**EXHIBIT 11**
**National Bank of Greece**
**Code of Ethics for Financial Professionals**
     This Code of Ethics, applies to the following directors, officers andemployees:
 • The executive members of the NBG Board of Directors (i.e. theChairman and Governor and Deputy Governor of NBG), the ChiefFinancial Officer of NBG, and the Manager ofthe Financial and Management Accounting Division of NBG;  • The executive members of the Board of Directors of each NBGsubsidiary, and the Chief Financial Officer of each subsidiary(together with NBG referred to as **“Group Company”**);  • All persons serving in a Division or department of any GroupCompany, who are responsible for preparing the financial statements andrecording the financial results of a Group Company, and for preparingthe consolidated financial statements of NBG or any Group Company thatis required to prepare separate consolidated financial statements;  • All employees serving in Divisions and other departments of NBG whoare responsible for investor relations.
     The individuals identified above are collectively referred to in this Code ofEthics as “**Financial Professionals”**. Each Financial Professional agrees asfollows:
(1) To comply with all laws, rules and regulations applicable to each GroupCompany, including the rules and regulations of self-regulatory organizationsof which any Group Company is a member.
(2) To demonstrate personal integrity and engage in and promote honest andethical conduct in the performance of such Financial Professional’s duties,including in situations where there is an actual or apparent conflict ofinterest between his or her personal and professional relationships. FinancialProfessionals who are subject to the provisions of paragraphs 15 to 23 of theNBG By-Laws must comply with the requirements set forth therein. All otherFinancial Professionals must notify the Board of Directors or Audit Committeeof NBG of all personal or professional relationships or material transactionswhich might reasonably be expected to give rise to a conflict of interest.Financial Professionals who are employed by a Group Company other than NBG maynotify the Audit Committee of such Group Company, if such a committee has beenformed, of a conflict of interest. In such cases, the Audit Committee of thatGroup Company must notify the NBG Audit Committee of the conflict. In theabsence of an Audit Committee being formed at the Group Company employing thatFinancial Professional, the Financial Professional must notify the NBG AuditCommittee of all personal or professional relationships or materialtransactions which might reasonably be expected to give rise to a conflict ofinterest.
(3) To take all reasonable measures to protect the confidentiality of allnon-public information regarding Group Companies and their customers obtainedor created in connection with his or her duties, and to comply with allapplicable laws and

 

regulations regarding confidential information and customers’ personal data.Each Financial Professional agrees to take all reasonable measures to preventthe unauthorized disclosure of such information to any third party, unlessrequired to do so by applicable law or legal or regulatory process.
(4) To ensure that the information contained in (i) NBG’s reports and documentsfiled with or submitted to regulatory bodies, and (ii) NBG’s publiccommunications, are complete, accurate, timely and understandable, and that allsuch information is presented in accordance with applicable rules andregulations. In order to help ensure compliance with the Code of Ethics, eachFinancial Professional agrees to cooperate with NBG’s Disclosure andTransparency Committee and the Corporate Announcements Service, pursuant toparagraph 8 of the NBG By-Laws.
(5) To promptly notify the NBG Audit Committee or Internal Audit Division ofany violations of (i) any applicable law, rule or regulation, (ii) the Articlesof Association or By-Laws of any Group Company or (iii) this Code of Ethics.
(6) To establish and maintain a good working relationship with the externalauditors of NBG and the Group and to provide all necessary assistance for themto complete their audit.
(7) To certify in writing that he or she has read, understood and agrees tocomply fully with the Articles of Association and By-Laws of the Group Companyby whom such Financial Professional is employed and this Code of Ethics. EachFinancial Professional understands that he or she will be held accountable forany violations of the relevant Articles of Association and By-Laws or this Codeof Ethics, and that he or she may be disciplined for any violations, inaccordance with the applicable Staff Manual. Violations may also result incivil and criminal penalties against Financial Professionals, the GroupCompanies and their employees.
     Each Group employee should promptly report a violation or suspected violationto the Audit Committee or the Internal Audit Division of NBG. Such report willbe treated with confidentiality.