%
0%
0%

0%
0%
0%

0%

0%

0%
0%

0%

0%
0%

0%
0%

96%

0%

0%
0%

0%

0%

0%
0%

0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%

99%

0%
0%

0%

Loans and advances
Debt securities, including UoP

0%
0%
0%

0%

13
14

0%
0%
0%

15
16

Equity instrumentsof which insurance undertakings

0%
50%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
50%

0%
0%

0%

0%
0%

0%
0%

0%
0%

17
18

Loans and advances
Debt securities, including UoP

50%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

50%

0%
0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

Equity instruments

0%
0%
0%

0%
0%

19

0%
0%
0%

0%

0%

0%

20

Non-financial undertakings

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

1%
2%
0%

0%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

1%
1%
1%

0%

0%

0%

0%

0%

0%

9
10

21
22
23
24

not HfT eligible for GAR calculationof which investment firms

Loans and advances
Debt securities, including UoP
Equity instruments
Households

0%
0%

0%

1%
2%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%
0%

0%
0%

0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%

0%

48%
3%

1%
1%
0%
0%
0%

0%
47%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
47%

0%
4%

0%

0%

0%
0%

0%

4%

0%
0%

0%

4%

4%

0%

0%

0%
41%

25

of which loans collateralised by residential immovable
property

61%

5%

5%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

61%

5%

5%

0%

0%

31%

26

of which building renovation loans

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%

0%
0%
0%

0%
0%

0%
0%

0%
0%

0%

1%
0%

27
28
29

of which motor vehicle loans
Local governments financing
Housing financing

100%

0%

0%
0%

0%
0%

0%

0%
0%

30

Other local government financing
Collateral obtained by taking possession: residential

0%

0%

0%

0%

0%

0%

0%

0%

100%

1%

0%

0%

0%

0%

0%

25%

2%

2%

0%

0%

0%

0%

31
and commercial immovable properties
32 Total GAR assets

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

284

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

100%

1%

0%

0%

0%

0%

0%

0%

0%

0%

25%

2%

2%

0%

0%

48%

1%

SUSTAINABILITY REPORT 2023

3.2. GAR KPI stock based on CapEx
Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Proportion of total covered assets funding

Proportion of total covered assets funding

Taxonomy-relevant sectors (Taxonomy-eligible)

Taxonomy-relevant sectors (Taxonomy-eligible)

Water and marine resources (WTR)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)

31 December 2022
Circular economy (CE)
Proportion of total covered assets funding

Pollution (PPC)

Biodiversity and Ecosystems (BIO)TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Proportion of total covered assets funding

Proportion of total covered assets funding

Proportion of total covered assets funding Taxonomy-

Taxonomy-relevant sectors (Taxonomy-eligible) Taxonomy-relevant sectors (Taxonomy-eligible) Taxonomy-relevant sectors (Taxonomy-eligible)

relevant sectors (Taxonomy-eligible)

Proportion of total covered assets funding

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets funding

Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

funding Taxonomy-relevant sectors

Taxonomy-relevant sectors(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)(Taxonomy-aligned)% (compared to total covered assets in the denominator)

Proportionof total
assetscoveredOf which
Use ofProceeds

Of which

Of whichtransitional

enabling

Of which
Use ofProceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which

Use ofenabling

Proceeds

Of which

Of whichtransitional

enabling

GAR - Covered assets in both numerator and denominator
1

Loans and advances, debt securities and equity instruments

42%

3%

3%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

42%

3%

3%

0%

0%

2

Financial undertakings

11%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

11%

0%

0%

0%

0%

not HfT eligible for GAR calculation

48%
3%

3

Credit institutions

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

1%

4

Loans and advances

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

5
6

Debt securities, including UoP
Equity instruments

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

1%
0%

7
8

Other financial corporations

15%
19%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

15%
19%

0%
0%

0%
0%

0%
0%

0%
0%

2%

58%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

58%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%

0%
0%
0%

0%
0%

11

Loans and advances
Debt securities, including UoP
Equity instruments

12of which management companies

96%

0%

0%

0%

0%

0%

0%

0%

0%

99%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%
0%
0%

0%
0%
0%

0%

0%

0%
0%

0%

0%
0%

0%
0%

96%

0%

0%
0%

0%

0%

0%
0%

0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%

99%

0%
0%

0%

Loans and advances
Debt securities, including UoP

0%
0%
0%

0%

13
14

0%
0%
0%

15
16

Equity instrumentsof which insurance undertakings

0%
50%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
50%

0%
0%

0%

0%
0%

0%
0%

0%
0%

17
18

Loans and advances
Debt securities, including UoP

50%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

50%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

Equity instruments

0%
0%
0%

0%
0%

19

0%
0%
0%

0%

0%

0%

20

Non-financial undertakings

0%

0%
0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

1%
2%
0%

0%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
47%

0%
4%

0%

0%

9
10

21
22
23
24

of which investment firms

Loans and advances
Debt securities, including UoP
Equity instruments
Households

25

of which loans collateralised by residential immovable
property

26

of which building renovation loans

27
28
29

of which motor vehicle loans
Local governments financing

30

Other local government financing
Collateral obtained by taking possession: residential

31

Housing financing

and commercial immovable properties
32 Total GAR assets

0%
0%

0%

0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%
0%

0%
0%

0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%
0%

0%

0%
0%

0%
0%

0%

1%
1%
0%
0%
0%

1%
2%
0%

0%
0%
0%

0%
47%

0%
4%

4%

0%

0%
0%

0%

0%

0%

0%

0%

0%
0%

4%

0%

0%

0%
41%

61%

5%

5%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

61%

5%

5%

0%

0%

31%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

100%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

1%
0%

0%
0%
0%

0%
0%
0%

0%

1%
1%
1%

0%

0%
0%
0%

0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

1%

100%

1%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

100%

1%

0%

0%

0%

0%

25%

2%

2%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

25%

2%

2%

0%

0%

48%

0%
0%

285

SUSTAINABILITY REPORT 2023
Climate Change Mitigation (CCM)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Climate Change Adaptation (CCA)
Proportion of total covered assets
funding Taxonomy-relevant sectors

Water and marine resources (WTR)
Proportion of total covered assets
funding Taxonomy-relevant sectors(Taxonomy-eligible)
Proportion of total covered
assets funding Taxonomy-(Taxonomy-eligible)
Proportion of total covered
assets funding Taxonomy-

eligible)
Proportion of total covered
assets funding Taxonomy-

eligible)
Proportion of total covered
assets funding Taxonomy-(Taxonomy-eligible)
Proportion of total covered
assets funding Taxonomy-

relevant sectors (Taxonomy-

relevant sectors (Taxonomy-

relevant sectors (Taxonomy-

relevant sectors (Taxonomy-

relevant sectors (Taxonomy-aligned)aligned)aligned)aligned)aligned)

Proportion of total covered assets
funding Taxonomy-relevant sectors% (compared to total covered assets in the denominator)

31 December 2022
Circular economy (CE)
Pollution (PPC)
Proportion of total covered assets funding Proportion of total covered assets funding
Taxonomy-relevant sectors (TaxonomyTaxonomy-relevant sectors (Taxonomy-(Taxonomy-aligned)

Of which
Of which
Of which
Use oftransitional enabling
Proceeds

Of which
Use ofOfwhich

Of which
Use ofProceeds

enabling

Proceeds

Of which
Use of

Of whichenabling

Proceeds

Of which
Use of

Of whichenabling

Proceeds

Biodiversity and Ecosystems (BIO)
Proportion of total covered assets
funding Taxonomy-relevant sectors

Of which
Use of

Of whichenabling

Proceeds

TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)
Proportion of total covered assets
funding Taxonomy-relevant sectors(Taxonomy-aligned)

Of which
Use of

Of whichenabling

Proceeds

Of which

Proportionof total assets
coveredOf
whichtransitional enabling

GAR - Covered assets in both numerator and denominator
1

Loans and advances, debt securities and equity

43%

3%

3%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

43%

3%

3%

0%

0%

11%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

11%
0%

0%
0%

0%
0%

0%
0%

0%
0%

3%

Credit institutions

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

5

Loans and advances
Debt securities, including UoP

6
7
8

Equity instruments
Other financial corporationsof which investment firms

0%
15%
19%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
15%
19%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%

Loans and advances
Debt securities, including UoP
Equity instruments

58%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

58%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%

12
13

of which management companies
Loans and advances

96%
99%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

96%
99%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

14

Debt securities, including UoP
Equity instrumentsof which insurance undertakings

0%
0%
50%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%
0%

0%
0%
50%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

Loans and advances
Debt securities, including UoP
Equity instruments

50%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
100%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

50%

0%
0%

0%
100%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

25%
39%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

25%
40%

0%
0%

0%
0%

0%
0%

0%
0%

1%
1%

10%

0%
0%
4%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%

0%

0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

10%

0%
0%
4%

0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

4%

0%
0%
0%

4%

0%
0%
0%

0%
0%
0%

1%
0%
41%

2
3
4

9
10
11

15
16
17
18
19
20
21
22
23
24

instruments not HfT eligible for GAR calculation
Financial undertakings

Non-financial undertakings
Loans and advances
Debt securities, including UoP
Equity instruments
Households

0%
47%

0%

0%

0%

0%

0%

0%

0%
47%

0%

48%

1%
1%
2%
1%
1%
0%

25

of which loans collateralised by residential immovable
property

61%

5%

5%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

61%

5%

5%

0%

0%

31%

26

of which building renovation loans

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

1%

27
28

of which motor vehicle loans
Local governments financing

100%

29
30

Housing financing
Other local government financing
Collateral obtained by taking possession: residential

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%

0%

0%
0%

0%

0%

100%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

100%

0%

0%

0%

0%

0%

26%

2%

2%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

26%

2%

2%

0%

0%

48%

31

and commercial immovable properties
32 Total GAR assets

0%

286

1%

SUSTAINABILITY REPORT 2023

4.1. GAR KPI flow based on turnover
31 December 2023
Climate Change Mitigation (CCM)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Climate Change Adaptation (CCA)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-

Proportion of total covered assets funding% (compared to flow of total eligible assets)

Taxonomy-relevant sectors(Taxonomy-aligned)
Of which
Use ofProceeds

Water and marine resources (WTR)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-

Circular economy (CE)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-

eligible)
Proportion of total covered

eligible)
Proportion of total covered

eligible)
Proportion of total covered

assets funding Taxonomyrelevant sectors (Taxonomy-

assets funding Taxonomyrelevant sectors (Taxonomy-

assets funding Taxonomyrelevant sectors (Taxonomy-aligned)aligned)aligned)Of which
Of whichtransition
enablingal

Of which
Use ofProceeds

Of which

Of which Use Of whichenablingof Proceeds

enabling

Of which
Use ofProceeds

Pollution (PPC)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-

Biodiversity and Ecosystems (BIO)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-

eligible)eligible)

TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets funding

funding Taxonomy-relevant

funding Taxonomy-relevantTaxonomy-relevant sectors

sectors (Taxonomy-aligned)

sectors (Taxonomy-aligned)(Taxonomy-aligned)

Of which

Of which

Use ofenabling

Proceeds

Of which

Of which Use Of whichenablingof Proceeds

enabling

Of which
Use ofProceeds

Proportion of
total newassets covered

Of which
Of whichtransition
enablingal

GAR - Covered assets in both numerator and denominator
12
3
4

Loans and advances, debt securities and equity instruments not HfTeligible for GAR calculation
Financial undertakings
Credit institutions

0%

2%

1%

0%

0%

2%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

2%

2%

1%

0%

0%

0,69%

8%
21%

6%
21%

6%
21%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

8%
21%

6%
21%

6%
21%

0%

0%

0%

0%
0%
0%

0%
0%
0%

0,06%
0,24%
-0,01%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

31%

31%

31%

0%

0%

Loans and advances

0%

0%

0%

5
6

Debt securities, including UoP
Equity instruments

31%

31%

31%

0%

0%

0%
0%

0%
0%

0,25%
0,00%

7
8

Other financial corporations
Loans and advances

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

2%
4%
13%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

-0,18%-0,24%

9

2%
4%
13%

10

Debt securities, including UoP
Equity instrumentsof which management companies

0%
0%
-71%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
-71%

0%
0%
0%

0%
0%
0%

0%
0%
0%

-0,56%

0%

0%
0%
0%

0%

0%

0%
0%
0%

0%

0%

0%
0%
0%

0%

0%

0%
0%
0%

0%

0%

0%
0%
0%

0%

11
12
13
14

Loans and advances
Debt securities, including UoP

-73%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

-0,03%

0%

0%
0%

0%

0%

0%
0%

0%

0%

0%
0%

-73%

0%

0%
0%

0%

0%

0%
0%

15

Equity instrumentsof which insurance undertakings

0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
-8%
-8%

0%
0%

0%
0%

0%
0%

0%
0%
0%

0,00%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%
0%

0%

Loans and advances

0%
-8%
-8%

Debt securities, including UoP
Equity instruments

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
22%

0%
0%

0%

0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%
0%

0%
0%

0%
22%

0%
0%

0%

0%

0%
0%

0%

0%

0%
0%

0%

0%

0%
0%

0%
0%

0%
0%

0,00%
0,00%

10%

1%
0%

0%
0%
0%

0%
0%

1%
0%

0%
0%

0%
0%
0%

0%

0%
0%

0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

10%
-10%

10%

0%
0%

0%
0%

1%
0%

0%
0%

0%
0%

0,16%
-0,18%

0%

0%
0%
0%

0%

0%

0%
0%

0%
0%
0%

0%

0%

0%
0%
0%

0%

2%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%

31%

2%

0%

0%

0,34%

0%

0%

0%
0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%

0%

0%

0%
0%

1%
2%

1%
2%

0%
0%
0%

0%
0%
0%

0,00%

0%
0%

0%
-1%
-1%

0%

0%
0%

0%
0%

0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0,00%
0,00%

16
17
18
19
20

of which investment firms

Non-financial undertakings

21
22

Loans and advances

9%
-10%

Debt securities, including UoP

29%

23
24

Equity instruments
Households

0%
-1%

1%
20%

2%

0%

0%

1%
2%

0%

0%
0%

0%

0%
0%

0%
0%

0%

1%
20%

0%

0%
0%

0,07%
0,25%
-0,03%
0,00%
0,01%
0,01%

25

of which loans collateralised by residential immovable property

-1%

1%
2%

0%

0%

26

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

27

of which building renovation loansof which motor vehicle loans

28
29
30

Local governments financing
Housing financing
Other local government financing

0%
0%

0%
0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%
0%
0%

0%

0%
0%
0%

0%
0%

0%

56%
0%
56%

0%
0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

0%

56%
0%
56%

0%
0%

0%

0%

-0,27%
0,00%-0,27%

31

Collateral obtained by taking possession: residential andcommercial immovable properties

-31%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

-31%

0%

0%

0%

0%

-0,15%

0%

1%

1%

0%

0%

1%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

1%

1%

1%

0%

0%

1%

32 Total GAR assets

287

0%

0,89%
0,01%

SUSTAINABILITY REPORT 2023

4.2. GAR KPI flow based on CapEx
31 December 2023
Climate Change Mitigation (CCM)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Climate Change Adaptation (CCA)
Proportion of total covered assets funding

Water and marine resources (WTR)
Proportion of total covered assets funding

Circular economy (CE)
Proportion of total covered assets funding

Pollution (PPC)
Proportion of total covered assets funding

Biodiversity and Ecosystems (BIO)
Proportion of total covered assets funding

Taxonomy-relevant sectors (Taxonomy-

Taxonomy-relevant sectors (Taxonomy-

Taxonomy-relevant sectors (Taxonomy-

Taxonomy-relevant sectors (Taxonomy-

Taxonomy-relevant sectors (Taxonomy-

eligible)
Proportion of total covered

Proportion of total covered assets funding% (compared to flow of total eligible assets)

assets funding Taxonomyrelevant sectors (Taxonomy-

Taxonomy-relevant sectors(Taxonomy-aligned)
Of which Useof Proceeds

Of whichtransitionaleligible)aligned)Of which

Of whichenabling

enabling

eligible)relevant sectors (Taxonomy-eligible)

eligible)

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets

Proportion of total covered assets funding

funding Taxonomy-relevant

funding Taxonomy-relevant

funding Taxonomy-relevant

funding Taxonomy-relevantTaxonomy-relevant sectors (Taxonomy-

Proportion of
total new assets

sectors (Taxonomy-aligned)

sectors (Taxonomy-aligned)

sectors (Taxonomy-aligned)

sectors (Taxonomy-aligned)aligned)coveredOf which

Of which

Of which

Of which

Of which

Use ofProceeds

eligible)

TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding Taxonomy-

Of which

Use ofProceeds

enabling

Of which

Use ofProceeds

enabling

Of which

Use ofProceeds

enabling

Of which

Use ofProceeds

enabling

Of which

Of which

Use ofProceeds

transitional

Of whichenabling

GAR - Covered assets in both numerator and denominator
1

Loans and advances, debt securities and equity instruments not HfTeligible for GAR calculation

1%

2%

1%

0%

0%

2%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

2%

2%

1%

0%

0%

0,69%

8%
21%

6%
21%

6%
21%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

8%
21%

6%
21%

6%
21%

0%
0%

0%
0%

0,06%
0,24%

0%
31%

0%
31%

0%
31%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
31%

-0,01%

0%
0%

0%
31%

0%

0%
0%

0%
31%

0%

0%
0%

0%

0%

0%
0%

0%

0%

0%

0%

0%
0%

0%
0%

0,25%
0,00%

2%
4%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

2%
4%

0%
0%

0%
0%

0%
0%

0%
0%

-0,18%-0,24%

Loans and advances
Debt securities, including UoP
Equity instruments

13%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

13%

0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0,07%
-0,56%of which management companies

-71%
-73%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

-71%
-73%

0%
0%

0%
0%

0%
0%

0%
0%

-0,03%-0,03%

Debt securities, including UoP
Equity instruments

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0%
0%

0%

0%
0%

0%
0%

0,00%
0,00%

of which insurance undertakings

-8%
-8%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

-8%
-8%

0%

0%
0%
0%

0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0,01%
0,01%
0,00%

0%
40%

0%
13%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%

0%
0%

0%
41%

0%
13%

1%

0%
0%

0%
0%

0,00%

0%

0%
0%

0%

0%

0%
0%

0%

0%

0%
0%

0%

0%

0%
0%

0%

1%

0%
0%

0%

1%

37%
43%

3%
23%

0%
0%

0%
0%

0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

0%
0%
0%

37%
45%

3%
23%

0%

0%

0%
0%
0%

-0,18%

2%

0%
0%
0%

2
3

Financial undertakings

4

Loans and advances

5
6

Debt securities, including UoP
Equity instruments

7
8

Other financial corporations

9
10
11
12
13
14
15
16
17
18
19
20
21
22

Credit institutionsof which investment firms

Loans and advances

Loans and advances
Debt securities, including UoP
Equity instruments
Non-financial undertakings
Loans and advances
Debt securities, including UoP
Equity instruments

0%

0%
0%

0,25%

0,16%

0%

0%

0%

0%

2%
0%

0%

0%
0%
0%

of which loans collateralised by residential immovable property

-1%
-1%

1%
2%

1%
2%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

-1%
-1%

1%
2%

1%
2%

0%
0%

0%
0%

0,89%

25
26
27

of which building renovation loansof which motor vehicle loans

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%

0%

0%

0%

0%

0%

0%

0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0,00%
0,00%

0%

0%

0%

0%

0%

56%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

56%

0%

0%

0%

0%

-0,27%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
56%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
0%

0%
56%

0%
0%

0%
0%

0%
0%

0%
0%

0,00%
-0,27%

-31%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

-31%

0%

0%

0%

0%

-0,15%

0%

1%

1%

0%

0%

1%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

1%

1%

1%

0%

0%

1%

23
24

28
29
30
31

Households

Local governments financing
Housing financing
Other local government financing
Collateral obtained by taking possession: residential andcommercial immovable properties

32 Total GAR assets

2%

288

0%
0%

0%

0,34%
0,00%
0,01%

SUSTAINABILITY REPORT 2023

5.1. KPI off-balance sheet exposures based on turnover
Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Water and marine resources (WTR)

Proportion of total covered assets funding Taxonomy-relevant
sectors (Taxonomy-eligible)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)% (compared to total eligible
off-balance sheet assets)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-aligned)

Proportion of total covered assets
funding Taxonomy-relevant

Proportion of total covered assets
funding Taxonomy-relevant

sectors (Taxonomy-aligned)

sectors (Taxonomy-aligned)

Of which
Use ofProceedsOf
whichenabling

Of which
Use ofProceedsOf
whichenabling

Of which Use Of which Of whichof Proceeds transitional enabling

31 December 2023
Circular economy (CE)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)

Pollution (PPC)

Biodiversity and Ecosystems (BIO)TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Proportion of total covered
assets funding Taxonomyrelevant sectors (Taxonomyaligned)
Of which
Use ofProceeds

Of whichenabling

Proportion of total covered assets
funding Taxonomy-relevant sectors

Proportion of total covered assets
funding Taxonomy-relevant(Taxonomy-aligned)

sectors (Taxonomy-aligned)

Of which
Use ofProceedsOf
whichenabling

Of which
Use ofProceedsOf
whichenabling

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyaligned)
Of which
Use ofProceeds

Of which Of whichtransitional enabling

1 Financial guarantees (FinGuar KPI)

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

2 Assets under management (AuM KPI)

6,12%

0,91%

0,00%

0,00%

0,62%

0,09%

0,07%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

6,19%

1,00%

0,00%

0,00%

0,62%

5.2. KPI off-balance sheet exposures based on CapEx
Climate Change Mitigation (CCM)

Climate Change Adaptation (CCA)

Water and marine resources (WTR)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)% (compared to total eligible
off-balance sheet assets)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-aligned)

Of which
Use ofProceeds

31 December 2023
Circular economy (CE)
Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)

Pollution (PPC)

Biodiversity and Ecosystems (BIO)TOTAL (CCM + CCA + WTR + CE + PPC + BIO)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyeligible)

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomy-eligible)

Proportion of total covered assets
funding Taxonomy-relevant
sectors (Taxonomy-aligned)

Proportion of total covered assets
funding Taxonomy-relevant
sectors (Taxonomy-aligned)

Proportion of total covered assets
funding Taxonomy-relevant
sectors (Taxonomy-aligned)

Proportion of total covered assets
funding Taxonomy-relevant
sectors (Taxonomy-aligned)

Proportion of total covered
assets funding Taxonomyrelevant sectors (Taxonomyaligned)

Of which
Use ofProceedsOf
whichenabling

Of which
Use ofProceedsOf
whichenabling

Of which
Use ofProceeds

Of whichenabling

Of which
Use ofProceedsOf
whichenabling

Of which
Use ofProceedsOf
whichenabling

Of which Of whichtransitional enabling

Proportion of total covered assets funding
Taxonomy-relevant sectors (Taxonomyaligned)

Of which Use Of which Of whichof Proceeds transitional enabling

1 Financial guarantees (FinGuar KPI)

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

2 Assets under management (AuM KPI)

7,13%

3,14%

0,00%

0,10%

2,28%

0,23%

0,19%

0,00%

0,02%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

0,00%

7,35%

3,33%

0,00%

0,10%

2,30%

6. Disclosures according to Annex XII - Nuclear energy and fossil gas related activities
6.1. Nuclear energy and fossil gas activities
Nuclear energy related activities
1
2
3

The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes
with minimal waste from the fuel cycle.
The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or
industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.
The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial
processes such as hydrogen production from nuclear energy, as well as their safety upgrades.

No
No
No

Fossil gas related activities
4

The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.

Yes

5

The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.

Yes

6

The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.

No

289

SUSTAINABILITY REPORT 2023

6.2. Aligned activities - Denominator
Amount and proportion
Economic activities based on KPI TurnoverRow

CCM + CCA

Million EUR
1
2
3
4
5
6

Amount and proportion of Taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPI

Climate change

Climate change

mitigation (CCM)

adaptation (CCA)

Amount%Amount%Amount

%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

7

Amount and proportion of other Taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI

1 934

100%

1 934

100%

0

0%

8

Total green asset ratio, Turnover

1 934

3%

1 934

3%

0

0%

Amount and proportion
Economic activities based on KPI CAPEX

Row

CCM + CCA
Million EUR
1
2
3
4
5
6

Amount and proportion of Taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of theapplicable KPI

Climate change

Climate change

mitigation (CCM)

adptation (CCA)

Amount%Amount%Amount

%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

7

Amount and proportion of other Taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI

1 963

0%

1 963

0%

0

0%

8

Total green asset ratio, CAPEX

1 963

3%

1 963

3%

0

0%

290

SUSTAINABILITY REPORT 2023

6.3. Aligned activities – Numerator
Amount and proportion
Economic activities based on KPI TurnoverRow

CCM + CCA

Million EUR
1
2
3
4
5
6

Amount and proportion of Taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPI

Climate change

Climate change

mitigation (CCM)

adaptation (CCA)

Amount%Amount%Amount

%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

7

Amount and proportion of other Taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI

1 934

100%

1 934

100%

0

0%

8

Total amount and proportion of Taxonomy-aligned economic activities in the numerator of the total green asset ratio based on turnover

1 934

100%

1 934

100%

0

0%

Amount and proportion
Economic activities based on KPI CapEx

Row

CCM + CCA

Million EUR
1
2
3
4
5
6

Amount and proportion of Taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPIAmount and proportion of Taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of
the applicable KPI

Climate change

Climate change

mitigation (CCM)

adptation (CCA)

Amount%Amount%Amount

%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

7

Amount and proportion of other Taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI

1 963

100%

1 963

100%

0

0%

8

Total amount and proportion of Taxonomy-aligned economic activities in the numerator of the total green asset ratio based on turnover

1 963

100%

1 963

100%

0

0%

291

SUSTAINABILITY REPORT 2023

6.4. Eligible but not aligned activities
Amount and proportion
Economic activities based on KPI TurnoverRow

CCM + CCA

Million EUR
1
2
3
4
5
6

Amount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPI

Climate change

Climate change

mitigation (CCM)

adaptation (CCA)

Amount%Amount%Amount

%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

3

0%

3

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

7

Amount and proportion of other Taxonomy-eligible but not Taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI

15 744100%

15 087

0%

657

100%

8

Total amount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activities in the denominator of the eligible ratio based on turnover

15 74789%

15 090

85%

657

0%

Amount and proportion
Economic activities based on KPI Capex

Row

CCM + CCA

Million EUR
1
2
3
4
5
6

Amount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPI

Climate change

Climate change

mitigation (CCM)

adptation (CCA)

Amount%Amount%Amount

%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

0

0%

7

Amount and proportion of other Taxonomy-eligible but not Taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI

15 798100%

15 141

100%

657

100%

8

Total amount and proportion of Taxonomy-eligible but not Taxonomy-aligned economic activities in the denominator of the eligible ratio based on turnover

15 79889%

15 141

11%

657

4%

292

SUSTAINABILITY REPORT 2023

6.5. Non-eligible activities
Economic activities based on KPI Turnover

Row
1
2
3
4
5
6
7
8

Million EUR
Amount and proportion of economic activity referred to in row 1 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of economic activity referred to in row 2 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of economic activity referred to in row 3 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of economic activity referred to in row 4 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominatorof the applicable KPIAmount and proportion of economic activity referred to in row 5 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of economic activity referred to in row 6 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of other Taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI
Total amount and proportion of Taxonomy-non-eligible economic activities in the denominator of the applicable KPI(non-eligible ratio turnover)Economic activities based on KPI Capex

Row
1
2
3
4
5
6
7
8

Million EUR
Amount and proportion of economic activity referred to in row 1 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of economic activity referred to in row 2 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of economic activity referred to in row 3 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of economic activity referred to in row 4 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominatorof the applicable KPIAmount and proportion of economic activity referred to in row 5 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of economic activity referred to in row 6 of Template 1 that is Taxonomy-non-eligible in accordance with Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of
the applicable KPIAmount and proportion of other Taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI
Total amount and proportion of Taxonomy-non-eligible economic activities in the denominator of the applicable KPI(non-eligible ratio turnover)293

Amount

%

0

0%

0

0%

0

0%

25

0%

0

0%

0

0%

48 113100%

48 13873%

Amount

%

0

0%

0

0%

0

0%

25,3

0%

0

0%

0

0%

48 033100%

48 0580,73

SUSTAINABILITY REPORT 2023

Sustainability Report 2023
© 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 atCommercial Registry Office of Oporto
under the Single Registration and
Tax Identification Number 501 525 882[GRI 2-3]
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
paulo.neves@millenniumbcp.pt
sempremelhor@millenniumbcp.pt

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.

294

SUSTAINABILITY REPORT 2023

295